ENESTECH – ENESTECH SOFTWARE (CYPRUS) LTD, a legal entity under the laws of Cyprus, registered office: Emmanouil Roidi, 10-12 2nd floor Agіa Zoni, 3031, Limassol, Cyprus.
SENET software – a platform for managing personal computers and related devices, developed and owned by ENESTECH and intended for use by the Client in the field of computer games and the entertainment industry. SENET software also includes all software, any data, tools and services provided through the Site, and related applications available to the Client on the Site. In the Turkish market SENET software is presented under the brand Enes-T.
Client – any legal or natural person visiting the Site or registered on the Site in order to use SENET software for their commercial purposes.
Customer’s personal account – an account in the SENET software created by the Customer after its registration on the Site, which provides the Customer with the opportunity to use the SENET software.
End User – a person or persons renting personal computers or other related devices of the Client used within the SENET software.
Personal data – any information relating directly or indirectly to a specific or determinable natural or legal person (personal data subject).
Processing personal data – any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
License – a transaction concluded between the Client and ENESTECH, in accordance with the terms of which ENESTECH grants the Client the right to use SENET software under a simple (non-exclusive) license.
Tariff plan – the amount and procedure for making payments for the use of SENET software.
Website – a website administered by ENESTECH and located at the URL: https://senet.cloud/.
1. PROTECTION OF CLIENT’S PRIVACY
1.1. This policy defines the procedure for the collection, storage, use and disclosure of ENESTECH personal data of Clients, as well as the rights of Clients in connection with their personal data stored by ENESTECH.
2. PERSONAL DATA
2.1. Personal data refers to information or judgment (including forming part of the database) about an individual sufficient to identify him, regardless of whether they are reliable and whether they are recorded on a tangible medium.
3. REASON FOR COLLECTING PERSONAL DATA
3.1. ENESTECH collects and stores some personal data necessary for conducting business, providing services and providing access to SENET software. ENESTECH may collect Customer personal data for the following purposes:
3.1.1. The provision of products and services, in particular SENET software;
3.1.2. Identification and evaluation of the application for a license to use the SENET software;
3.1.3. Providing the ability to install SENET software;
3.1.4. Provision of services for maintenance and support of SENET software;
3.1.5. Request processing and improvement of SENET software;
3.1.6. Promotion and advertising of products and services using SENET software;
4. ENESTECH COLLECTES THE FOLLOWING PERSONAL DATA
4.1. ENESTECH may collect the following types of customer data:
- name, position and contact information, for example, email address, fax number, telephone numbers, name of the organization to which the Client belongs, its location;
- billing information, such as credit card or bank details;
- information provided in correspondence with ENESTECH;
4.2. ENESTECH may collect the following types of End User Data:
4.2.1. Name, contact information, for example, email address, fax number, phone numbers, address, age and gender, IP address, information about geographical location, game situation, number of ad views, unique identifier of a mobile device or identifiers and settings of other devices, information about the use of SENET software, as well as other Internet sites (including third-party sites and Internet sites for mobile devices) viewed by End Users (as well as the date and time of viewing), the response to advertising (if any), as well as information on whether direct marketing messages or electronic newsletters sent by ENESTECH correspond to the interests of the End User.
4.2.2. Analysis tools and advertising display technologies can use server log files, web beacons, cookies, tracked pixels and other technologies to collect the mentioned information, as well as information received from third-party websites, mobile products and services, with demographic, advertising, market and other analytical studies. By itself, this information is not personal data, however, if ENESTECH combines any piece of information with personal data, then ENESTECH will treat this information as personal data.
4.2.3. ENESTECH does not sell personal data to advertisers and does not transmit to advertisers information that directly identifies the End User (for example, name, email address or other contact information) unless the End User grants permission for this. However, advertisers can tell ENESTECH about the target audience for their advertisements and ENESTECH will show these ads to people for whom they will be relevant. ENESTECH provides advertisers with ad performance reports that help them understand how people interact with their content.
4.2.4. If the Client fails to pay for the use of SENET software within 7 (seven) calendar days after the expiration of the term, according to the selected Tariff plan, ENESTECH has the right to suspend the Client’s Personal Account. In the absence of payments by the Client, ENESTECH has the right to delete the Client’s Personal Account and the personal data of End Users contained in it 15 (fifteen) calendar days after the suspension of the Client’s Personal Account. During these 15 (fifteen) calendar days, the Client has the right to request ENESTECH to upload and transfer to the Client the personal data of the End Users, after which ENESTECH shall not be liable for the processing and disposal of such personal data of the End Users.
