Privacy Policy

Version: 1.0

Date: November, 2024

This document, known as the 'Privacy Notice,' provides an explanation of the privacy regulations that apply to the collection and submission of Personal Data and other information when you access, install, or use Services via our Website https://social-gate.net  ‘Website’), regardless of the device (computer, mobile phone, tablet, etc.) you utilize.

The entity responsible for processing your Personal Data, as outlined in this Privacy Notice, is: ASG 360 SERVICES LTD, Voukourestiou, 25, NEPTUNE HOUSE 1st floor, Flat/Office 11 Zakaki, 3045, Limassol, Cyprus. Company registration number HE 441291;

email: [email protected] ('we,' 'us,' or 'our').

For the processing of Your Personal Data, when You access and use our Website, we act as a Data Controller within the meaning of the applicable data protection laws. In this case, we determine the purposes and means of the processing of Your Personal Data and take primary responsibility.

For the processing of End users’ personal data, when You use Social Gate on our Customers’ websites and/or mobile app we act as a Data Processor and process Personal Data on behalf of our customers.

If You are an End user of our customer and are concerned about processing of Your Personal Data by such customer or want to exercise Your rights as a data subject, please contact such customer directly.

TABLE OF CONTENTS

  • Handling of your Personal Data
  • Objectives for Processing Personal Data
  • Basis for Processing Personal Data
  • Sharing your Personal Data
  • Cross-Border Transfers of Personal Data
  • Rights related to your Personal Data
  • Data Security
  • Data Retention
  • Country Specific Provisions
  • Children’s Data
  • Links to Other Websites
  • Updates to the Privacy Notice
  • Additional Terms

HANDLING OF YOUR PERSONAL DATA

We may process the following categories of Personal Data:

Technical data. In the course of Your access and use of the Website, we automatically collect from Your browser and process the following personal data:

  • IP address, information about your location, information about your mobile operator or Internet provider;
  • Data related to your device: its operating system, browser type, and version, screen resolution, set time zone, language settings, device type: its model and manufacturer (if applicable);
  • Information about your browsing session and any interaction with the Website interface (for example, the number of pages you visited, the number of pages you clicked);
  • Information about the source from which you visited the Website;
  • Cookie data.

Contact data. When You contact us with general questions about Social Gate, our Company, Services, or this Website or with the aim to order our Services we may collect and process the following Personal Data:

  • Your name
  • Your email
  • Name of the organization You represent
  • Other data voluntarily provided by You

Search data. When You contact us on behalf of the organization interested in our Services, we may conduct an independent search and analysis of information about Your company and You from open sources. We may collect the following data:

  • User identifier (UID);
  • Your public account information available on Social networking services. This data may include Your first name, last name, gender, date of birth, state, city, email, telephone number, photo, date of the account creation. We will collect only those data that You have authorized for sharing from Your public account.

OBJECTIVES FOR PROCESSING PERSONAL DATA

We adhere to purpose limitation and lawfulness principles. So, we collect and process Your Personal Data for specified, explicit, and legitimate purposes and on appropriate legal bases. In this part of the Privacy Notice, You can find the description of legitimate purposes and legal bases for processing we carry out as a Data Controller:

Legitimate purpose Personal data Legal basis
Making our Website available and usable Technical data Legitimate interest. Our legitimate interest is to give You access to our Website and its complete functionality.
Ensuring the correctness of the Website operation and security Technical data Legitimate interest. Our legitimate interest is to keep our Website working correctly and properly as well as prevent and eliminate any external threats to the Website.
Making our Website better Technical data Legitimate interest. Our legitimate interest is to make our Website as good and convenient for You as possible.
Communication with You Contact data
Search data
Technical data
Legitimate interest. Our legitimate interest is to maintain communication with You both on general matters and in negotiations before entering into the contract with the organization You represent.
Understanding the context of future business relations with prospective Customers Contact data
Search data
Legitimate interest. Our legitimate interest is to understand and anticipate how to work with prospective Customers.

SHARING YOUR PERSONAL DATA

We do not disclose your Personal Data to third parties unless specified in this Privacy Notice:

  • Service Providers: we engage third-party service providers to assist us with various operations, including email automation, website and app diagnostics, analytics, and more. Consequently, some of these service providers may process Personal Data.

Key long-term service providers include:

  • Website hosting providers, IT security providers, email service providers, and analytics providers.
  • Our clients, partners, and other stakeholders, as necessary for the provision and improvement of our Services.
  • Legal and regulatory authorities, as required by law.
  • Professional service providers, for the purpose of seeking professional advice.

CROSS-BORDER TRANSFERS OF PERSONAL DATA

To facilitate our Services and Websites, we may store, access, and transfer Personal Data globally, including in countries where we operate. These countries may not offer the same level of Personal Data protection as your country of residence. We assess cross-border data transfers and implement appropriate safeguards to ensure that your Personal Data remains protected in accordance with this Privacy Notice. For instance, if your Personal Data is transferred to countries outside the European Economic Area (EEA), we ensure the recipient country has received an adequacy decision from the European Commission. To transfer personal data to recipients lacking an adequacy decision, we may utilize standard contractual clauses that have been approved by the European Commission or other legally recognized transfer mechanisms. These measures are in place to safeguard the protection of your Personal Data. We are committed to conducting such transfers securely and in accordance with relevant data protection regulations.

