Privacy Policy
The date of the last update of this Privacy Policy is 16/05/2022.The NAJOX Company (hereinafter – the “Company” or its definition without the quote marks, which definition may include such parts of it, legal and natural, as shareholders, partners, affiliates, directors, officers, subsidiaries, employees, agents, suppliers, third party information providers, licensors, licensees, distributors, and/or contractors), which operates the website www.najox.com (hereinafter – the “Site” or “Website” or their definitions without the quote marks), is committed to protecting the personal and financial information of its users. Users are the natural persons, which use the website for the purpose of having entertainment and personal amusement, without any other intention of usage. All users of the website shall be 18 years old or older to have the official and legal right to use the website. If a user is younger than 18 years old, he or she must register on the website only with the written consent of their official parent or official custodian/trustee, and such consent shall be made in an official form in full accordance with the applicable law of the country of citizenship of the user. Any possible registration without such a written consent can and will be considered illegal. The Company may at any time request the copy of such consent from users under 18 years old and, upon non-provision of such, can delete/halt/stop/freeze/deactivate access right of such a user to the website until the copy of the mentioned consent is received.
This Privacy Policy (hereinafter referred to as “PP”, “Privacy Policy”, or “Policy”) describes the policy of the Company about the collected information on the website, including its practices, principles, and transparency. The PP is elaborated using the applicable law of Ukraine.
Every user of the website shall comply with the requirements and provisions of PP. After agreeing to PP, a user gives their full and irrevocable consent to collect, process, use, distribute, transfer, disclose, and possess the personal and financial information to the Company. If a user disagrees with PP, he or she cannot use the website and shall immediately leave it. The parent or the official custodian/trustee of a user under 18 years old shall register the user themselves, providing the consent to the PP on behalf of the user and provide written consent to the user to use the website in accordance with the law of the country of citizenship of the user and keep such a written consent until the Company asks for a copy of it and 20 (twenty) years after such asking. If you have any questions regarding the PP, you may contact the company to ask those questions. If a user gives consent to PP, it means they fully read and understand all provisions of PP in whole and in its every part.
This PP is elaborated taking into account the General Data Protection Regulation (GDPR), as well as the system for data protection that’s used on the website.
General provisions
Users of the website can use many functions of the website without registration and thus, without the provision of personal and/or financial data. During the registration, some personal and financial data may be requested and should be provided by users to successfully complete the registration procedure.
Collection of data and its purpose
All data that are provided by the users are safely stored on the website’s servers, implementing the reasonable means of data protection, considering the market best solutions and practices. All applied data protection means are adequate and prevent intentional or unintentional leakage of data, including the leakage that can become possible due to unauthorized access to the database.
Any personal and financial information can further be used to personalize the communication between a user and the Company and the formation of payment documents to be paid by users, such as invoices, for any on-site purchases.
A user can cancel the account and ask to delete all connected information to it by sending a letter to the Company, which official representatives review the letter and obligate to delete the account of a user and all connected data within 12 months after the letter is received by the Company (if a letter does not contain the request of immediate deletion). Storage of data and account for 12 months in some cases may be required to resolve any possible financial and communication issues, which stayed unresolved upon the user letter’s receiving by the Company.
Other data that may be automatically or manually collected by the website include technical data such as IP of a visitor, screen resolutions of the user devices, their operating systems, information about the browser, Internet service provider, history of IP changes that are connected to a user, and other data. Such data by no means shall identify the user’s person or financial information and thus is called ‘anonymous’ data. The ‘anonymous’ data can be stored on the servers of the company for unlimited time and may be used for commercial, statistical, financial, business, technical, marketing, development, and other purposes and goals of the company (including the improvement of access to users and personifying various website’s offers, products, and services for users, solve technical issues, errors, and mistakes of website’s functioning, including ones on the devices of users), for which it can be collected, stored, changed, deleted, aggregated, segregated, modified, interpreted, archived, extracted from an archive, summed, deducted, inducted, uncollected, sent, viewed, distributed, resent, altered, or used in another manner at the Company’s discretion, including sharing with the Company’s partners and affiliates to form the personalized banners and other advertising & targeted commercial offers.
