On the basis of what legal provisions are or may be processed your personal data?

The rules on the protection of personal data (hereinafter referred to as the GDPR ) are set out, inter alia, in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (Text with EEA relevance), the country related special acts (lex specialis).

"Personal data" - means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is a person who can be directly or indirectly identified, in particular on the basis of an identifier such as name and surname, identification number, location data, internet identifier or one or more specific physical, physiological, genetic, mental factors, economic, cultural or social identity of a natural person,
"Processing" - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction,
"Controller" - means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law,
"Joint controller(s)" - Joint controller(s) occurs when at least two Controllers jointly determine the purposes and means of processing, they are Joint controllers (art. 26 GDPR),
"Supervisory authority" - means an independent public authority which is established by a Member State,
"Recipient" - means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing,
"Processor" - means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller,
"Third party" - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data,

"Third country" - an entity outside the EEA (European Economic Area) to which personal data is disclosed,
"Consent" - of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her,
"Privacy Policy" - this document, presenting information on the principles of personal data processing in accordance with the substantive scope indicated in art. art. 13 GDPR - information clause regarding the processing of personal data,
"Cookies Policy" - information on the use of cookies on the website run by the Controller. The Cookie Policy is available on the Controller's website,
"GDPR" - Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46 / EC (General Data Protection Regulation: http://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/page3g_en/page3g_ en?opendocument

Who does this Privacy Policy apply to?

This Privacy Policy (hereinafter referred to as PP) applies to the processing of personal data of natural persons, website users and players. The categories of personal data concerned are natural persons acting alone, natural persons acting on behalf of organizational units without legal personality, natural persons acting on behalf of legal persons (e.g. as members of their bodies, proxies, contact persons), in case of contractual relations this PP applies before the conclusion of a contract and after the conclusion thereof.

Who is the Controller?

Please be advised that Controller is Fulqrum Publishing Limited, 27, 25 Martiou Str., D. MICHAEL TOWER, Office 105A, Engomi, 2408, Nicosia, Cyprus, Tax No.: CY10268076B, Register No.: HE268076.

Contact details to the Controller

Please send inquiries regarding the protection of personal data to the Controller by traditional mail to the above-mentioned address or by e-mail to the address DPO.CY@fulqrumpublishing.com

Data Protection Officer

Please be advised that the Controller has not appointed a Data Protection Officer. Inquiries regarding the protection of personal data should be directed to the Controller by traditional mail to the Controller's address or by e-mail to the following address: DPO.CY@fulqrumpublishing.com

Information about Joint controllers

The information about the joint controllership is available under the link: FQ P CY Privacy Policy Supplement

For what purposes is or can your personal data be processed?

Personal data is or may be processed for the following purposes:

No.

Purpose of personal data processing

Scope of personal data

Lawfulness of processing

Offers

(Personal data processed in connection with the Controller's receipt of an offer regarding possible cooperation)

in the case of natural persons: name,

surname, position, e- mail address, telephone number,

in the case of legal persons: name,

surname, position, e-

mail, telephone number,

in the case of natural persons: art. 6 (1) f) GDPR,
in the case of legal persons: art. 6 (1) f) GDPR,

NDA

(Personal data processed in connection with the preparation, conclusion and implementation of the provisions of the confidentiality agreement (NDA))

in the case of natural persons: name,

surname, ID number, position, e-mail address, telephone number,

in the case of legal persons: name and surname, position, e- mail address, telephone

number,

in the case of natural persons: art. 6 (1) b), f)

GDPR,

in the case of legal persons: art. 6 (1) f) GDPR,

Arrangement

(Personal data processed in connection with the preparation, conclusion and implementation of the provisions of the contract)

Arrangement (Personal data

processed in connection with the preparation, conclusion and implementation of the provisions of the

contract)

in the case of natural persons: art. 6 (1) b), c), f)

GDPR,

in the case of legal persons: art. 6 (1) c), f) GDPR,

To send periodic emails, such as updates on new games release dates via e-mail (including Newsletter)

e-mail

art. 6 (1) a) GDPR - consent of the data subject,
art. 6 (1) f) GDPR -

processing is necessary for

the purposes of the legitimate

interests pursued by the

controller,

Personal data processed in connection with the exercise of rights in the field of personal data protection

