PRIVACY POLICY

Reviewed on January 1, 2023

Company adopts this Privacy Policy which describes how it collects and processes the information about the User collected through the Website. Please, do not use the Website if you do not agree to the Privacy Policy.

1. TERMS AND DEFINITIONS

1.1. The following terms used in this Privacy Policy have the meanings set forth in this paragraph:

1.1.1. «Company» or «e-dota2.com» or «We» - , a legal entity incorporated under the laws of Bulgaria, legal address: 70 Tsar Simeon I, Burgas municipality, Burgas district, Burgas, Bulgaria, 8000, Reg. number: 207125574, e-mail: [email protected].

1.1.2. «Personal account» - account maintained by the User for the purposes of trading through the Company.

1.1.3. «Personal Data» - any data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, the possession of the Company.

1.1.4. «Privacy Policy» - the present document.

1.1.5. «Processing» - any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.

1.1.6. «Terms of Use» - an agreement between the User and the Company available at https://e-dota2.com/terms/

1.1.7. «Traffic Data» - the information of the User’s IP addresses, domain servers, types of computers accessing the Website and types of web browsers used to access the Website.

1.1.8. «User», «you» - an individual who uses the Website under Terms of Use.

1.1.9. «Website» - collection of information, texts, graphic elements, design, pictures, photo and video and other intellectual property, as well as the software in the information system available on the Internet at a domain address https://e-dota2.com/.

1.2. In providing you with the Company’s Website, we naturally collect information about you. This Privacy Policy ("Privacy Policy") sets out what we collect, how we store, use that information, who we might share it with, and the steps we take to make sure it stays private and secure.

1.3 The headings (of articles) of the Privacy Policy are for convenience only and shall not in any way affect the meaning or interpretation of the Privacy Policy.

1.4. The Privacy Policy shall be governed and construed in accordance with the laws of the Company’s domicile, unless otherwise expressly provided.

2. COLLECTED INFORMATION

2.1. The Company may collect the following information when the User accesses the Website:

2.1.1. User’s IP address.

2.1.2. Device information including, but not limited to, identifier, name, and type of operating system.

2.1.3. Mobile network information.

2.1.4. Standard web information, such as the User’s browser type and the pages the User accesses on the Website.

2.2. The Company uses cookies or similar technologies that may to some extend identify the User. Cookies are small text files that enable the Company to collect the information about web-browsing activities of the User such as the pages visited by the User and the time the User spent on viewing the page. The User may decline the cookies at his or her discretion in the personal settings of the web-browser. See Section 4 of this Privacy Policy for more information.

2.3. The Company collects Personal Data that the User provides directly under the Terms of Use to perform any transactions at the Website or use the Company’s services. Personal Data may include:

2.3.1. Personal information, such as:

2.3.1.1. Name and Surname.

2.3.1.2. Date of birth.

2.3.1.3. Home address.

2.3.1.4. Email address.

2.3.1.5. User’s social media profile.

2.3.2. Financial information, such as:

2.3.2.1. Bank account number.

2.3.2.2. Bank statement and trading information.

2.3.2.3. Previous transaction or payment history.

2.3.2.4. Any other information, including payment information, that may be required for transaction performance.

2.3.3. Identity verification information, such as:

2.3.3.1. Images of the User’s government issued ID.

2.3.3.2. Images of the User, holding his ID.

2.3.3.3. Any other Personal Information, that might be required to establish the User’s identity.

2.3.4. The User’s Steam unique numeric identifier.

2.3.5. Residence verification information.

2.4. When the User uses a location-enabled device to access the Website and services, the Company may collect geographical location data or use various means to determine the location, such as sensor data from the User’s device that may, for instance, provide data on nearby cell towers and Wi-Fi access spots.

2.5. The Company will not knowingly collect personally identifiable information from any person under the age of 13. Parents, who are concerned about the transfer of personal information from their children, may contact the Company by [email protected].

