Russian Federation

Moscow

May 10, 2020.

 

Trip Fare Area website, located at the domain name tripfarea.eu, (or “we”) is dedicated to protecting the privacy rights of our online users (“users” or “you”). This Online Privacy and Cookie Policy (the “Policy”) has been crafted to inform you as to the ways we collect, store, use, and manage the information you provide in connection with any “Trip Fare Area” website (collectively, the “Site”). Please note that the scope of this Policy is limited only to information collected by Trip Fare Area through use of the Site. This Policy does not apply to the practices of third parties that Trip Fare Area does not own or control.

Trip Fare Area offers information available at https://tripfarea.eu also to users resident in the EU. Trip Fare Area is the data controller for personal information collected of those users. Users who are resident in the EU may address questions relating to the way we collect, store, use and disclose their personal information to Trip Fare Area at the email tripfarea@tripfarea.eu.

Also, the function of recall and deletion of personal information is available in the user’s personal account.

For users not located in the EU

When signing up for the website Trip Fare Area, you are invited to agree with this Policy and the processing of your data, including your personal information, also called personal data in some jurisdictions (we refer to this informationdata collectively as “personal information” throughout this Policy), in the manner provided in this Policy and our Terms of Use. We therefore process your personal information based on your consent. In any event, any use of the site will be construed as your agreement with this Policy and our Terms of Use. If you do not agree to these terms, please do not use our site.

Specifically for users located in the EU

This Policy is merely informative about how Trip Fare Area collects, stores, uses and discloses your personal information. We are not asking you to consent to this Policy. If we require your consent we will ask for it in separate notice and consent forms. Please note that if you provide us with consent, you have the right to withdraw this consent at any time by contacting us at tripfarea@tripfarea.eu.

It is advised that you review this Policy regularly as it may be amended from time to time as set out below (see the Changes to this Policy section below).

PERSONAL DATA

Personal data is any information relating to you as an individual and through which you can be identified directly or indirectly, such as your name, photograph or identification number.

We are committed to protecting your privacy and freedom and will only process personal data in accordance with applicable data protection legislation. How we process your personal data depends on whether you are a registered user or just a visitor to our Website.

We have tried to describe how we process personal data as transparently and clearly as possible in the Privacy and cookie policy below. We invite you to carefully read the policy that applies to you and to contact our Data Protection Officer at tripfarea@tripfarea.eu if you have any questions.

If you visit our website, we will process your personal data in accordance with this Privacy and cookie policy.

INFORMATION COLLECTION

We collect information about you directly from you, from third parties, and automatically through your use of our Site. We may combine the information that we collect about you from these various sources.

Information we collect directly from you

We will also collect any information that you provide to us through your use of our Site. The types of personal information we collect may vary depending on your activity. Personal information may include:

  • name and surname;
  • user contact number;
  • email address (e-mail);
  • user address;
  • user identification number

If you contact us via email (e.g., to contact customer support), we will collect your name and email address, as well as any other content included in the email, in order to send you a reply. We may use your personal information submitted in your communications to contact and respond to you.

Additionally, we may acquire information from you through your access and participation in message boards on the website. This information may include posts, comments, photos or screenshots, videos, ratings and other. If you post content to our website, such information may be available to other users of our website (e.g., if you upload a profile picture, your image may be available to all other users of our website). If you post your own content on our website, your posting may become public and “Trip Fare Area” cannot prevent such information from being used in a manner that may violate this Policy, our Terms of Use, the law, or your personal privacy.

Information we collect about you from third parties

When you install any of the website, we may collect and record the information you provide us voluntarily through a social networking website in accordance with their policies and terms.

If you log into our website using Facebook, you must enter your Facebook email address and password. We will ask that you grant us permission to access and collect your Facebook basic information (this includes your name, profile picture, gender, networks, user IDs, list of friends, date of birth, email address, and any other information you have set to public on your Facebook account).  If you allow us to have access to this information, then we will have access to this information even if you have chosen not to make that information public.

If you log into our website using Google, you must enter your Google email address and password.  By logging in through Google, you are granting us access to your Google profile information, which may include your name, location, email, birthday, and any demographic data.

You may also be able to log into our website using other third-party websites. We encourage you to read the privacy policies of third-party platforms that you use to log into your gaming accounts to understand how those third parties use and disclose your information. We have no control over how any third party site uses or discloses the personal information it collects about you.