Usage of ‘anonymous’ data can also help users navigate the website and improve its usage, including forming personal offers for users, which might enhance the interaction with the website, as well as might help the Company improve the website’s functionality. An example of data collection and usage is making statistics about the website’s visiting or defining its global statistics of the geography of users.
The information may be collected using various technical and technological means, including cookies and automated screenings of the software and hardware of users. Further information about cookies usage can be found in the Cookie Policy.
Games of third parties
The website may use its own games, as well as the games of third parties. If any third party uses the personal or financial data of users, it does so in full accordance with this Policy and under a corresponding partnership agreement with the Company, in either case providing applicable data security and protection according to the Policy and the Law.
Cookies
The Company uses cookies when it operates the Website. Read more about cookies in the Cookie Policy.
Sharing data
In some cases, the Company is obliged to disclose the data about users:
• In the case of legal and lawful demand of a governmental body, facility, or authority under the applicable law, which is connected to financial, criminal, legal, or civil proceedings
• The same s above only connected to the laws about money laundering and financing of terrorism
• To third parties of the Company, which can receive such information according to agreements and contracts concluded with the Company and concerning the provision of advertising, commercial, and informational services to the Company and/or the website’s users.
The Company never sells user data to anyone.
Rights of users for the collected data
According to all existing applicable legislation, European and worldwide, users who provide their data to the website have the following rights:
1) The right of confirmation
Every person can ask a website’s runner (in this case, the Company) if there is any data collected and used by the website, including personal and financial, of that user. Any user of the website, following this right, can address the Company’s Data Protection Officer to use this right.
2) The right of access
Any user of the Website can require and receive information about what exactly data are gathered and used about this user by the website.
When asked, a user shall be presented with a copy of such data (by means of one of the indicated channels of communication with a user), where it should be said:
• the list of available data
• the purpose of their processing
• if the data may be disclosed or have been disclosed, then the list of names and other information about the recipients of such information, including third countries and international organizations
• the period of storage of personal and financial data or, if not indicated directly, the algorithm of the definition of the period of such storage
• indication on the right of a person to demand to stop data usage, have it cleaned, or to claim for the right to be forgotten
• indication on the right of a person to claim a complaint to an applicable supervising authority, with the indication of this authority’s contact data.
If any information will be or has been rendered to any parties under the disclosure procedures of the Company, the subject of the information shall be notified upon this event.
Any user of the website, following this right, can address the Company’s Data Protection Officer to use this right.
3) The right to supplement
A user of the website can demand supplement or complete the data if it is incomplete or incorrect.
Any user of the website, following this right, can address the Company’s Data Protection Officer to use this right.
4) The right to erasure (the right to be forgotten)
Any user of the website can demand to erase all the information about him or her from the database, including personal, financial, and anonymous, and it shall be made by the company within 12 months since such a demand receiving if the immediate erasure is not demanded by the user. After the erasure, the indicated information can no longer be operated or processed by the Company, as well as such a user can no longer be considered a user. Thus, after the implementation of the right to be forgotten, the user account and all connected data are erased from the system, which makes it impossible for the user to use the website as a registered user and communicate to the Company’s official representatives after such erasure.
The user can, however, register anew after the implementation of the right to be forgotten, and a new data collection procedure according to this PP will be taking place.
If any pieces of personal data have been made public by any one of the Company, upon receiving the request within the right to be forgotten, the Company’s Data Protection Officer shall make all depending and reasonable steps to ensure that the public data will be erased as well, including withdrawal of it from public access in the case if it cannot be erased. Upon doing such steps by the Company’s Data Protection Officer, it is considered that the Company has successfully performed its obligation under the requirements of the right to be forgotten and a user cannot demand from the company to make more or other steps than those that were already made under this procedure. If a user wishes to receive the confirmation of the steps done, the Company’s Data Protection Officer sends an official letter to a user, where he or she lists such steps, which serves as a sufficient verification of the fact that the steps were actually made. The Company’s Data Protection Officer has no right to list the steps that were not actually made as ones that were made.
5) The right to limit the data processing
A user of the website can require a limitation of data processing. The reasons for such can be:
• non-accuracy of the personal or financial data
• the data are processed unlawfully or not within this PP
• there is no objective need for the Company to use the user data anymore
• the company requested the personal or financial data for legal or financial usage but the user objects against such usage.
