Data Controller and Owner

SUREP LTD

34, ARCHIEPISKOPOU MAKARIOU III,

ZAPPEION BUILDING, OFFICE 13

2107, NICOSIA, AGLANTZIA

CYPRUS

Owner contact email: egor@borscht.mobi

Types of Data collected

Among the types of Personal Data that Chaos Lords (hereinafter the «Application»)

collects, by itself or through third parties, there are: Cookies and Usage Data.

Other Personal Data collected may be described in other sections of this privacy policy

or by dedicated explanation text contextually with the Data collection.

The Personal Data may be freely provided by the User, or collected automatically when

using this Application.

Any use of Cookies - or of other tracking tools - by this Application or by the owners of

third party services used by this Application, unless stated otherwise, serves to identify

Users and remember their preferences, for the sole purpose of providing the service

required by the User.

Failure to provide certain Personal Data may make it impossible for this Application to

provide its services.

Users are responsible for any Personal Data of third parties obtained, published or shared

through this Application and confirm that they have the third party's consent to provide

the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Data Controller processes the Data of Users in a proper manner and shall take

appropriate security measures to prevent unauthorized access, disclosure, modification,

or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following

organizational procedures and modes strictly related to the purposes indicated. In

addition to the Data Controller, in some cases, the Data may be accessible to certain

types of persons in charge, involved with the operation of the site (administration, sales,

marketing, legal, system administration) or external parties (such as third party technical

service providers, mail carriers, hosting providers, IT companies, communications

agencies) appointed, if necessary, as Data Processors by the Owner.

Place

The Data is processed at the Data Controller's operating offices and in any other places

where the parties involved with the processing are located. For further information, please

contact the Data Controller.

Retention time

The Data is kept for the time necessary to provide the service requested by the User, or

stated by the purposes outlined in this document, and the User can always request that

the Data Controller suspend or remove the data.

The use of the collected Data

The Data concerning the User is collected to allow the Owner to provide its services, as

well as for the following purposes: Analytics.

The Personal Data used for each purpose is outlined in the specific sections of this

document.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Analytics

The services contained in this section enable the Owner to monitor and analyze web

traffic and can be used to keep track of User behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google

utilizes the Data collected to track and examine the use of this Application, to prepare

reports on its activities and share them with other Google services.

Google may use the Data collected to contextualize and personalize the ads of its own

advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: US

MixPanel (MixPanel)

MixPanel is an analytics service provided by Mixpanel Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US

TestFlight (Apple Inc.)

TestFlight is an analytics service provided by Apple Inc.

Personal Data collected: Cookies, email address and Usage Data.

Place of processing: US

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Data Controller, in Court

or in the stages leading to possible legal action arising from improper use of this

Application or the related services.

The User declares to be aware that the Data Controller may be required to reveal

personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide

the User with additional and contextual information concerning particular services or the

collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third party services

may collect files that record interaction with this Application (System logs) or use for this

purpose other Personal Data (such as IP Address).

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested

from the Data Controller at any time. Please see the contact information at the beginning

of this document.

The rights of Users

Users have the right, at any time, to know whether their Personal Data has been stored

and can consult the Data Controller to learn about their contents and origin, to verify their

accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for

their transformation into anonymous format or to block any data held in violation of the

law, as well as to oppose their treatment for any and all legitimate reasons. Requests

should be sent to the Data Controller at the contact information set out above.This

Application does not support “Do Not Track” requests.

To determine whether any of the third party services it uses honor the “Do Not Track”

requests, please read their privacy policies.

Users also have the right to lodge a complaint with their local data protection authority

about any of activities that are deemed not to be in compliance with GDPR.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time

by giving notice to its Users on this page. It is strongly recommended to check this page

often, referring to the date of the last modification listed at the bottom. If a User objects

to any of the changes to the Policy, the User must cease using this Application and can

request that the Data Controller remove the Personal Data. Unless stated otherwise, the

then-current privacy policy applies to all Personal Data the Data Controller has about

Users.

Definitions and legal references

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an

association, which is, or can be, identified, even indirectly, by reference to any other

information, including a personal identification number.

Usage Data

Information collected automatically from this Application (or third party services employed

in this Application), which can include: the IP addresses or domain names of the

computers utilized by the Users who use this Application, the URI addresses (Uniform

Resource Identifier), the time of the request, the method utilized to submit the request to

the server, the size of the file received in response, the numerical code indicating the

status of the server's answer (successful outcome, error, etc.), the country of origin, the

features of the browser and the operating system utilized by the User, the various time

details per visit (e.g., the time spent on each page within the Application) and the details

about the path followed within the Application with special reference to the sequence of

pages visited, and other parameters about the device operating system and/or the User's

IT environment.

User

The individual using this Application, which must coincide with or be authorized by the

Data Subject, to whom the Personal Data refers.

Data Subject

The legal or natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural person, legal person, public administration or any other body, association or

organization authorized by the Data Controller to process the Personal Data in

compliance with this privacy policy.

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or

organization with the right, also jointly with another Data Controller, to make decisions

regarding the purposes, and the methods of processing of Personal Data and the means

used, including the security measures concerning the operation and use of this

Application. The Data Controller, unless otherwise specified, is the Owner of this

Application.

This Application

The hardware or software tool by which the Personal Data of the User is collected (Chaos

Lords).

Small piece of data stored in the User's device.

How long we store data

Your data will be stored on our system as long as you are registered. Beyond that, we

are only storing data if it is legally necessary or otherwise required by law.

Latest update: February 27, 2019