5. PROCEDURE FOR RECEIVING PERSONAL DATA
5.1. In most cases ENESTECH will receive personal data directly from Customers. ENESTECH collects personal data when the Client interacts with ENESTECH personally – by phone, e-mail or using other electronic communication channels.
6. COOKIE FILES AND ANALYTICS
6.2. If the Client has any difficulties with disabling cookies, ENESTECH recommends that the Client contact the technical support of his browser for help or advice.
6.3. The client should know that if he does not accept cookies, he will not be able to use all the functionality of the Site.
7. RULES FOR STORING PERSONAL DATA
7.1. ENESTECH takes reasonable measures to protect personal data and prevent unauthorized access to or change thereof, as well as to destroy or de-identify them if they are no longer required. ENESTECH stores personal data in electronic form. Personal data is password protected, and the system itself is equipped with firewalls.
7.2. Third-party data storage service providers are required to protect personal data from unauthorized access or misuse by implementing appropriate technological measures and organizational procedures. ENESTECH may forward information to foreign third-party data storage service providers, but ensures that proper data processing procedures and security measures are in place.
8. ACCESS TO PERSONAL DATA
8.1. Unless ENESTECH is obligated to provide personal data to third parties in accordance with applicable law, based on a court decision or for the purpose of investigating alleged fraud or other illegal activities, only Customers working on ENESTECH or any of the Affiliates will see and use the Clients information service providers, marketing campaigns, and products.
8.2. Persons with access to personal data may include ENESTECH full-time employees or those contracted (for example, customer service employees, sales agents, marketing specialists, consultants, etc.), employees of subsidiaries, advertising agencies and Affiliates (which offer services, marketing campaigns and products).
8.3. ENESTECH is committed to protecting information systems and files from unauthorized access, and ENESTECH personnel and contracted agents and service providers are notified of the importance of protecting privacy.
8.4. Affiliates are ENESTECH officials, employees and other personnel, agents, contractors, partners, executives, licensors, service providers and representatives.
8.5. ENESTECH requires all third parties to ensure the security of personal data and process it in accordance with the law. ENESTECH does not allow third-party service providers to use personal data for their own purposes. ENESTECH authorizes them to process personal data only for specified purposes in accordance with ENESTECH instructions.
9. CUSTOMER RIGHTS
9.1. The client has the right:
9.1.1. Request access to personal data (that is, send a «request from the personal data subject to provide access to such data»). The client is entitled to receive a copy of the personal data stored by ENESTECH and verify the legality of their processing.
9.1.2. Request correction of personal data. The client has the right to request that data stored by ENESTECH be supplemented or corrected if it is incomplete or inaccurate. However, in this case, ENESTECH may need to verify the accuracy of the new data that the Customer will provide to ENESTECH.
9.1.3. Request the deletion of personal data. If there is no reason to continue processing ENESTECH personal data of the Client, the Client may demand that ENESTECH delete it.
9.1.4. Demand to stop processing personal data in cases where ENESTECH acts on the basis of legitimate interests (or the interests of a third party) and the Client objects to the processing due to personal circumstances, considering that this affects his fundamental rights and freedoms.
9.1.5. Demand restricts the processing of personal data. The Client has the right to demand that ENESTECH suspend the processing of personal data in the following cases: (i) if the Client wants ENESTECH to establish the accuracy of the data; (ii) if the use of ENESTECH data is illegal, but the Client does not want ENESTECH to delete it; (iii) if the Client wants ENESTECH to save the data even though ENESTECH does not need it anymore, since the Client needs it to go to court, conduct legal proceedings or protect against claims; or (iv) the Client has requested the termination of the use of his data, but ENESTECH must verify that there are legal grounds that take precedence over the rights of the Client.
9.1.6. Require the transfer of personal data to the Client or to a third party. ENESTECH undertakes to transfer the Client’s personal data to the Client or a third party specified by the Client in a structured, generally accepted and machine-readable format. Please note that this right only applies to automatically received information for the use of which the Client initially gave his consent or which ENESTECH uses to conclude an agreement with the Client.
9.1.7. Withdraw consent at any time (in cases where ENESTECH processes the data on the basis of consent). Withdrawal of consent does not affect the legality of the processing performed prior to the withdrawal. Revocation of consent may affect the ability to provide certain products or services.
If the Client wants to exercise any of the above rights, please contact ENESTECH at the email address firstname.lastname@example.org.
10. RESPONSIBILITY OF THE CUSTOMER
10.1. In the event that the Client, as part of the work with SENET software, collects personal data of his End Users, the Client’s responsibility will be to comply with all relevant requirements of the legislation on working with personal data, including, but not limited to, obtaining the consent of the End User to process his personal data.