Any user of the website, following this right, can address the Company’s Data Protection Officer to use this right.
6) The right of the data portability and readability
Any user of the website has the right not only to find out, which data and how exactly used by the company but also to receive such data report in a structured and machine-readable format, in one of the formats that are widely accepted by the computer society today. For instance, a file can have one of the following formats: .html, .htm, .txt, .zip, .pdf, .doc, .docx, .xls, xlsx, .tiff, .tif, .png, .bmp, .jpeg, jpg, .xml, or .rtf (the list is not exclusive and may be supplemented by the company upon preliminarily agreeing with a user). The data portability (readability of its format) makes it convenient for the user to read the data using one of the popular programs that would open the data file. The readable file is prepared by automated means in a format that’s convenient for the company (which may coincide with the format requested by the user or not but shall be in one of the above-mentioned formats if otherwise is not agreed upon with a user).
If there are more data holders of the user data and it will be necessary to transmit data between holders to form a single output file, which would contain the most complete dataset of the user data, then it shall be done between the data holders without special or separate notice or demand by a user, and the data holders should agree between themselves the procedure of such data passage and terms of its completion.
Any user of the website, following this right, can address the Company’s Data Protection Officer to use this right.
7) The right to object
Any user of the website can object to the usage of his or her personal data partially or fully. If a user objects against the data usage, he or she must be aware that some functions of the website may not be workable for him or her, including (but not limited to): entrance to the personal account and/or staying within it, opening webpages of the website, seeing personalized advertising, performing payments for any products or services of the website and/or receiving paid purchases, communication to the support service for any possible issues, problems, or errors, accessing the search function, opening games and playing them, having the user activity on the website saved and recorded, as well as performing other actions and operations.
The impossibility to process personal data may result in the loss of the personification of advertising shown to a user, so the shown advertising will no longer reflect the interests of a user.
The impossibility to process personal and financial data may reflect in the impossibility to keep track of the user transactions and actions, and cleaning up the history of already made transactions and actions, if any, which will result in the impossibility to show to a user the historical data of the website’s usage through the site’s interface and through a separate request from a user to the Company for such historical records. Also, any kind of forbidding of data processing may result in the impossibility of receiving answers from the Company for any sort of user requests, letters, or demands.
Any user of the website, following this right, can address the Company’s Data Protection Officer to use this right.
8) Automated individual decision-making
Any website’s user can ask and be satisfied with the request of processing any of his or her data, including financial and personal, only by automated means, without a manned (human) participation if such processing does not explicitly require manual processing to be completed. In some cases, data processing may demand receiving exclusive consent of a user with a manual (human-involving) processing and a user may grant such consent through the website’s interface. However, if a user requests only automated processing, all previously granted consents of manual processing lose their power, and all such further consents will also lose their power (albeit can stay technologically feasible). In this case, however, a user might lose the possibility to interact with the website or the Company fully or partially, as some website’s and company’s functionality require human involvement in the data processing.
Any user of the website, following this right, can address the Company’s Data Protection Officer to use this right.
9) The right to withdraw any prior consent to data processing
A user of the website has the right to withdraw any prior consent to data processing. In this case, he or she may be limited in receiving the services of the website since some of its functional and technological processes require user data processing, including (but not limited to): entrance to the personal account and/or staying with it, opening webpages of the website, seeing personalized advertising, performing payments for any products or services of the website and/or receiving paid purchases, communication with the support service for any possible issues, problems, or errors, accessing to the search function, opening games and playing them, having the user activity on the website saved and recorded, adjusting to the user’s device screen resolution, as well as performing other actions and operations. Also, this will result in the impossibility to protect user data since protection is also a form of processing.
Any user of the website, following this right, can address the Company’s Data Protection Officer to use this right.
Revision of PP
This PP may be revised, changed, and updated at times, at any time, at the sole discretion of the Company, without any prior or further user notification. If a user wants to keep track of changes, he or she must periodically visit the PP webpage to find any possible updates to the PP.
Contact data
The company’s contact data are found here.
