Privacy policy

Whenever the following terms and definitions appear in this Privacy Policy, they shall be construed as follows:

ENESTECH is 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 2.0 software is a management platform for 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.

CLIENT OR YOU whether a legal or natural person, is the entity that owns a computer club, possessing the right to manage and supervise it, or is legally authorized as a representative of the computer club, granting them the authority to act on behalf of the club in accordance with the prevailing laws. Additionally, the Client has obtained the corresponding license from ENESTECH to utilize the SENET 2.0 software and SENET BOOT.

END USER is a person who rent personal computer or other related device of the Client, which are used as part of the SENET 2.0 software.

PERSONAL DATA is any information relating to you that, by itself or in combination with other information, enables the person collecting and processing such information to identify you as an individual.

PROCESSING OF PERSONAL DATA means any operation with your personal data, by automated or non-automated means.

DATA CONTROLLER is an entity (person, organization, etc.) that determines why and how Personal data is processed. If you provide us with your Personal Data, ENESTECH becomes the Data controller.

DATA SUBJECT is any identified or identifiable natural person whose personal data is processed by the Data Controller. Here, this term means you as a user of services owned by ENESTECH.

CONSENT is a freely given, specific, informed and unequivocal consent of you, as a Data Subject, to the processing of your Personal Data in accordance with the stated purpose of their processing, expressed in written or electronic form.

SITE is a website administered by ENESTECH and located at the URL address:


ENESTECH does everything to protect your Personal Data.

Before you give us your Consent to process your Personal Data or provide us with your Personal Data, we ask that you read this Privacy Policy carefully so that we can be sure that you fully understand the terms on which we will cooperate.

This Privacy Policy explains when, where and why we process Personal Data, how we use it, the conditions under which we may disclose it to others, your rights in relation to your Personal Data and how we keep it secure.

Any questions regarding this Policy should be sent to

2. LEGAL GROUNDS FOR ENESTECH PROCESSINGIn particular, ENESTECH processes your Personal Data if:

2.1. Processing is based on your Consent;

2.2. The processing is necessary to provide our services to you in accordance with the License Agreement, which is a contract between you and us;

2.3. Processing is necessary for our legitimate interests. These legitimate interests are listed below:

– compliance with the financial and accounting legislation of Cyprus;

– assessment of ENESTECH’s business efficiency by analyzing the Site visit indicators and financial activity indicators;

– promotion of ENESTECH through social networks, mass media and affiliated persons, etc.;

– prevention of fraud;

2.4. Processing is necessary to comply with applicable law (for example, processing a request from a Data Subject);

2.5. In exceptional cases, processing is necessary to protect your vital interests or the vital interests of another natural person; or to carry out a task carried out in the public interest or in the exercise of official powers given to us.


3.1. ENESTECH may collect the following types of data about you:


Full name;


Full legal entity name;

Legal address;

Physical address;

Registration number;

Full name of an authorized representative (director);


Club name;

Club address;


Client’s email address;

Client’s phone number;



Server name.



3.2. ENESTECH may collect the following types of data about End Users:

3.2.1. Name, contact information, such as email address, fax number, phone numbers, address, age and gender, IP address, geographic location information, gaming situation, number of ad views, unique mobile device identifier or other device identifiers and settings , information about the use of SENET 2.0 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), feedback on advertising (if any), and as well as information on whether direct marketing messages or electronic newsletters sent by ENESTECH are in line with the End User’s interests.

3.2.2. Analytics tools and ad serving technologies may use server log files, web beacons, pixel tracking cookies, and other technologies to collect the aforementioned information, as well as with information obtained from third-party websites, mobile products and services, with demographic, advertising, market and other analytical studies. In itself, this information is not Personal Data, however, if ENESTECH combines any piece of information with Personal Data, then ENESTECH will treat that information as Personal Data.

3.2.3. ENESTECH does not sell personal data to advertisers or share information that directly identifies an End User (such as name, email address, or other contact information) to advertisers unless the End User gives permission to do so. However, advertisers may inform ENESTECH of the target audience for their advertisements and ENESTECH will show these advertisements 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.


4.1. When you use our services, we monitor and analyze web traffic and track your behavior while using our services. We may receive information about your IP address, proxy server and operating system, web browser or your mobile carrier and location based on phone settings.

In particular, we may collect the following categories of information:

– device identifiers, including cookies;

– information about the device, such as hardware and software settings, operating system, web browser, etc.;

– IP address, location (based on device settings) and login information;

– beacons and tags;

– other website tracking information.

For further information on the use of cookies and similar technologies, please read our Cookies Policy.


5.1. To provide high-quality services, ENESTECH employs people, contracts with independent contractors, and cooperates with other service providers, companies and organizations in strict compliance with Data Processing Agreements (DPAs) or Standard Contractual Clauses (SCCs). For these reasons, some of your personal data may be transferred to the specified persons.

5.2. ENESTECH engages service providers to provide support during the provision of our Services. They include:

– Analytics services.

– Microsoft Azure cloud service.

– Services for receiving and processing electronic payments and services for customer support and organization of customer interaction (Chargebee, Stripe, Zendesk, Pipedrive).

