Privacy and Cookie Policy

At HW GAMING SOLUTION LTD, October 28, 261, VIEW POINT TOWER, 3035, Limassol, Cyprus, (hereinafter: “HW GAMING SOLUTION”, “we”, “company” or “controller”) we take your (hereinafter: "you”, “individual”, “user” or “data subject”) privacy seriously. The purpose of this Privacy and Cookie Policy is for you to better understand how we collect and use your personal information. 

This Privacy and Cookie Policy governs your use of www.my-valkyrie.com (“the Website”) and by using the Website you specifically consent to the collection, use and disclosure of your information (including personal information) in accordance with this Privacy and Cookie Policy. As described below, we share your information (including personal information) with our affiliates and with third-party partners (as defined below) and use it in ways consistent with this Privacy and Cookie Policy. We may also use your information (including personal information) together with other information to provide and improve products, services and content. 

DEFINITIONS 

Our Privacy and Cookie Policy is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016h (hereinafter: GDPR)), the Council of Europe Conventions and terms used in national legislation. Our Privacy and Cookie Policy should be legible and understandable for the general public, as well as our affiliates and third-party partners. To ensure this, we would like to begin by explaining the used terminology.

Personal information means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 

Data subject is any identified or identifiable natural person, whose personal information is processed by the controller responsible for the processing. 

Processing is any operation or set of operations which is performed on personal information or on sets of personal information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. 

Restriction of processing is the marking of stored personal information with the aim of limiting their processing in the future. 

Profiling means any form of automated processing of personal information consisting of the use of personal information to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. 

Automated decision making is when a decision is made which is based solely on a automated processing (including profiling) which produces legal effects or significantly affects individual. 

Pseudonymization is the processing of personal information in such a manner that the personal information can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal information are not attributed to an identified or identifiable natural person. 

Controller or controller responsible for the processing is 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 information; where the purposes and means of such processing are determined by Union law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law. 

Processor is a natural or legal person, public authority, agency or other body which processes personal information on behalf of the controller. 

Recipient is a natural or legal person, public authority, agency or another body, to which the personal information are disclosed, whether a third party or not. However, public authorities which may receive personal information in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those information by those public authorities shall be in compliance with the applicable information protection rules according to the purposes of the processing.

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal information.

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal information relating to him or her.

NAME AND ADDRESS OF THE CONTROLLER 

Controller for the purposes of the GDPR, other data protection laws applicable in Member states of the European Union and other provisions related to data protection is: 

HW GAMING SOLUTION LTD

October 28, 261, VIEW POINT TOWER, 3035, Limassol, Cyprus

Registration Nr.: ΗΕ 436806

VAT Nr.: CY 10436806Q

e-mail address: info@my-valkyrie.com.

DATA PROTECTION OFFICER

We do not have Data Protection Officer as we do not process personal data to such an extent that this obligation should be fulfilled, but you can always contact us by e-mail: info@my-valkyrie.com.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We process and collect personal information if you provide it to us or we collect it from your visit to the Website when:

• you use or visit our Website, we collect the information through cookies,

• you subscribe to our newsletter,

• you register for contests and collecting prizes,

• you purchase products on our webshop,

• you contact us through various channels (including social media).

Information we collect from you:

1. Website usage information

By visiting our Website, we collect the following information: 

• technical information that we collect automatically when you use our Website, including device data or other log data. We collect information such as web requests, data sent in response to such requests, browser type, browser language, IP address, timestamp for the request, and other anonymous statistics relating to the use of our Website. This information cannot be used by itself to identify or contact you. We may automatically combine the personal information we collect with other, non-personal information. In this case, we will treat the combined information as personal information in accordance with this Privacy and Cookie Policy. We obtain this information through the use of cookies and other technologies (see below for more information in the Cookie and tracking technology section).

The legal basis for the processing of personal information referred to in the preceding paragraph is our legitimate interest (Article 6(1)(f) GDPR) or your consent (Article 6(1)(a) GDPR).

Until you provide us with personal information (such as your name, e-mail address, etc.), any information we automatically collect when you use the Website is anonymous information and we cannot and do not identify you.

2. Personal Information 

When you request information using the Websites or contact us directly, we may collect personally identifiable information about you that you provide us such as:

• your name and surname, 

• email address,

• home address,

• phone number,

• company name, which enables identification of individual.

In case you subscribe for marketing e-mails, we will collect your information that you submit in the sign-up forms, such as your e-mail address and your marketing preferences.