The scope of data necessary to exercise the rights of the person

art. 6 (1) c) GDPR - legal provisions,
art. 6 (1) f) GDPR -

processing is necessary for the purposes of the legitimate interests pursued by the

controller,

Personal data processed in connection with the verification of sanction lists - the sanctions lists published inter alia by the United Nations Security Council (UN), the European Union, the United States of America (such as the Office of Foreign Assets Control), and the

People’s Republic of China (such as the People's Bank of China, the Ministry of Public Security, the Ministry of Commerce, the Ministry of Foreign Affairs) and country related lists provided by competent

authorities based on applicable law,

The scope of personal data available in the sanctions lists

in the case of natural persons: art. 6 (1) c) GDPR,
in the case of legal persons (natural persons acting on behalf of legal person)- art. 6

(1) c) GDPR,

For other purposes - while the content of art. 13 GDPR will then be presented individually for the

respective processing purpose

We hereby inform that depending on the purpose of processing, the scope of the indicated personal data may change.

How long will personal data be processed in accordance with the storage limitation principle (personal data retention)?

Please be advised that personal data are or may be processed for the period of:

No.

Purpose of processing

Lawfulness of processing

Processing period

Offers

(Personal data processed in connection with the Controller's receipt of an offer regarding possible cooperation)

in the case of natural persons: art. 6 (1) f) GDPR,
in the case of legal persons: art. 6 (1) f) GDPR,

until objective to processing,
for internal administrative purposes related to the management of the process of receiving offers - for a period of 10 years from the date of

receipt of the offer,

NDA

(Personal data processed in connection with the preparation, conclusion and implementation of the provisions of the confidentiality agreement (NDA))

in the case of natural persons: art. 6 (1) b), f)

GDPR,

in the case of legal persons: art. 6 (1) f) GDPR,

in order to prepare, conclude and implement the provisions of a confidentiality agreement (NDA) - for the duration of the preparation, conclusion and duration of the contract - for an indefinite period or until the contract is terminated or until an objection to the processing is raised,
for purposes related to the investigation of claims between the parties to the contract for the performance of the provisions of the contract (NDA) - if applicable - for the duration of the claims in accordance with applicable law and for the period of their

investigation - if applicable,

for internal management purposes - controlling and archiving documentation in connection with the conclusion of the contract

- for a period of 10 years from the date of the contract, which may be

changed,

Arrangement

(Personal data processed in connection with the preparation, conclusion and implementation of the provisions of the contract)

in the case of natural persons: art. 6 (1) b), c), f)

GDPR,

in the case of legal persons: art. 6 (1) c), f)

GDPR,

in order to prepare, conclude and implement the provisions of the contract - for the duration of the preparation, conclusion and duration of the contract - for an indefinite period or until the termination of the contract or until objections to processing are submitted,
in order to make financial settlements - for

a minimum period of 6

years from the end of the financial year,

for purposes related to the investigation of claims between the parties to the contract for the performance of the provisions of the contract - if applicable - for the duration of the claims in accordance with applicable law and for the period of their

investigation - if applicable,

for internal management purposes - controlling and archiving documentation in connection with the conclusion of the contract

- for a period of 10 years from the date of the contract, which may be

changed,

To send periodic emails, such as updates on new games release dates via e-mail (including Newsletter)

art. 6 (1) a) GDPR -

consent of the data subject,

art. 6 (1) f) GDPR -

processing is necessary for the purposes of the legitimate interests pursued

by the controller,

until the consent is withdrawn,
until an objection to the processing is submitted,
for an indefinite period,

Personal data processed in connection with the exercise of rights in the field of personal data protection

art. 6 (1) c) GDPR - legal provisions,
art. 6 (1) f) GDPR -

processing is necessary for the purposes of the legitimate interests pursued

by the controller,

for the period resulting from legal provisions (for an indefinite period),
until an objection to the processing is submitted,

People’s Republic of China (such as the People's Bank of China, the Ministry of Public Security, the

Ministry of Commerce, the Ministry

in the case of natural persons: art. 6 (1) c) GDPR,
in the case of legal persons (natural persons acting on behalf of legal person)- art. 6 (1) c) GDPR,

for the period according to applicable law,

of Foreign Affairs) and country related lists provided by competent

authorities based on applicable law,

Please be advised that the given periods of personal data processing for individual processing purposes may change, among others, as a result of amendments to the law or internal organizational changes.