Information we collect automatically about your use of our website

When you use the website, we may record information regarding the use of the website, and we may collect other information that is visible on your social network page in accordance with the relevant terms of use associated with that page.

If you use the website on your mobile telephone or other mobile device, including iPads and tablets, we collect mobile device identifiers, including Media Access Control (MAC) address, and possibly IP address. In certain games we will create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as user name, character name, general location (based on your Internet Protocol (“IP”) address) or e-mail address. This information is useful to us for troubleshooting and helps us understand usage trends.

Except as described in this Policy, we will not share this information with any third party. If you no longer wish to allow us to track or use this information, you may turn it off.

In addition, we create a unique user ID to track your use of our website. This unique user ID is stored in connection with your account information.

Please see the Cookies section below for more information about the information we automatically collect about you.

Public Information

Some of the information you give us when you register is open to the public, such as your profile picture, your username, the date of registration. Should you wish to hide any of the information that is made public, you can do so by changing the settings to “only me” in the privacy settings tab of your profile.

INFORMATION USE

We need the above personal information for the purposes as described in this Policy, and not providing this information will have an impact on our ability to provide you with the website. “Trip Fare Area” primary objective in collecting user information is to provide and enhance the website and to enable users to easily navigate and enjoy the website. This includes sending you electronic communications related to the website, from which you can unsubscribe at any time using the instructions in such communications. In addition, we may use user information for the following purposes:

Providing and improving our websites. To facilitate payments and communications between users; to provide and maintain the website; to improve the website; to develop new features, products, or websites; to authenticate users; to perform technical operations, such as updating software; to validate our users and ensure their qualifications to use the website; and for other customer website and support purposes.

Marketing and communications. To communicate with you, including via email or others notification, about your account and use of the website, including to send website updates; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, and other information we think may interest you; and for other informational, marketing, or promotional purposes. For more information about opting out of certain communications, please see the Your rights and choices in relation to your personal information section below.

Research and analytics. To analyze how you interact with the website; to monitor and analyze usage and activity trends; and for other research, analytical, and statistical purposes.

Protecting rights and interests. To protect the safety, rights, property, or security of “Trip Fare Area”, the website, any third party, or the general public; to detect, prevent or otherwise address fraud, security or technical issues; to prevent or stop activity which “Trip Fare Area”, in its sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Policy and our Terms of Use.

Legal compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.

Specifically for our users who reside in the EU, we rely on the following legal bases for the collection and use of your information:

  • to provide you with the website you request, pursuant to our Terms of Use;
  • based on our legitimate business interest, and subject to your right of objection, to: (I) improve our websites, (II) ensure the security of our site, (III) send you newsletters, marketing emails and others notifications with the latest information, (IV) to protect our rights and property, enforce our terms of use and legal notices and for the establishment, exercise and defense of legal claims, and (V) to conclude corporate transactions (e.g., corporate restructuring, sale or assignment of assets, merger); (VI) share your information with third party marketplaces and website providers for adverting purposes.
  • to comply with our legal obligations, any court order or binding decision;
  • for purposes unrelated to those described in this Privacy Policy by first notifying you and, where required, offering you a choice as to whether or not we may use your personal information in this different manner.

To the extent you provide information about friends and family members, you will present them this Privacy Policy and obtain their consent to provide the information. If you do not have their consent, do not send us their personal information.

COOKIES

Like many websites, Trip Fare Area uses server log files and automated data collection tools, such as cookies and web beacons (collectively, “Data Collection Tools”) when you access or use our website. We tie the information gathered by these means to our customers’ personal information. These Data Collection Tools automatically track and collect certain technical information that your computer or device, such as your IP addresses, browser types, browser language, referring and exit pages, URLs, platform type, the number of clicks, domain names, landing pages, clickstream data, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of activity on our website, and other similar information. In some cases, we will associate this technical information with your ID number for our internal use. By using our website, you consent to our use of cookies, web beacons and Data Collection Tools.

A cookie is a very small text document which normally contains a unique identifier. Cookies are created when your browser loads a particular website. The website sends information to the browser and the browser then creates a text file. Each time a user returns to the same website, the browser retrieves and sends this file to the website’s server. More information on using cookies can be found at www.allaboutcookies.org.

We use cookies for a variety of reasons, including to: (I) analyze the usage of our website; (II) provide a more personalized experience; (III) manage advertising; (IV) allow you to more easily login to our website; (V) help make your use of our website more efficient and more valuable by providing you with a customized experience and recognizing you when you return.