We collect personal information if you explicitly provide it, on legal basis of your consent (point a of the first paragraph of Article 6 of the GDPR), if we have concluded a contract or if we carry out measures at your request prior to the conclusion of the contract (point b of the first paragraph of Article 6 of the GDPR), on the basis of the law (point c of the first paragraph of Article 6 of the GDPR), or if there is a legitimate interest for us to do so (point f of the first paragraph of Article 6 of the GDPR).

If you wish to delete your personal information that we received from you, please send an e-mail to info@my-valkyrie.com and your personal information will be deleted from our database.

Legal basis and purposes for processing personal information

We process personal information only for the purposes for which it was collected and in accordance with this Privacy and Cookie Policy. We take reasonable steps to ensure that the personal information we process is accurate, complete and current, but we depend on you to update or correct your personal information when necessary.

We are not responsible for the accuracy of the personal information you enter.

1. CONSENT

We process personal information on the basis of the consent of the individuals concerned, such as for the following purposes:

• When you register on our webshop and become registered user

During the process of purchasing the products listed on our webshop, you can register and become our registered user. To become our registered user, you must provide personal data such as: name, surname, email and password. 

• When you purchase product from our webshop as a registered user or guest 

During the purchase process in our webshop, we will need your personal data for fulfilling the order, such as: name, surname, address, email, phone number. 

• When you register for our contests and collecting prizes, or for promotional codes 

From time to time, we may conduct an online contest and collect classical personal information, demographic information and other materials that you voluntarily submit to us for the purposes of prize collection. Participating in an online contest is completely voluntary. We may use your information gathered via contests for the purposes of performing the contest and to contact you as per such contest's terms and conditions.

• marketing e-mails (subscription to our newsletter, card abandonment e-mails)

From time to time, we offer marketing e-mails. If you have given us consent for marketing e-mails, we will use your personal information for marketing analysis and to provide you with promotional update communications by e-mail about topics such as our products, news and blogs, media, and partner updates signing up to our newsletter. 

If you have subscribed to marketing e-mails, you can object to further marketing at any time by selecting the "unsubscribe" URL at the end of all our marketing and promotional update communications to you, or by sending an email to  info@my-valkyrie.com.

2. LEGITIMATE INTEREST

Where circumstances require us to do so, we may process your personal data on the basis of a legitimate interest pursued by us, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal information, for example for the following purposes:

• Website optimisation,

• answering questions, you send us through various channels (including social media),

• ensuring the security of IT systems,

• to improve the provision of goods by contacting you for the purpose of ascertaining satisfaction with our goods, 

• to prevent abuse and/or fraud,

• marketing e-mails: from time to time, we offer marketing emails. If you have given us consent for marketing emails, we will use your personal information for marketing analysis and to provide you with promotional update communications by email about topics such as our products and services, news and blogs, media, and partner updates,

• card-abandonment emails: uder GDPR we have legitimate interest to remind you via email about items you might have left as unpurchased in your cart during ordering process. You can anytime unsubscribe from such emails, if you don’t wish to receive them, through the link included in email. 

3. LEGAL OBLIGATION

We process personal information on the basis of the law and in accordance with the relevant legislation:

• in connection with your order for lawful purposes (tax legislation, accounting regulations, etc.).

TRANSFER OF YOUR PERSONAL INFORMATION TO THIRD PARTIES (USERS OF PERSONAL INFORMAITON) AND TO THIRD COUNTRIES

We may share your personal information with third parties only as set out in this Privacy and Cookie Policy, and certain personal information is transferred to the US based on standard contractual clauses included in the personal information processing agreements we enter into with business partners.

We may share it with: 

• our business partners and contractors who provide services on our behalf or who we use to support our business. All of these third parties comply with the requirements set out in our Privacy and Cookie Policy and we have entered into appropriate personal information processing agreements with them. We will disclose your personal information if necessary to fulfil our obligations to you and to the minimum extent necessary (e.g. e-mail notification providers, security solutions providers),

• we may share your personal information with those third parties for whom you have given your consent,

• we may report to law enforcement agencies any activities that we reasonably believe to be unlawful, or that we reasonably believe may aid a law enforcement investigation into unlawful activity. In addition, we reserve the right to release your personal information to law enforcement agencies if we determine, in our sole judgment, that either you have violated our policies, or the release of your personal information may protect the rights, property, or safety of the company or another person. We will disclose personal information that that law enforcement agencies require in particular case to be disclosed,

• we may disclose your personal information to comply with a law, regulation or compulsory legal request, to protect the safety of any person from death or serious bodily injury, prevent fraud or misuse of products or services or its users or to protect our property rights. We will disclose personal information to government entities, or third parties based on judgments of courts or tribunals or decisions of administrative authorities or another binding act. We will disclose personal information that previously mentioned entities require in particular case to be disclosed.