Under what circumstances is the provision of personal data a statutory or contractual requirement or a requirement necessary to enter into a contract?

Please be advised that providing personal data is:

No.

Purpose of processing

Lawfulness of processing

Processing

Offers

(Personal data processed in connection with the Controller's receipt of an offer regarding possible cooperation)

in the case of natural persons: art. 6 (1) f) GDPR,
in the case of legal persons: art. 6 (1) f) GDPR,

a) providing personal data is voluntary, and failure to provide personal data will result in the inability to read and make a decision in connection with the received offer for

cooperation,

NDA

(Personal data processed in connection with the preparation, conclusion and implementation of the provisions of the confidentiality agreement (NDA))

in the case of natural persons: art. 6 (1) b), f)

GDPR,

in the case of legal persons: art. 6 (1) f) GDPR,

processing of personal data in order to prepare, conclude and implement the provisions of a confidentiality agreement (NDA) - providing personal data is contractual, and failure to provide personal data will result in the inability to prepare, conclude and implement the provisions of the contract,
processing of personal data for purposes related to the investigation of claims between the parties to the contract for the performance of the provisions of the contract (NDA) - it is voluntary, and failure to provide personal data will result in the inability to pursue

claims,

Arrangement

(Personal data processed in connection with the preparation, conclusion and implementation of the provisions of the contract)

in the case of natural persons: art. 6 (1) b), c), f)

GDPR,

in the case of legal persons: art. 6 (1) c), f)

GDPR,

processing of personal data in order to prepare, conclude and implement the provisions of the contract - providing personal data is contractual, and failure to provide personal data will result in the inability to prepare, conclude and implement the provisions of the contract,
in the case of financial settlements, it is of a statutory nature and failure to provide personal data will result in the inability to meet the obligations arising from the applicable law on the Controller,
processing of personal data for purposes related to the investigation of claims between the parties to the contract for the performance of the provisions of the contract - it is voluntary, and failure to provide personal data will result in the inability

to pursue claims,

To send periodic emails, such as updates on new games release dates via e-mail (including Newsletter)

art. 6 (1) a) GDPR -

consent of the data subject,

art. 6 (1) f) GDPR -

processing is necessary for the purposes of the legitimate interests pursued by the controller,

is voluntary, and failure to provide personal data will result in the inability to prepare periodic emails, such as updates on new games release dates via e- mail, including

Newsletter

Personal data processed in connection with the exercise of rights in the field of personal data protection

art. 6 (1) c) GDPR - legal provisions,
art. 6 (1) f) GDPR -

processing is necessary for the purposes of the legitimate interests pursued by the controller,

is voluntary, and failure to provide personal data will result in the inability to exercise the rights of the person in the field of personal data protection,
is of a statutory nature, and failure to provide personal data will result in the inability to comply

with the provisions of the

law in the area of personal data protection imposed

on the Controller,

Processing of personal data based on the consent of the data subject

Please be advised that in the case of processing personal data based on the consent of the data subject (Article 6 (1) (a) of the GDPR):

No.

Purpose of processing

Lawfulness of

processing

Art. 6 (1) a) GDPR

To send periodic emails, such as updates on new games release dates via e-mail (including Newsletter)

1) art. 6 (1) a) GDPR -

consent of the data subject,

The data subject has the right to withdraw their consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Withdrawal of the consent granted should be reported to the e-mail address:

DPO.CY@fulqrumpublishing.com

The processing of personal data based on the legitimate interest pursued by the Controller (processing is necessary for the purposes of the legitimate interests pursued by the controller)

Please be advised that in the case of processing personal data based on the legitimate interest pursued by the Controller (Article 6 (1) f) of the GDPR processing is necessary for the purposes of the legitimate interests pursued by the controller):

No.