We may also employ web beacons or other technology for a variety of reasons such as: (I) allowing us to know if a certain page was visited or whether an email was opened; and (II) tracking pixels, which allow us to advertise more efficiently by excluding our current users from certain promotional messages or identifying the source of a new installation.

You can set your web browser to warn you about attempts to place cookies on your computer, limit the type of cookies you allow or refuse cookies all together. We invite you to visit the support websites of the various browsers you may use to learn on how to block the use of Data Collection Tools. However, you may not be able to use some or all of the features of the website if you refuse/disable cookies.

When you give your consent to our use of cookies, we will usually retain your consent for one month from your last interaction with our websites or applications before asking for your consent again.

This table summarises the different purposes for which we use cookies.

Cookie categoriesMaximum Storage Period of Data Collected through Cookies

1. Cookies required

These cookies are necessary to enable and maintain the main functionalities of our websites and applications. The services you have requested, such as adding products to your order, cannot function without these cookies. Certain parts of our websites and applications will not work without these cookies, such as adding products to your order or completing your order. We also use cookies to help keep our platform secure and to test new features to ensure that they do not interfere with the main functions of the platform.

25 months

2. Functional cookies

We may use cookies that are not essential but enable various useful features on our websites. For example, these cookies collect information about your interaction with our websites and applications, and can be used to remember your preferences or interests.

25 months

3. Analytic cookies

We analyse your behaviour as a user on our website, using cookies and similar technologies, in order to improve our website and adapt it to offer you the best possible experience. We hope that by analysing this data we can ensure that our website is as user-friendly as possible. For example, we keep track of which pages are most visited and how you navigate our website. We use Google Analytics to better understand how customers use our websites and applications. If you do not want to use Google Analytics in your browser, you can install the following Google add-on: https://tools.google.com/dlpage/gaoptout?hl=en_GB.

25 months

4. Advertising cookies

We use cookies and similar technologies to provide you with advertising on our platform and services and to collect information about your browsing habits so that the advertising we provide is more relevant to you and your interests. For this reason, we analyse (among other things), how often you use our website and which products interest you. This allows us to better tailor the advertisements we provide to you. We also use these cookies to check whether you come from a website of our advertisers or partner companies. We may share this information with third parties who help manage our online advertising.

25 months

5. Social network cookies

These cookies are used when you share information using a share button from a social network or a “like” button on our websites or applications, or when you interact with our content on or through a social platform such as Facebook or Twitter. These cookies collect information about your social networking interaction with us, such as whether or not you have a social network account and whether you are logged into your account when you interact with our content on our websites and applications. This information may relate to advertising targeting activities.

25 months

MANAGE YOUR COOKIE PREFERECES

1. Enable/disable cookies and delete cookies It may also be possible to delete or disable cookies that have previously been installed on your device through your browser settings. By disabling cookies, parts of our website may not work. Cookies that are essential to the operation of the website cannot be deactivated. You can use the links below to learn more about how to change your browser’s cookie settings, and how you can delete cookies through your browser settings:

  • Chrome
  • Firefox
  • Internet Explorer
  • Edge
  • Safari (iOS)
  • Safari (macOS)
  • Opera
  • Samsung Android Browser

2. Additional information and questions For more information on the processing of your personal data, including information on your rights, please consult our privacy policy. If you have any questions or complaints regarding our cookie notice, we are happy to assist you. We would also like to hear any suggestions you may have for improving our cookie notice. You can contact us at tripfarea@tripfarea.eu.

DO NOT TRACK DISCLOSURE

Our website does not respond to Do Not Track signals. For more information about Do Not Track signals, please click here. You also may opt out of interest-based advertising by following the instructions in the “Your rights and choices in relation to your personal information” section below.

THIRD PARTY WEBSITES

Please note that third party partners/providers, such as analytics companies or companies delivering advertisements on the website, may also use cookies or other technologies, and those practices and providers are subject to their own policies.

Our website may contain third party tracking tools from our website providers. Such third parties may use cookies, APIs, and SDKs in our websites to enable them to collect and analyze user information on our behalf. The third parties may have access to information such as your device identifier, MAC address, geo-location information, and IP address for the purpose of providing their websites under their respective privacy policies. This Policy does not cover the use of tracking tools from third parties. We do not have access or control over these third parties. The following are examples of the third parties that we use for analytics:

Google Analytics

Trip Fare Area uses a tool called “Google Analytics” to collect information about use of this website. Google Analytics collects information such as how often users visit this Site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. Trip Fare Area uses the information it gets from Google Analytics to understand website usage and patterns and to improve its website. Google Analytics collects only the IP address assigned to you on the date you visit a website, rather than your name or other identifying information. Trip Fare Area does not combine the information collected through the use of Google Analytics with personal information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit a website, the cookie cannot be used by anyone but Google.