We do not transfer the personal information we collect to other third parties or to third countries without an adequate level of protection. Your personal information may be transferred to the United States (within the framework of a web analytics and e-mail notification service provider), and we will enter into appropriate contracts with any contract processors in the United States.

CHILDREN’S PRIVACY

We are committed to protecting the online privacy of children and making the internet safe. We do not provide products or services to children, or knowingly collect or solicit personal information from children under 15 years of age. Any communication we get that is identified as being from a child under 15 will not be kept by us. We encourage parents or guardians of children under 15 to regularly check and monitor their children’s use of e-mail and other activities online.

We use all available technology and make every effort to verify that the person with parental responsibility for the child has given or approved consent.

AUTOMATED DECISION MAKING AND PROFILING 

On the basis of individual’s explicit voluntary consent, we process personal information for automated decision making and profiling. Automated decision making refers to a decision which is taken solely on the basis of automated processing of your personal information. This means processing using, for example, software code or an algorithm, which does not require human intervention. As profiling uses automated processing, it is sometimes connected with automated decision making. Not all profiling results in automated decision making, but it can do. We only collect the minimum amount of data needed and we have a clear retention policy for profiles we create. We have additional checks in place for our profiling/automated decision-making system to protect any vulnerable groups (including children). If a decision is to be solely based on automated processing (including profiling), then we will inform you of your right to object and about the logic involved in automated decision making or profiling, the significance and envisaged consequences. You will have the right to request human intervention and express your point of view or challenge the decision. Suitable measures will be put in place to safeguard your rights and freedoms and legitimate interest.

SECURITY OF YOUR PERSONAL INFORMATION

We take appropriate technical and organizational measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy and Cookie Policy. We restrict access to personal information to our employees and business partners who need to know such information in order to operate, develop or improve our product or services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security. We are not responsible for the functionality, privacy or security measures of any other organization.

Note that we offer links to other Website or platforms not owned or operated by us. Your use of these third-party services is entirely optional and at you risk. We are not responsible for the privacy policies and/or practices of these third-party services.

LINKS TO OTHER WEBSITES

Our Website may contain links to third party Websites. These sites have their own privacy policies, which you should read for yourself as we accept no responsibility for them. 

1. Links to social media 

Our Website contains links to social networks (social plugins) which we have integrated links to them to redirect you to these social networks when you click on their icons. The processing of personal information obtained by the social networks when you click on a social network plug-in and are redirected to a social network is carried out by the aforementioned social networks and in accordance with their privacy policies, which can be found at:

• Facebook: processing of personal information is carried out by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA; the data protection declaration is available at https://www.facebook.com/policy.php,

• Instagram: processing of personal information is carried out by Instagram LLC, 1601 Willow Rd, Menlo Park, CA 94025, USA; the data protection declaration is available at: https://help.instagram.com/155833707900388,  

• Twitter: processing of personal information is carried out by Twitter International Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 IRELAND; a data protection declaration is available at: https://twitter.com/en/privacy, 

• LinkedIn: processing of personal information is carried out by LinkedIn Corporation, 1000 West Maude Avenue Sunnyvale, CA 94085, USA; the privacy statement is available at: https://www.linkedin.com/legal/privacy-policy,

• TikTok: processing of personal information is carried out by TikTok Information Technologies Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland; the privacy statement is available at https://www.tiktok.com/legal/page/eea/privacy-policy/en. 

2. Links to other platforms

• Squarespace: processing of personal information is carried out by Squarespace Ireland Limited, Squarespace House, Ship Street Great, Dublin 8, D08N12C, Ireland; the privacy statement is available at https://www.squarespace.com/privacy.  

• Stripe: we use Stripe platform payment of your purchase. You can review Stripe’s privacy policy about processing of your personal data here: https://stripe.com/en-si/privacy. 

DATA RETENTION

We store your personal information for as long as is needed for its purpose. We may store anonymized information longer, but only in a way that it cannot be tracked back to you. We store personal information in accordance with applicable law.