Please note that ENESCTECH does not process your payment details (e.g. bank card number). This data is processed by third-party service providers who securely process your encrypted personal data.

5.3. ENESTECH has contractors in other countries, including outside the European Economic Area, who may have access to your Personal Data. At the same time, in all cases where we transfer your Personal Data to others, we ensure that your Personal Data is protected and used only within the scope of the purposes specified in this Privacy Policy. This is achieved by using only certified services and products, signing data processing agreements for the protection of personal data with contractors and partners (including Standard Contractual Terms adopted by the European Commission and in accordance with EU legislation on data protection), as well as taking technical measures to ensure protection of information during its storage, use, processing and transmission.

5.4. By ticking the appropriate box when providing us with your personal data, you consent to such transfer and processing within the scope of the purposes defined in this Privacy Policy.

5.5. In the event of any merger, acquisition, sale or change of control, we will continue to ensure the privacy of your personal data and will notify affected Users before the personal data is transferred or becomes subject to a different privacy policy.


Your Personal Data will be stored by ENESTECH for no longer than is necessary for the purposes of processing such Personal Data.

As a general rule, ENESTECH stores your Personal Data as long as your Personal Account is active. In case of deletion of the Personal account, ENESTECH keeps personal data for no more than 90 days after deletion.

However, in the event of conflicting situations in the resolution process, ENESTECH may retain personal data for 180 days or more if the processing is necessary for the establishment, exercise or defense of legal claims and to comply with a legal obligation that requires processing under Union or Member State law. After the expiration of this period or earlier, if the conflict situation is resolved, all personal data will be deleted.

After the storage period expires, ENESTECH stops processing your personal data, unless otherwise established by the relevant legislation.


7.1. Right to confirmation

You can obtain confirmation from ENESTECH as to whether your personal data is being processed.

7.2. Right of access

You can access your personal data processed by ENESTECH.

7.3. Right to rectification

You can ask ENESTECH to fill in incomplete personal data that needs correction.

7.4. Right to erasure (Right to be forgotten)

You can ask ENESTECH to delete personal data. In most cases, ENESTECH will remove them unless otherwise required by law. To delete your personal data, you can contact us by email at We will respond to your request to delete your information within 30 days and notify you of the outcome.

7.5. The right to limit the amount of processing

You can challenge the validity of your personal data or if ENESTECH is no longer interested in processing your personal data, but you want ENESTECH to do so for other reasons, for example, for the purpose of filing a claim against someone. In this case, instead of deleting the information, its processing will be limited.

7.6. The right to data portability

You can transfer your personal data directly from one operator to another, if this is technically possible and does not have a negative impact on the rights and freedoms of others.

7.7. The right to object to the processing of your personal data by ENESTECH

You may object to the processing of your personal data if the processing relates to the performance of a task in the public interest or in the exercise of official powers granted to us. Another case is if we process your data for the purposes of legitimate interests pursued by us or a third party, and you believe that such interests outweigh your interests or fundamental rights and freedoms. If you submit a request to object to processing, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing.

7.8. The right to withdraw consent at any time by contacting us

Once we at ENESTECH receive a withdrawal request from you, we will process it in a timely manner and will no longer process your personal data, unless otherwise required by law.

Please note that when your personal data is processed for direct marketing purposes, you have the right to object to such processing at any time without providing any justification, and we will no longer process your data for such direct marketing purposes.


We process your personal data both in Europe and outside Europe. Although the countries where we process data may have different laws, we take steps to ensure compliance with high levels of privacy (namely, as set out in Section 5 of this Privacy Policy).


ENESTECH will provide information on the actions taken at your request in connection with your rights mentioned above within a maximum period of one month from the date of receipt of the request. This period can be extended by another two months if ENESTECH is overwhelmed by the number of requests or if the request is complex and requires many actions. ENESTECH will notify you of any such extension within one month of receipt of the request along with the reasons for such delay.


ENESTECH takes technical and organizational measures to ensure that information is processed in a manner that ensures adequate information security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage. For example, ENESTECH uses verified contractors who may have access to data with whom relevant data processing agreements have been signed.


11.1. In the event that you, as part of working with SENET 2.0 software, will collect personal data of your End Users, it will be your responsibility to comply with all relevant requirements of the legislation on the processing of personal data, including, but not limited to, obtaining the consent of End Users to the processing of personal data.

11.2. You must notify ENESTECH within five working days if you have received any communication from an End User directly or indirectly related to the processing of personal data, including but not limited to requests to exercise rights under data protection laws, complaints or general correspondence and provide ENESTECH with a copy of any such communication. You shall not take any action in connection with such notice, except as required by law, without the prior approval of ENESTECH.

11.2. You must immediately notify ENESTECH of detection of violations of the confidentiality of Personal Data, including those of End Users, so that ENESTECH can fulfill its obligations under Articles 33 and 34 of the GDPR and be able to properly investigate cases of violations of the confidentiality of Personal Data.


12.1. We may make changes to this Privacy Policy from time to time. After any changes to the Privacy Policy are made, your rights may not be limited unless you provide your express consent. The latest version is listed on this page. If we make material changes, we will notify you by email.