Google’s ability to use and share information collected by Google Analytics about your visits to our website is restricted by the Google Analytics Terms of Use (as amended for government websites) and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this Site by disabling cookies on your browser or mobile device. For more information about Google Analytics, please see the Google Privacy Policy. To prevent Google Analytics from using your data through a web browser, you can get the Google Analytics Opt-out Browser Add-on.

SHARING OF INFORMATION WITH THIRD PARTIES

Except as set forth in this Policy, Trip Fare Area does not share your personal information with any third parties. In the event we offer websites or promotions where your information is separately collected and used according to the privacy policy of a third party, we will inform you of that at the time of collection and you may elect not to participate in the website or promotion.

We will share your information with other Trip Fare Area users as necessary to provide our websites. For example, if you post a profile picture, that picture may be available to all other users of our websites.

We also may share your information with third parties as required by legal or regulatory obligations; as requested by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or us to legal liability; or as Trip Fare Area otherwise deems necessary to detect, prevent, or otherwise address fraud, security, technical issues, or other threats to Trip Fare Area or others.

We may share your information with third party companies that perform websites on our behalf, including payment processing, order fulfillment, data analysis, marketing websites, email campaigns, hosting websites, and customer website. While providing the websites for us, these companies may access your personal information, and are required to use it solely as directed by us for the purpose of our requested website.

In conjunction with the running of our games we may partner with a third party to assist us in providing you with our website. We will share the information you provide us through your social network, such as (1) your first and last name; (2) your profile picture or its URL; (3) your user identification number of the pertinent social network, which is linked to publicly available information such as name and profile picture; (4) the login email you provide to the pertinent social network upon registration; and (5) game play information with these third parties so they may facilitate the use of our website as well as contact you about other games which may be of interest to you, website notifications and to solicit your feedback and input. If you do not wish to have this information shared please do not use our website. If you wish to no longer have your personal information used by our partners you may contact us at tripfarea@tripfarea.eu and we will facilitate your request to the partner.

We may disclose your information to another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.

We may use and share with third party advertisers (and other third parties) certain technical information and other non-personal information to show general demographic and preference information among Trip Fare Area users. We may also allow advertisers to collect technical information and other non-personal information, which they may share with us, through the use of tracking technologies like cookies and web beacons. The information collected may be used to offer you targeted ad-selection and delivery in order to personalize your user experience by increasing the likelihood that advertisements for products and websites you see will appeal to you, a practice known as behavioral advertising, and to undertake web analytics (i.e. to analyze traffic and other end user activity to improve your experience). Please see the your rights and choices in relation to your personal information section below for more information about opting out of behavioral advertising.

Information about our users is an integral part of our business. We share your personal information only as described in this Policy.

STORAGE OF YOUR PERSONAL INFORMATION

The personal information we collect, as described in this Policy, is being stored on servers in the Russian Federation. You expressly agree with your personal information being stored and processed in this country.

Specifically for our users who are resident in the EU, we are not asking you to consent to the storage of your information in the above mentioned country. Rather, we have put in place appropriate contractual safeguards to protect your personal information in compliance with applicable laws. As indicated above, you have a right to request information on those contractual safeguards.

DATA RETENTION

We will keep you information for as reasonably necessary for the purposes set out above, though generally no longer than 3 years.

We may keep your personal data for longer if required by applicable laws.

PROTECTING PERSONAL INFORMATION

We strive to protect personal information while it is under our control. If you have an account with us, your account information is accessible online only through the use of a password. To help protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. You acknowledge that you provide your personal information at your own risk. You are also responsible for all uses of the Trip Fare Area by any person using your password. Please advise us immediately if you believe your password has been compromised or misused.

SECURITY

We have implemented commercially reasonable technical, physical, managerial and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. However, we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use, disclose, or alter your personal information for improper purposes. Also please note that email and messaging systems are not considered secure, so we discourage you from sending us personal information through these mediums.

In the event that personal information has been or is compromised as a result of a breach of security, Trip Fare Area will promptly notify those persons whose personal information has been compromised, in accordance with the notification procedures set forth in this Policy, or as otherwise required by applicable law.