Purpose of the processing

Lawfulness of the

processing

Art. 6 (1) f) GDPR

Offers

(Personal data processed in connection with the Controller's receipt of an offer regarding possible cooperation)

in the case of natural persons: art. 6 (1) f)

GDPR,

in the case of legal persons: art. 6 (1) f)

GDPR,

Please be advised that for the legitimate interest pursued by the Controller:

with regard to the processing of personal data in order to become acquainted with the cooperation offer, a binding business relationship shall be considered,
the processing of personal data for internal administrative and managerial purposes

related to the management

of the process of receiving

offers is considered,

NDA

(Personal data processed in connection with the preparation, conclusion and implementation of the provisions of the confidentiality agreement (NDA))

in the case of natural persons: art. 6 (1) f)

GDPR,

in the case of legal persons: art. 6 (1) f)

GDPR,

Please be advised that in the case of processing personal data of natural persons and natural persons representing or acting on behalf of a legal person, the legitimate interest pursued by the Controller is considered to be:

processing in order to prepare, conclude and implement the provisions of a confidentiality agreement (NDA),
processing for purposes related to the investigation of claims between the parties to the contract for the performance of the provisions of the contract (NDA) - if applicable - the legitimate interest pursued by the Controller is the processing of personal data for the purpose of seeking claims for the implementation of the provisions of the contract (NDA),
processing for internal management purposes - the legitimate interest pursued by the Controller is the control and archiving of documentation in connection with the

conclusion of the contract,

Arrangement

(Personal data processed in connection with the preparation, conclusion and implementation of the provisions of the contract)

in the case of natural persons: art. 6 (1) f)

GDPR,

in the case of legal persons: art. 6 (1) f)

GDPR,

Please be advised that in the case of processing personal data of natural persons, natural persons representing or acting on behalf of a legal person, the legitimate interest pursued by the Controller is considered to be:

a) processing in order to

prepare, conclude and

implement the provisions of the contract,

processing for the purpose of financial settlements - activities related to the monitoring and payment of payments,
processing for purposes related to the investigation between the parties to the contract of claims arising from the performance of the provisions of the contract - if applicable - the legitimate interest pursued by the Controller is the processing of personal data for the purpose of seeking claims for the implementation of the provisions of the contract,
processing for internal management purposes - the legitimate interest pursued by the Controller is the exercise of control and archiving of documentation in connection with the

conclusion of the contract,

To send periodic emails, such as updates on new games release dates via e-mail (including Newsletter)

1) art. 6 (1) f) GDPR -

processing is necessary for the purposes of the legitimate interests pursued by the controller,

A legally legitimate interest is considered to be a binding relationship, including a business relationship, an ongoing contract with the data subject and data processing for internal administrative purposes, also in relation to the exercise of the rights of data subjects in connection with the possibility of exercising the rights of persons to whom data concern and provided for by law (e.g. documenting withdrawal of

granted consent),

Personal data processed in connection with the exercise of rights in the field of personal data protection

1) art. 6 (1) f) GDPR -

processing is necessary for the purposes of the legitimate interests

pursued by the controller,

A legally legitimate interest is to the exercise of the rights of data subjects in connection with the

possibility of exercising the

rights of persons to whom data concern and provided for by law and demonstrate the compliance with the

GDPR regulations,

Disclosure of personal data by the Controller

We hereby inform that personal data is or may be disclosed by the Controller:

disclosed to data recipients providing services to the Controller pursuant to art. 28 GDPR – Data Processing Agreement. Depending on the purpose of personal data processing, the categories of data recipients may be: IT infrastructure providers (software and hardware), website hosting, tools for conducting meetings, conferences, online webinar, external recruiting companies. The list of the processors to whom the Controller entrusts the processing of personal data is available at the request of the data subject,
disclosure of data to recipients cooperating with the Controller. Depending on the purpose of personal data processing, the categories of recipients to whom personal data may be disclosed are entities operating in the field of audits, postal services, courier services, law offices. We would like to inform you that after disclosing personal data, the data recipient becomes the Controller. The list of recipients to whom the Controller discloses personal data is available at the request of the data subject,
disclosure of data to recipients who are public / state authorities. Depending on the purpose of personal data processing, the categories of data recipients may be such bodies as the Tax Office, Police, courts, the Supervisory Authority or other entities to which the Controller discloses personal data under applicable law. Please be advised that after disclosing personal data, their recipient becomes the Controller of the data. The list of recipients to whom the Controller discloses personal data is available at the request of the data subject,
disclosure of personal data to third parties. The list of third parties to whom the Controller discloses personal data is available at the request of the data subject.

