Privacy policy
Last updated: 05/01/2021
This privacy policy informs about the purpose, scope and timing of data processing, as well as the rights of the data subject ("User") arising from the use of the website https://turboenot.com/ ("Website") and using its services.

We are committed to protect your privacy and personal data and therefore we process personal data of Users in accordance with applicable law - Regulation (EU) 2016/679 Of The European Parliament And Of The Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) ("Regulation"), as well as legal acts governing data processing and the right to privacy.

1. Data Controller and contact information

The controller of personal data is a performer of commercial activities Elena Kolesnikova (reg.No.18078018004), Latvia, Pinki, Sparu iela 17, LV-2107 ("we, us" and "Elena Kolesnikova"). Complaints or questions about the processing of personal data can be directed to our data protection specialist at: Elena.turboenot@gmail.com.

2. Personal data categories

The categories of personal data that Elena Kolesnikova collects and processes are:

1) All users:

• IP address.

2) Users sending request for a game:

• identification data - name, surname, age;
• contact information - e-mail, phone;
• country;
• other data collected from the event registration form.
• IP address.

3) Users participating in a game:

• identification data - name, surname, age;
• contact information - e-mail, phone;
• country;
• other data collected from the event registration form;
• video record of a game the user participated;
• IP address.

3. How we store and process your data?

Your data is processed for the following purposes:

• Application for games, events, activities;
• Information provision and answers to your questions;
• Provision of services for which you have agreed;
• Anonymous statistics on the use of the Website;
• Maintenance and improvement of the Website;
• Marketing communications;
• Examination of complaints, suggestions and questions.

We process User's data using the latest technological solutions, assess the risks of confidentiality and use our organizational, financial and technical resources, which are necessary to ensure the security of processing personal data in accordance with the principles set forth in the Regulation.

The data is used only by the employees and contractors of Elena Kolesnikova for the purposes indicated above.

Received personal data is stored using a reliable cloud and server solution that provides data processing in the EU and EEA or in compliance with the Regulation. When changing providers of such services, we guarantee that we always cooperate only with trusted partners who ensure compliance with the requirements of the Regulation.

4. Data processing legal basis

Elena Kolesnikova processes personal data only on the basis of the following legal grounds:

a) User has given consent to the processing of his personal data for one or more specific purposes;

b) processing is necessary for the performance of a contract to which the User is party or in order to take steps at the request of the User prior to entering into a contract;

c) processing is necessary for compliance with a legal obligation to which Elena Kolesnikova is subject;

d) processing is necessary in order to protect the vital interests of User or of another natural person;

e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Elena Kolesnikova;

f) processing is necessary for the purposes of the legitimate interests pursued by Elena Kolesnikova or by a third party.

5. Data storage term

We store the received personal data until:

• Data is necessary for the purpose for which it was obtained;
• The User or Elena Kolesnikova can exercise their legitimate interests in the manner prescribed by regulatory enactments (to file objections or to initiate legal proceedings);
• There is a legal obligation to store personal data;
• User's consent to the corresponding processing of personal data is valid, unless there is another legal basis for the processing.

6. Term of storage of personal data

Elena Kolesnikova stores personal data of Users that sent requests for a game and Users participated in a game for 2 years. At the end of this period, Elena Kolesnikova deletes from e-mails and systems all personal data and documents containing them, as well as electronic correspondence, and destroys all printed documents.

7. Processing of data of persons who applied for news and communications

Type of personal data: name and/or surname, e-mail, phone;
Purpose of data processing: Elena Kolesnikova newsletters;
Legal basis for the processing of personal data: consent;
Personal data processing term: permanently until the person withdraws his / her consent or unsubscribes from newsletters.

8. Rules for the processing of personal data of participants in games

1) Type of personal data: name and/or surname, age, e-mail, phone, country;
Purpose of data processing: registration for game, reminder about the game, feedback after the game;
Legal basis for the processing of personal data: legitimate interests; Personal data processing term: 2 years.

2) Type of personal data: name and/or surname, e-mail;
Purpose of data processing: Elena Kolesnikova newsletters;
Legal basis for the processing of personal data: consent;
Personal data processing term: permanently until the person withdraws his / her consent or unsubscribes from newsletters.