RIGHTS RELATED TO YOUR PERSONAL DATA

Please note that different jurisdictions have various data protection laws that grant privacy rights to you as a data subject. Subject to applicable data protection laws, you may have the following rights:

  • Deletion: Request the erasure of your Personal Data.
  • Access: Know and access the Personal Data collected by us about you.
  • Rectification: Correct, update, or supplement inaccurate or incomplete Personal Data held by us.
  • Objection: Object to the processing of your Personal Data based on our legitimate interests (e.g., for marketing purposes).
  • Portability: Request a copy of your Personal Data in a structured, commonly used, and machine-readable format or, if technically feasible, transmit your Personal Data to another controller (only applicable when our processing is based on your consent and carried out by automated means).
  • Restriction: Restrict the processing of your Personal Data (when legally justified).
  • Withdraw Consent: Withdraw your previously provided consent to processing activities.
  • Lodge a Complaint: Exercise your rights by contacting us directly or, if necessary, file a complaint with a supervisory authority.

To exercise any of these rights, please contact us via the provided email address. You will not be charged for exercising your rights, and we have one month to respond to your request.

DATA SECURITY

We maintain strict controls over the Personal Data we collect. Our dedicated IT security team has implemented appropriate physical, technical, and organizational measures to safeguard your information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, access, and other unlawful forms of processing.

DATA RETENTION

We retain your Personal Data only for as long as necessary to provide you with our Services or as long as we have another legitimate basis for doing so, but not longer than permitted or required by law.

When determining the appropriate retention period, we consider factors such as the quantity, nature, and sensitivity of the Personal Data, the purposes for which we process it, and any legal requirements mandating specific retention periods.

COOKIE NOTICE

Cookies are snippets of data that can be installed on Your internet web browser when You visit the Website. We use some types of cookies, but we are not interested in identifying You as an individual with the data from cookies. We use the following cookies:

Name of Cookie Type of Cookie Storage period Purpose of use
PHPSESSID Functionality Cookie Session This Cookie helps to provide functions across pages.
_csrf Security Cookie Session This Cookie helps to protect the Website against attacks.

COUNTRY-SPECIFIC PROVISION

For Users in the European Economic Area (EEA):

If you reside in EEA countries, you can exercise your rights as outlined in the European Union's General Data Protection Regulation (GDPR) by contacting us at the provided email address: [email protected].

CHILDREN'S DATA

We work globally and provide our Services to Customers which operate in different sectors and industries (gaming, gambling, e-commerce, etc.). We acknowledge that there may be some legal restrictions on the age of End users that have the right to log in to and use our Customers’ website and/or mobile app.

We inform You that our Customers that provide You with their services or products are primarily responsible for compliance with these legal requirements. However, if You are a parent or other holder of parental responsibility and believe that we process personal data of a child unlawfully, please contact us. We will try to understand Your issue and make our best efforts to protect the rights of a child.

LINKS TO OTHER WEBSITES

Our Website may contain links to other websites, such as social media platforms, that have different privacy practices than ours. If you access any of these websites through the provided links and/or submit your Personal Data to them, your information will be processed according to their established procedures and governed by their respective privacy policies. We encourage you to carefully review the Privacy Notice or similar privacy notice of any website you visit.

HOW TO COMPLAIN

If you wish to file a complaint, please contact our designated privacy contact using the contact information provided in this Privacy Notice. We kindly ask that you provide us with as much information as possible regarding your complaint to assist us in comprehensively understanding and investigating the matter.

If you are unsatisfied with our response or feel that your complaint has not been adequately resolved, you have the right to lodge a complaint with the appropriate data protection authority. This is especially applicable in the country where you usually reside, work, or where you believe a violation has occurred

UPDATES TO THE PRIVACY NOTICE

We continuously develop our Services and Websites, introducing new features or making modifications. Therefore, there may be occasions when we need to amend the Privacy Notice. If such amendments significantly affect the processing of your Personal Data, we will inform you of the changes in advance through reasonable means (e.g., notifications via applications, our Websites, or email). The date of the last update will always be indicated. Unless stated otherwise by us, each updated Privacy Notice becomes effective when it is published on this Website. It is recommended that you regularly review this Privacy Notice to stay informed of any changes. Your continued use of the Services and Websites will be considered as acceptance of the updated Privacy Notice.

ADDITIONAL TERMS

Data Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

Data Processor means the natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller and according to its instructions.

European Economic Area (EEA) means the member states of the European Union and three additional countries, namely Iceland, Liechtenstein, and Norway.

Personal Data means any information that directly, indirectly, or in connection with other information allows for the identification of a natural person.

Services means services provided by us as described in the relative Terms and Conditions of the Website.