To protect your privacy and security, we may take reasonable measures (such as requiring a unique password) to verify your identity before permitting you access to your account or the website. You are responsible to maintain the secrecy of your unique password and account information, and for controlling access to your email communication or interaction through Trip Fare Area.

YOUR RIGHTS AND CHOICES IN RELATION TO YOUR PERSONAL INFORMATION

Accessing, correcting, or deleting your personal information

Trip Fare Area takes your privacy seriously and works in a transparent way. In that sense, upon providing sufficient identification (to protect others’ privacy), you can request information from us about the personal information we hold in relation to you and you can correct any inaccurate data we hold.

Furthermore, you can change or delete any personal information by changing the applicable information found in your Trip Fare Area account. However, if you decide to delete or anonymize your personal information, you may no longer have access to certain content and your account may become deactivated.

In certain territories (including the EU), you also have a legal right to ask for a restriction of processing, to object to processing as well as the right to data portability. However, these rights are subject to conditions and may not always be applicable.

You have the right to withdraw your consent, on the basis of which we process your personal information, at any time, by closing your account or otherwise clearly indicating your withdrawal of consent. However, this does not affect our lawful processing based on your consent before this withdrawal.

If you want to exercise any of these rights, please contact us at: tripfarea@tripfarea.eu

Marketing communications

Subject to applicable legal provisions, we may send periodic promotional or informational emails to you. You may opt out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any website you have requested or received from us.

Behavioral advertising

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and your choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and your choices regarding having information used by NAI members. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.

Users in the European Union may go the European Interactive Digital Advertising Alliance (“EDAA”) Your Online Choices website and select their country to learn more about interest-based advertising and how to opt out in their own country. For example, users in France may go to the Contrôler ses cookies website to opt out of certain third-party ad networks’ interest-based advertising and find additional information at www.youronlinechoices.com/fr.

Opting out from one or more companies listed on the DAA Consumer Choice Page, the NAI Consumer Opt-Out Page, or through the various EDAA websites will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or App or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). If your browser is configured to reject cookies when you opt out on the DAA, NAI, and/or EDAA websites, your opt out may not be effective. Please note that if you use multiple devices you will have to opt out on each individual device.

LINKS TO OTHER WEBSITES OR APPLICATIONS

Links from the Trip Fare Area website to third party websites or applications are provided for your convenience. In addition, content in the website may be hosted by other websites or applications. Any personal information you provide on the linked pages or applications is provided directly to that third party and is subject to that third party’s privacy policy, not ours. These other websites and applications maintain their own policies regarding cookies and the collection and use of personal information. It is up to you to review those policies yourself.

POLICY REGARDING CHILDREN UNDER THE AGE OF 13

Most of Trip Fare Area’s websites are general audience and are not directed to children under the age of 13. Through these websites, Trip Fare Area does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to access those websites.

Through other websites, however, Trip Fare Area may be more likely to collect some personal information about children under 13. For such websites, Trip Fare Area will request users’ ages and, if a user indicates that s/he is under 13, Trip Fare Area will only collect personal information, such as persistent identifiers (e.g., IP address and device information), necessary for internal operations of the website. Trip Fare Area will only use such information to support internal operations of the website and not for other purposes.

If you are under 13, please do not attempt to register an account with any of the websites or send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal information other than persistent identifiers used to support internal operations of the websites, from a child under the age of 13, we will delete that information as quickly as possible. We recommend that minors over the age of 13 ask their parents or guardians for permission before sending any information about themselves to anyone over the Internet.

If you are between 13 and 16 years old, you live in the European Union or United Kingdom, and we ask for your consent, make sure that under your country’s data protection laws you are able to provide valid consent without authorization of your parents or guardian. We will verify your age and as the case may be ask for parental/guardian consent.

CHANGES TO THIS POLICY

Trip Fare Area may amend this Policy from time to time. Use of information we collect now is subject to the Policy in effect at the time such information is used. If we make changes in the way we use personal information, we will notify you by posting an announcement on our website or sending you an email. You are bound by any changes to the Policy when you use the website after such changes have been first posted. If you object to any change, your sole recourse shall be to immediately terminate your account and cease using the website.

QUESTIONS OR CONCERNS & CONTACT DETAILS

If you have any questions or concerns regarding privacy at Trip Fare Area, please contact us at:

Email: tripfarea@tripfarea.eu

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