Privacy Notice

Last Updated: July 2, 2024

Version: 1.0

1. This Privacy Notice

We encourage you to carefully read this Privacy Notice as it provides you with information about your personal data being processed in connection with your access to and use of the Website. In this Privacy Notice we explain which types of personal data we hold on you, how we collect and process such data, how long we keep it, and so on.

In this Privacy Notice, personal data and personal information are used as synonyms and mean any information that directly or indirectly identifies you as an individual, as well as any information that permits the identity of an individual to whom the information applies to be reasonably inferred by either direct or indirect means.

2. Definitions

Unless otherwise provided in this Privacy Notice, capitalised terms used in this Privacy Notice have the meaning determined in the Real Games Legal Notice (the “Legal Notice”). We encourage you to read the Legal Notice carefully as they affect your obligations and legal rights.

3. Contact Details

When we say “we”, “us”, or “our”, we mean LC Ecosystem Ltd, a company established under the laws of the British Virgin Islands. With respect to personal data collected when you access and use the Website, we act as a data controller, meaning that we determine what data is collected, as well as the purposes and means of processing of your data.

We process your personal data in accordance with this Privacy Notice, and we endeavour to comply with the applicable data protection legislation. If you have any questions regarding this Privacy Notice or the processing of your personal data, do not hesitate to contact us at [insert email].

4. Type of Data

The categories of personal data we collect depend on how you interact with us, use the Website, and the requirements of the applicable laws. We collect and process the following types of personal data as outlined below. Please note that we may also collect certain other information, which may be required under the applicable laws.

Category of Data
Examples	Description	Other Comments
Analytical Data
internet protocol (IP) address	A unique address of a device, which may help to identify your approximate location (country, city, region, ZIP code). For better understanding, IP addresses are expressed as a set of numbers, for instance: 194.150.2.33. According to the Google Analytics documentation, the IP address is anonymised (masked), so neither we nor Google can identify the IP address and precise location of a particular visitor of the Website.	Google. Analytical Data are collected via Google Analytics, operated by Google Ireland Limited and its affiliates, including Google LLC (“Google”). More information regarding Google Analytics is available here. Cookies. Google gathers information by means of cookies. Cookies are, in effect, small data files that are placed on your device and by which it is possible to recognise this device when you interact with or return to the Website. Aggregated Data. Google creates reports, which contain the aggregated information about the use of the Website, where we do not see any data pertaining to a particular person. In other words, we cannot identify you and your actions from the other visitors and their actions. Role. With respect to Analytical Data, Google acts as our data processor. However, Google may use such personal data for any of its own purposes, in which case, Google acts as an independent data controller, and we shall not be related to or liable for such processing. You can learn more about how Google processes personal data in Google’s privacy policy.
browser details	This includes information about the browser type and its version.
device details	This includes information about the type of device (e.g., computer, tablet, or smartphone).
operating system	This includes information about the type and version of the operating system on your device (e.g., Windows 10, macOS version 12.4, etc.).
other information regarding the use of the Website	For instance, when you clicked a certain button or made some input.
Contact Data
full name	This may include your first name, last name and middle name, if any.	Please do not provide it unless it is reasonably necessary or requested by us.
contact details	This may include your email address or social media contacts.	–
any other data requested by us or data that you choose to provide us with	–	Please do not provide personal data unless it is reasonably necessary or requested by us.

5. Data Use

Category of Data	Description	Lawful Basis for Processing
Analytical Data	To analyse the use of the Website and provide a better user experience by improving their functionality, usability, user flow and interface.	Your consent. When you visit the Website, you are able to opt out from using Google Analytics. You also may object to the collection of personal data by Google Analytics by downloading and installing a browser add-on from Google.
Contact Data	To respond to your inquiry.	Our legitimate interest to respond to your inquiry.

6. Processing Period

As a general rule, we keep personal data as long as it is necessary for the purposes it was collected. We may process certain personal data longer than outlined below, if it is necessary:

(a) to meet our legal obligations under the applicable law;

(b) in relation to anticipated or pending legal proceedings; or

(c) to protect our rights and legitimate interests or those of third parties.