Transferring personal data to a third country (i.e. outside the EEA)

Please be advised that personal data may be transferred to a third country, i.e. outside the EEA. In the event of transferring personal data outside the European Economic Area, such transfer may only take place on the terms set out in Chapter V of the GDPR:
1. pursuant to art. 45 GDPR - transfer based on an adequacy decision,
2. pursuant to art. 46 GDPR - transfer subject to appropriate safeguards, including the use of standard data protection clauses adopted by the European Commission,
We hereby inform that the transfer of personal data outside the EEA may involve the risk of not ensuring sufficient security of personal data. In the event of a risk related to the

transfer of personal data outside the EEA, the Controller provides such information in this Privacy Policy,

Please be advised that the list of entities outside the EEA to which the Controller discloses personal data is available at the request of the data subject,
List of entities that may transfer personal data outside the EEA, which may not provide sufficient protection of personal data provided for in the GDPR is available under the link: FQ P CY Privacy Policy Supplement

What are the rights of the data subject?

We would like to inform you about the right to request the Controller to exercise the following rights:

the right to access personal data relating to the data subject,
the right to rectify personal data,
the right to delete personal data (erasure of personal data),
the right to limit the processing of personal data (restriction of processing),
the right to object to the processing,
the right to transfer data (the right to data portability),
the right to receive a copy of your personal data,
the right to lodge a complaint with the supervisory body.

Please be advised that due to the individual purposes of processing listed in this Privacy Policy, the exercise of the rights of data subjects may be fully or partially limited, e.g. due to applicable law, which obliges the Controller to process them. Please send inquiries regarding the protection of personal data to the Controller by traditional mail to the above-mentioned address or by e-mail to the address: DPO.CY@fulqrumpublishing.com.

Who is the supervisory authority?

We would like to inform you about the right to lodge a complaint to the supervisory body, Office of the Commissioner for Personal Data Protection, contact to the supervisory body is available at:

http://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/contact_en/contact_en? opendocument,

Information on automated decision making, including profiling

Please be advised that personal data is not subject to profiling or automated decision-making.

What is the source of the data?

Personal data may:

come directly from the data subject,
come indirectly from the data subject. The source of personal data may be publicly available registers, i.e. sanctions lists. Personal data may come from a legal entity that provides personal data of persons designated on behalf of the legal entity to represent it or to contact it, or to implement the provisions concluded between the parties.

What scope of personal data is processed?

The Controller processes personal data to the extent necessary to achieve the purposes of processing indicated in the Privacy Policy. In accordance with the principle of minimization, we process only the scope of personal data necessary to achieve the purpose of processing.

How do we secure personal data?

Please be advised that in order to protect privacy and personal data, the Controller has implemented appropriate physical, technical, organizational and legal measures to ensure the security of personal data processing and to ensure the implementation of the rights and freedoms of natural persons.

Processing of personal data using social media or platforms

Please be advised that the Controller runs or can run a fanpage(s) on social media or platforms. The information about the social media and the platforms is available under the link: FQ P CY Privacy Policy Supplement

References to other sites

Please be advised that the website of the Controller may contain references to other websites (e.g. business partners cooperating with the Controller).
Please be advised that the Controller is not responsible for the processing of personal data of other websites. Information on the processing of personal data is made available by the Controllers to which the abovementioned websites belong.

Processing of personal data via sales platforms

Please be advised that the Controller, as part of cooperation with sales platforms, may process personal data in connection with the offer of products and services.

Information on the processing of personal data to the extent to which the Controller determines the purposes and means of the processing of personal data, is available in the dedicated Privacy Policy provided by the Controller on the sales platform - if applicable.

Personal data breach notifications

We hereby inform that pursuant to Art. 34 GDPR, in the event of a breach of personal data protection that may result in a high risk of violation of the rights or freedoms of natural persons, the Controller shall notify the data subject of such a personal data breach without undue delay. Please be advised that pursuant to Art. 34 GDPR, personal data may be processed in connection with the personal data breach referred to above. Please be noted that the legal basis for the processing of personal data is art. 6 sec. 1 lit. c) GDPR. Please be advised that in the event of a personal data breach, the Controller will take all possible and available technical and organizational measures to meet the requirements set out in art. 33 and art. 34 GDPR.