3. THE PURPOSES OF THE DATA COLLECTION

3.1. The Company uses the Data, which we collect according to the paragraph 2.1, in order to:

3.1.1. Administer the Website and personalize the Website for the User.

3.1.2. Understand traffic patterns and the number of visitors to the Website.

3.1.3. Understand how the User uses and interacts with the Website.

3.1.4. Improve the Website.

3.1.5. Build up statistical data for auditing, research, modeling, and reporting for our advertisers and other partners.

3.1.6. Provide the User relevant advertising and content.

3.2. The Company uses the Data, which we collect according to the paragraph 2.3, in order to:

3.2.1. Process the User’s transactions.

3.2.2. Respond to the User’s service requests and support needs.

3.2.3. Verify the User’s identity and Steam community profile.

3.2.4. Access information about the User’s Steam Account to provide services to the User through the Website.

3.2.5. Contact you about the Company ’s technical notices, support, news, updates, promotions and new services (marketing communications). If you wish to stop receiving marketing communications from us, please contact us at [email protected] to opt-out.

3.2.5. Verify the User’s identity.

3.2.6. Verify that the transaction is actually performed by the User.

3.2.7. Follow international anti-money-laundering and KYC rules and practices.

3.2.8. Prevent any fraud or illegal activities.

3.2.9. Enable the transaction performance.

3.2.10. Follow requirements on person identification, established by Payment Service Providers.

3.2.11. Administer the Website and provide services to the User.

3.3. The Company may use the User’s Personal Data and other information we collect to detect, investigate and prevent fraudulent transactions and other illegal activities, develop new products and services and to verify compliance with the Website Terms of Use. The Company will not share any of the User’s Steam login credentials with third parties.

3.4. If the User does not provide the Company with any of the requested personal data, the User may not be able to use the Website properly. The Company may refuse the User access to Our Service and Website should we, in good faith, have doubts as to validity or authenticity of any personal data the User provides.

4. COOKIES

4.1. The Company uses cookies and other similar technologies (e.g. web beacons, Flash cookies, etc.) ("Cookies") to enhance the User’s experience using the Website. Cookies are small text files that are placed on the User’s device by websites that the User visits. They are widely used in order to make websites work, or work more efficiently, and to deliver a better and more personalized service. Cookies may be either "persistent" Cookies or "session" Cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the User before the expiry date). A session cookie, on the other hand, will expire at the end of the User session, when the web browser is closed.

4.2. The Company uses the following Cookies:

4.2.1. Strictly necessary Cookies. These are Cookies that are required for the operation of the Website.

4.2.2. Analytical/performance Cookies. They allow us to recognize and count the number of Users and to see how Users move around the Website when they are using it. This helps us to improve the way the Website works.

4.2.3. Functionality Cookies. These are used to recognize the User when he returns to the Website. This enables us to personalize our content for the User (for example, the User’s choice of language).

4.3. The Company uses Google Analytics which is a web analytics tool that helps us understand how the User engages with the Website. Like many services, Google Analytics uses first-party cookies to track the User interactions as in our case, where they are used to collect information about how the User uses the Website and how he uses it. This information is used to compile reports and to help us improve the Website. The reports disclose Website trends without identifying individual visitors. The User can opt out of Google Analytics without affecting how the User visits Our Website – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.

4.4. You can find more information about Cookies and how to manage them at http://www.allaboutcookies.org/. You may control the use of Cookies within your internet browsers’ settings. If you reject or delete certain Cookies, be aware that the performance of the related features and functions of the Website and services may be impaired.

5. TRANSFER OF PERSONAL DATA TO THE THIRD PARTIES

5.1. The Company reserves the right to store the information, including Personal Data collected under paragraphs 2.1 and 2.3 of the Privacy Policy, within the period up to 5 years. The Company uses standard adequate security measures against loss, misuse or alteration of such information. However, the Company cannot guarantee the total invulnerability of the security system from illegal actions of the third parties and the User shall not address any claim in relation to any damages caused by illegal actions of the third parties.

5.2. The User agrees that the Company may share and transfer information, including Personal Data collected under paragraph 2.3 of the Privacy Policy, to the third party who is contracting party with both the Company and the User. This third party may have its own policies and practices of Processing. At any event the Company is not responsible for such policies or practices of any third party.

5.3. The Company may share the User’s Personal Data where:

5.3.1. The Company needs to in order to operate the Website and Service.

5.3.2. The Company needs in order to perform the User’s transactions on the Website through or partner Payment processors.

5.3.3. The Company has a public or legal duty to do so (e.g. to assist with detecting fraud, tax evasion, financial crime prevention, regulatory reporting, litigation or defending legal rights and property, including our own).