Category of Data	Storage Period	Rationale
Analytical Data	No storage period as the Analytical Data is anonymous, aggregated, and does not allow for identifying any particular person against the visitors of the Website.	If and to the extent we become able to identify any particular person, we will promptly update this Privacy Notice and establish a certain limitation period for processing the Analytical Data.
Contact Data	For one (1) year from the last date when you contacted us regarding the same matter.	We set this retention period due to the statutes of limitations established in the Legal Notice.

7. Data Sharing

General. We do not sell or rent out your data. However, we may share your personal data in accordance with this Privacy Notice, applicable legislation, or with your consent, in each case for the purposes of and if it is reasonably necessary:

1. to provide you with access to the Website and performance of our undertakings with you;

2. for compliance with the applicable laws and regulations; or

3. for our legitimate interest to maintain, improve and develop the Website.

Please note that if we share any portion of your personal data with third persons, we will endeavour to secure such transfer using appropriate legal, organisational, and technical measures.

Recipients. Given the purposes outlined above, your personal information is shared with the following categories of recipients:

1. Affiliates;

2. analytical solution providers, such as Google Analytics;

3. support and technical teams;

4. hosting service providers;

5. government authorities, upon their request or if necessary to comply with our legal obligations;

6. another entity if we sell or otherwise transfer the Website or their parts; and

7. other third-party solutions, which may be from time to time integrated in relation to the Website.

8. Automated Decision-Making

Automated decision-making is the process of making a decision by automated means without any human influence on the outcomes. We do not make any automated decisions based on your personal data. If we intend to process your personal data by any automated means, we will do our best to inform you about the same prior to such processing.

9. Data Subject Rights

Verification. In case you wish to exercise your data subject rights, we may request certain information from you to verify your identity and confirm that you have the right to exercise such rights.

Data Subject Rights. According to the applicable legislation, you may have the following rights:

Rights	Description
Right to access your personal data	You may ask us whether we process your personal data. If we process your data, you may request certain information about the processing activity and/or a copy of the personal data we hold about you, and check that we are lawfully processing it.
Right to rectification of the personal data	You may have your incomplete or inaccurate data to be completed or rectified. We may need to verify the accuracy of the new data you provide to us.
Right to erasure of your personal data (commonly known as a “right to be forgotten”)	You may ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also may ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal or technical reasons which will be notified to you, if applicable, at the time of your request.
Right to object to processing of your personal data	You may object to processing of your personal data when the processing is not in compliance with the applicable legislation. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Right to restrict the processing of your personal data	You may ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data’s accuracy, (ii) where our use of the data is unlawful, but you do not want us to erase it, (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, (iv) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data (commonly known as a “right to the data portability”)	Following your request, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which is processed based on your consent or performance of a contract with you.
Right to withdraw consent	You may withdraw your consent at any time, where we are relying on consent to process your personal data.
Right not to be subject to automated decision-making	If and to the extent applicable, you reserve the right not to be subject to a decision based solely on automated processing of data, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
Right to file a complaint	You may file a complaint with a relevant supervisory authority in case we violate your rights or obligations imposed on us under the applicable legislation. The relevant supervisory authority will particularly depend on where you are located.

10. Third-Party Links

The Website may include links and social media plugins to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share certain data about you. We do not control these third-party websites and applications, and are not responsible for their privacy statements. When you leave the Website, we encourage you to read the privacy policy/notice/statement of every website or application you visit.

11. Personal Data of Minors

The Website is not intended for the use of children (under 18 years old or older, if the country of your residence determines a higher age restriction). We do not knowingly market to, solicit, process, collect, or use personal data of children.

If we become aware that a child has provided us with personal information, we will use commercially reasonable efforts to delete such information from our database. If you are the parent or legal guardian of a child and believe that we have collected personal information from your child, please contact us.

12. Modifications and Updates of this Privacy Notice

We keep our Privacy Notice under regular review, and we may update it at any time. If we make any changes to this document, we will change the “Last Updated” date above. Please review this Privacy Notice to check for the updates. If we make substantial changes to the way we treat your personal information, we will display a notice on the Website.