Retention for personal information may vary depending on the applicable sectoral legislation (eg. tax, accounting legislation). In the case where the applicable sectoral legislation establishes mandatory duration for retention of personal information, we will delete if after the expiration of that mandatory duration.

When personal information is no longer needed, we shall delete it using reasonable measures to protect the personal data from unauthorized access or use.

UPDATE OR REMOVAL YOUR PERSONAL INFORMATION OR OPT-OUT

You can update or remove your personal information at any time.

• Updates: If you still wish to use our products or services and your relevant personal information changes, please let us know at info@my-valkyrie.com,

• Removal: If you decide to remove your personal information, we will completely remove your data from our collections.

Any request that you send to info@my-valkyrie.com may take up to 10 days to process and become effective.

After receiving your withdrawal of consent, we will stop processing your personal information and will delete it. We will let you know that your withdrawal was took into account.

YOUR RIGHTS 

In relation to your personal information that we process, you have the right:

• to withdraw consent to processing of your personal information at any time. If you only wish to update your personal information, you can do that by contacting us at info@my-valkyrie.com,

• to obtain confirmation whether we process your personal information,

• to access: to request confirmation whether we process your personal information relating to you, and if so, to request a copy of that personal information, to ask about purposes of processing, categories of personal information concerned, whether personal information is transferred to a third country or international organization etc.,

• to rectification: to request that we rectify or update any personal information that is inaccurate, incomplete or outdated,

• to erasure (Right to be forgotten): to request that we erase your personal information in certain circumstances, such as when the processing of personal information is no longer necessary in relation to the purposes for which it was collected or otherwise processed or where we collected personal information on the basis of your consent and you withdraw your consent etc.,

• of restriction of processing: to request that we restrict the use of your personal information in certain circumstances, such as when accuracy of the personal information is contested by you;

• to data portability: to request that we provide a copy of your personal information to you in structured, commonly used and machine-readable format in certain circumstances and you have the right to transmit that personal information to another controller in certain circumstances,

• to object at any time to processing of personal information for our legitimate interest, to direct marketing and profiling connected with direct marketing,

• to state that the decision based solely on the automated processing of your personal information, including the creating of profiles, that has legal effects relating to you or significantly affects you in a similar way, does not apply to you.  If the decision (1) is necessary for entering into, or the performance of, a contract between the you and the company or (2) it is based on your explicit consent, we shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the company, to express his or her point of view and contest the decision,

• to appeal, independent of the above stated rights, to a supervisory authority if you believe that processing of your personal information violates the data protection regulations. You may file a complaint to the competent state authority: Commissioner for Personal Data Protection, Iasonos 1, 1082 Nicosia, P. O. Box 23378, 1682 Nicosia, Cyprus, telephone number: +357 22818456, website: commissioner@dataprotection.gov.cy. 

For all stated rights, you may, at any time, contact us at info@my-valkyrie.com.

We shall promptly ensure that the request is complied with immediately, but no later than in 1 month. You will receive requested personal information in a structured, machine-readable and generally applicable way. First copy of your personal information in electronic or hard is free of charge, each additional copy we may charge a fee to cover cost of preparing the copy. 

COOKIES AND TRACKING TECHNOLOGY

This Cookie Policy provides you with detailed information about how and when we use cookies. A cookie is a small file, typically of letters and numbers, downloaded onto a device when the user accesses certain websites.  

Cookies are used to keep track of your movements within the website, help you resume where you left off, remember your registered login, preferences and other users’ functions. You can modify your browser settings to control whether your computer accepts or declines cookies. If you choose to decline cookies, you may not be able to use certain interactive features on our Website. Note that you can always go back and delete cookies from your browser; however, that means that any settings or preferences controlled by those cookies will also be deleted and you may need to recreate them. 

The law states that we can store cookies on your device if they are strictly necessary for the operation of the Website (strictly necessary cookies). Without these strictly necessary cookies, essential features like the display of this Website, cannot be provided. For all other types of cookies (unnecessary cookies; e.g. analytics cookies), we need your prior informed consent.

Below is a list of cookies that we use. We have listed them so that you can choose if you want to opt-out of cookies or not.

This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages.

You can at any time change or withdraw your consent from the Cookie Declaration on our website.

Learn more about who we are, how you can contact us and how we process personal data in our Privacy Policy.

Please state your consent ID and date when you contact us regarding your consent.

Your consent applies to the following domains: www.my-valkyrie.com.