3) Type of personal data: photo and video recordings;
Purpose of data processing: analysis of conflict situations that occurred during the game, feedback after the game;
Legal basis for the processing of personal data: consent;
Personal data processing term: until the last day of all games paid by the User plus one month.

9. Data transfer to third parties

We do not disclose User's personal data to third parties, except:

• according to the clear and undeniable consent of User;
• to persons provided for by regulatory enactments in the manner and amount established therein;
• in cases provided for by regulatory enactments for the protection of legitimate interests.

Services which presume processing of User's personal data by third parties in the course of service provision:

- Hosting and website support services. Data: User IP address, e-mail, name. The service provider has the possibility to access all data of users, but without Elena Kolesnikova request, personal data is not accessed. Transfer of data to third countries (Yes).
- Newsletter services. Data: e-mail, name. Transfer of data to third countries (Yes).
- Online Games with Users and recordings of online games. In accordance with ZOOM privacy policy: https://zoom.us/privacy. Transfer of data to third countries (Yes).

10. How can you access your data, check the accuracy and correct it?

You have the right at any time to request information about your personal data in order to verify the accuracy of the stored data and / or to correct or update this data. You can also ask to completely delete your personal data if it is not needed for further processing.

We will make commercially reasonable efforts to provide you with reasonable access to any of your personal data we maintain within 1 month as of receipt of your access request.

In order to ensure your safety and privacy protection, we will take appropriate measures to verify your identity before disclosing information about the personal data you request.

11. COOKIE

"Cookie" is a small piece of data sent by the web server and stored on the user's computer. The web client (usually a web browser) each time you try to open the page of the corresponding site sends this piece of data to the web server as part of the HTTP request. More information on how cookies work is available at www.cookiecentral.com.

12. How we use cookie?

Our Website uses cookies to improve the quality of our services, as well as to prepare anonymous analytics and statistics on the use of the Website for marketing purposes. We use the necessary cookies, session cookie and analytics cookies (cookies of the first and third parties (partners)) in order to:

• maintain and manage the security of the Website;
• remember whether you have consented to the use of cookies on our Website;
• measure the effectiveness of a marketing campaign;
• summarize information on the use of the Website, which allows us to evaluate how well the Website meets the needs of Users, and make the necessary improvements;
• analyze which pages of the Website you are visiting.

Some cookies may be placed by third parties, a service provider that performs certain functions for us (for example, Facebook, Google, Yandex, Mailchimp).

13. Personal data transfer

The cookie information is not used for your personal identification. Cookies are not used for any purpose other than those described here.

We may share your information with third parties who provide us with website analytics or customer service services. These persons have the right to use your data only to the extent that it is necessary to provide us with these services.

We transfer your data to third parties only in the manner described in this Privacy Policy. We do not sell your data to third parties.

14. How to control cookie?

You can control and manage cookies in your browser settings. You can delete or block all cookies that are already on your computer, but if you do so, some functions of this Website may not work as intended, and you may need to manually configure individual settings each time you visit the Website.

When User does not accept cookies for Elena Kolesnikova marketing and analytics purposes, we do not process this information, although inform you that we also use cookies that do not require user consent. You can find a list of these cookies here: https://wikis.ec.europa.eu/display/WEBGUIDE/04.+Co...

15. Questions, applications and complaints

Users can send their questions about general data protection issues or the processing of their personal data to the Elena Kolesnikova Data Protection Officer at: Elena.turboenot@gmail.com

Elena Kolesnikova will, without undue delay and in any event within 1 month after receipt of the User's request, inform you of the action taken upon the request in accordance with the requirements of law. If necessary, this period may be extended by a further two months, taking into account the complexity and the number of requests.

16. Data State Inspectorate

If you believe that Elena Kolesnikova is violating your statutory rights, you can lodge a complaint with the Data State Inspectorate (Datu valsts inspekcija) to: 14 Blaumaņa str., Riga, te.No. 67223131, email: info@dvi.gov.lv.















































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