5.3.4. The Company has asked for the User’s permission to share the User’s information and the User has agreed.

5.4. The Company may share the User’s Personal Data and information with:

5.4.1. Law enforcement, government officials, or other third parties when the Company is compelled to do so by a subpoena, court order, or similar legal procedure; or the Company believes in good faith that the disclosure of personal data is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of any of our policies.

5.4.2. The Company’s vendors and agents including hosting providers, hired by us to provide services, game developers.

5.4.3. Payment processors (for the purpose of the User’s transactions performance when using the Website).

5.4.4. Companies that the Company plans to merge with or be acquired by (should such a combination occur, the Company will notify the User and will require that the newly combined entity follow these terms with respect to the User’s personal data).

5.5. The Company will not:

5.5.1. Will not provide the User’s Personal Data to any other Website Users or third parties other than described in this Privacy Policy without notifying the User first.

5.5.2. Will not sell or rent the User’s personal data to third parties, other than as described in this Privacy Policy without notifying the User first.

5.6. Whether the Company assigns its rights to the third party or is involved in a merger or similar transfer of assets, the User grants to the Company the right to the transfer the Personal Data to its assignee, acquiring company or transferee of the assets.

5.7. The Website may, from time to time, contain links to and from the websites of our partner networks, game developers, advertisers, Payment processors, etc. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any information, including personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any information or personal data to these websites or use these services.

5.8. The Website may also contain services of/from our partners, vendors, game developers.

In order to provide Services to you and/or for the purpose of duly transactions performance on the Website, when you use Our Website, it, may, from time to time, get and/or collect User’s personal data, such as your name (username, login) and/or other identifiers from our partners’, vendors’, game developers’ Services. We will not provide this data to any other Website users or third parties other than described in this Privacy Policy without notifying you first. Please note that these services that our Website may contain have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any information, including personal data that may be collected through these services, such as contact and location data. Please check policies of such services before using these services.

5.9. For the purpose of duly transactions performance on the Website Users might be required to provide their personal and payment processing data (such as name, surname, address, copies of ID cards or other identifying documents, residence place confirmation documents, credit card identification data) to the respective Payment Service Provider, including the consent for processing these data by the payment services in order to carry out the requested transactions. Please note that the respective personal and payment processing data provided by you to a third-party Payment Service Provider shall be collected, stored and processed solely by the respective Payment Service Provider and not subject to this Privacy Policy. You should read carefully and follow the applicable privacy policies of the Payment Service Provider.

6. KEEPING YOUR INFORMATION SAFE AND TRANSFERRING IT

6.1. The Company protects your information using security standards such as firewalls and data encryption, physical access controls to our premises and information access authorization controls. We also authorize access to your information only for those employees or contractors who require it to fulfill their job or service responsibilities.

6.2. Please note that transmission of data or information (including communications by e-mail) over the internet or other publicly accessible networks is not one hundred percent secure. Please note that we are not liable for the security of any data you are transmitting over the internet.

6.3. The Company stores and processes your information using cloud services in various jurisdictions, including the United States of America. As such, the information that we collect from you may be transferred to, and stored in various jurisdictions outside of your country of residence and outside the European Economic Area ("EEA"). The laws on processing such information, including where such information is classed as "personal data", in these locations may be less stringent than in your country. It may also be processed by staff operating outside of your country or the EEA who work for us, for one of our service providers or one of our business partners. By submitting your information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.

7. USER’S RIGHTS

7.1. The User may access, review and edit his Personal Data at any time by contacting our support team via [email protected]. The User may be requested by our team to provide the respective confirmation documents in case of your personal data information change.

7.2. European Users have the right under applicable privacy laws to ask us via [email protected] to provide details of the personal data we hold about them or in certain circumstances may request we delete their personal data.

7.3. A request on access, review, provision of details, amendment or deletion of personal data is usually processed within 72 hours from the moment the Company receives it. However, due to technical reasons delays are possible, and in such case the Company shall process the respective request within a reasonable term.

8. CHANGES IN THE PRIVACY POLICY

8.1. The Company reserves the right to add to, change, update, or modify the Privacy Policy. Any such change, update, or modification will be effective immediately upon posting on the Website and the User acknowledges that the ongoing use of the Website is independent and adequate consideration in support of such modification. If any modification is unacceptable, the User’s only recourse is not to use the Website.