10.2. The Client must comply with the data protection laws applicable to him in connection with this License and must not take actions that will violate ENESTECH any of its obligations under the applicable data protection laws. Using SENET software, the Client agrees that ENESTECH may transfer, collect, store, process and use information about user activities when working with SENET software, including, but not limited to, information about the frequency of use of certain functions, types, time and the subject of use for statistical and analytical purposes for the possibility of further improvement of the SENET software, as well as for the purpose of advertising. Personal data is stored in accordance with the requirements of the GDPR if the Client is a resident of the European Economic Area (EEA) and / or in accordance with the requirements of the jurisdiction where the Client is located.
10.3. The Client knows that when using SENET software, he will collect and process the personal data of End Users, such as: aliases, passwords, IP addresses, phone numbers and other personal data, if required by the laws of the jurisdiction of the Client.
10.5. If the Client processes personal data (in this case, the Client is considered a «Processor»), he undertakes:
10.5.1. Process personal data in accordance with the requirements of the legislation of the jurisdiction of the Client;
10.5.2. Do not publish, disclose or disclose personal data to third parties, except as otherwise provided by applicable law;
10.5.3. Provide access to personal data only to those persons who need access to it for the purposes of the License;
10.5.4. To ensure that all persons to whom the Client provides access to personal data are reliable, trustworthy and trained in data protection laws, and as a result are aware of the obligations of the Client as a Processor, as well as their personal obligations with respect to the License and protection laws data;
10.5.5. At a minimum, take all measures and give a written description and justification for each of the technical and organizational measures that have been or will be implemented in order to:
- protect personal data from unauthorized or illegal processing and accidental loss, destruction, damage, alteration or disclosure; as well as
- timely detect and report on violations of personal data;
10.5.6. If another personal data processor («Sub-processor») is used to process personal data on its behalf, ensure compliance with laws on the protection of personal data;
10.5.7. Notify ENESTECH within five business days if the Client has received any message from a third party directly or indirectly related to the processing of personal data, including, but not limited to, requests for the exercise of rights in accordance with data protection laws, complaints or general correspondence and provide ENESTECH with a copy of any such message. The client should not take any measures in connection with such a message, unless otherwise provided by law, without the prior approval of ENESTECH;
10.5.8. Taking into account the nature of the processing of personal data and, as far as possible, provides assistance to ENESTECH in fulfilling obligations in accordance with data protection laws;
10.5.9. Taking into account the nature of the processing of personal data and the information available to the Client, provide assistance to ENESTECH in ensuring compliance with data protection laws, including compliance with GDPR. Such assistance should include, but is not limited to:
- immediately notify ENESTECH of the detection of privacy violations of personal data, providing all information available to the Client or having reasonable grounds regarding the violation of personal data so that ENESTECH can fulfill its obligations under Articles 33 and 34 of the GDPR and is able to properly investigate cases of violation of personal privacy personal data;
- assist in risk assessment regarding the processing of personal data that the Client performs in accordance with the License;
10.5.10. At the choice of ENESTECH, delete or return ENESTECH personal data and make sure that any party to whom the Client has disclosed personal data will do the same:
- in cases where ENESTECH instructs the Client to delete or return personal data, in which case the Client is exempted from his obligations to protect personal data under the License to the extent that this action does not allow him to fulfill these obligations; or
- after the termination of the License, the Client is obliged to delete or return all personal data if the applicable law does not require the Client to retain personal data. In cases where ENESTECH requests the return of personal data, the Client must use all reasonable efforts to ensure that they are in the format and on the media specified by ENESTECH;
10.5.11. Comply with all ENESTECH instructions to change personal data or restrict their processing and ensure that any party to whom the Client disclosed personal data does the same;
10.5.12. Store personal data in a structured, commonly used and machine-readable format;
10.5.13. Do not transfer personal data outside of its jurisdiction without prior notice to ENESTECH.
10.5.14. Provide ENESTECH with all the information necessary to demonstrate compliance with this License, as it relates to data protection; and also allow ENESTECH or its external consultants to inspect the Client’s data processing activities, which will enable ENESTECH to ensure that the Client fully complies with its obligations under this License.
11. ADDITIONAL INFORMATION
11.1. If you have comments and questions related to the processing of personal data, as well as to gain access to, update, modify or delete personal data, please contact ENESTECH at the email address email@example.com.
11.2. It is very important that the personal data stored in ENESTECH is accurate and current. Please inform ENESTECH about changes in personal data.