Privacy Policy

Introduction

The security and proper use of personal data are of the utmost importance to us.

This Privacy Policy is an integral part of the General Terms and Conditions available at: https://mgames.bg/terms-of-use/. It does not regulate rights and obligations, but is intended to explain to users what personal data we process in connection with the provision of goods, why and how we process it, including when it is necessary to disclose personal data to third parties. It also provides information about the rights users have regarding the processing of personal data by “MORADIANI GAMES” EOOD.

For greater clarity and for the convenience of users, many sections of this Privacy Policy include examples that illustrate why and/or how “MORADIANI GAMES” EOOD processes users’ personal data. These examples are not part of this Privacy Policy and are not exhaustive.

Basic Principles for the Processing of Personal Data

We process personal data lawfully, in good faith, and in a transparent manner with respect to the data subject (“lawfulness, good faith, and transparency”);

We process personal data only for specific, explicitly stated, and legitimate purposes, and do not further process it in a manner incompatible with those purposes (“purpose limitation”);

The personal data being processed is appropriate, relevant, and limited to what is necessary in relation to the purposes for which it is processed (“data minimization”);

The personal data we process may be kept up to date at all times, as we take all reasonable measures to ensure that inaccurate personal data is deleted or corrected in a timely manner, taking into account the purposes for which it is processed (“accuracy”).

The personal data we process is stored in a form that allows for the identification of the data subject for a period no longer than is necessary for the purposes for which the personal data is processed (“storage limitation”);

The personal data we process is stored in a manner that ensures an appropriate level of security for the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, by implementing appropriate technical or organizational measures (“integrity and confidentiality”);

Data Controller

The personal data controller is “MORADIANI GAMES” EOOD, with UIC 208654580, with its registered office and address of management in Sofia 1000, 9 Slaveykov Square, Bezisten, Center, Sofia (“MORADIANI Games”).

If you have any questions regarding privacy at “MORADIANI GAMES” LLC or would like to contact us regarding a matter related to personal data protection, please contact our Data Protection Officer at the following email address: e-mail:mouradianigames@gmail.com

This Privacy Policy may be amended in accordance with national and European legislation. Any changes take effect upon publication on this page. We recommend that you check our website frequently to see the latest updates. Our Privacy Policy will not be amended in a way that would result in weaker protection of our customers’ and users’ personal data without their consent.

What Personal Data Do We Process?

We collect your personal data so that we can provide our products and services and continuously improve them.

Here are the types of information we collect:

Information You Provide to Us: We receive and store any information you provide in connection with Moradiani Games’ services.

For example: information related to searches on the platform, orders you have placed, email address, phone number, address, inquiries, requests for access to personal information, etc.

Automatic Information: We automatically collect and store certain types of information when you use the Moradiani Games EOOD website

For example: information about your use of the website, including your interaction with the content and services available through the website.

Like many websites, we use “cookies” and other unique identifiers and collect certain types of information when your web browser or device accesses the site.

For example: the Internet Protocol (IP) address used to connect your computer or other device to the Internet; information about your computer, device, and connection, such as device type and application version or browser type, browser plug-in types and versions, operating system, or time zone settings; the location of your device or computer; information about your interaction with content, such as content downloads, streams and playback details, including duration and the number of concurrent streams and downloads, as well as network data regarding streaming and download quality, including information about your internet service provider; connectivity data and any errors or failed events; website metrics (technical errors, your interactions with the service’s features and content, settings preferences, and backup information, etc.)

We may also use device identifiers, “cookies,” and other technologies on devices, apps, and websites to collect browsing, usage, or other technical information for the purpose of fraud prevention.

Information from other sources: We may receive information about you from other sources:

For example: information regarding the delivery of goods purchased through the website, information on the number of page views.

What are “cookies”?

In order to provide our services and successfully deliver to you each of the products offered on the website, we use “cookies.” For more information about cookies and how we use them, please read our Cookie Policy.

On what basis do we collect and process your personal data?

We collect and process your personal data in accordance with the law and in compliance with this Policy and the General Terms and Conditions. We process data when you have given your explicit consent to the processing of personal data, or when processing is necessary for the performance of a contract to which you are a party, or to take steps at your initiative prior to entering into a contract (such as simply using the website without having to place an order). Data processing is also necessary for the purposes of our legitimate interests, namely: when, without processing certain types of data, we would be unable to provide our services and enter into a contract for the sale of any of the products on the website, improve the website and our customer service, and deliver value to our users.

For example, collecting information about searches on the website, its use, and the analysis of this data is in our legitimate interest, because it is a key method for determining the quality of our services and products and a means of improving them.

Given the above grounds for the collection and processing of personal data, if you decide that you do not wish to provide Moradiani Games with the personal data necessary to conclude a Sales Contract, Moradiani Games will be unable to provide you with the goods available on the website.

Purposes of Personal Data Processing

We process your personal data in order to provide and improve the products and services on the website. These purposes include:

Purchase and delivery of products and services. We use your personal information to process and fulfill orders, deliver products and services, process payments, and communicate with you regarding orders, products, and services, and in certain cases, with your express consent, to send you promotional offers, newsletters, news, etc.

Providing, troubleshooting, and improving Moradiani Games’ services. In certain cases, we may use your personal data to provide functionality, analyze performance, correct errors, and improve the usability and effectiveness of the website.

Recommendations and Personalization. We use your personal data to recommend features, products, and services that may be of interest to you, to identify your preferences, and to personalize your experience on the site.

Compliance with legal obligations. In some cases, we are legally required to collect and process your personal data.

For example: We process personal data to fulfill obligations arising from accounting and tax laws.

To facilitate communication. We use your personal data to communicate with you regarding the goods and services we provide through various channels (e.g., by phone and email).

Preventing Fraud and Credit Risks. We process personal information to prevent and detect fraud and abuse in order to protect the security of our customers.

Purposes for Which We Seek Your Consent. We may also ask for your consent to process your personal data for a specific purpose, which we will disclose to you. When you consent to our processing of your personal information for a specific purpose, you may withdraw your consent at any time, and we will cease processing it. However, this does not apply if the processing is necessary for another lawful purpose.

Categories of individuals to whom we disclose users’ personal data

Our customers’ information is an important part of our business, and we do not sell it to third parties. Moradiani Games may share its customers’ personal information (or part thereof) only as described below and with third parties that adhere to practices that are at least as protective as those described in this Privacy Policy.

Moradiani Games may share its customers’ personal information with third parties that act as data processors. Data processors are entities that process personal data on behalf of and as instructed by Moradiani Games based on a written agreement. They are not permitted to process the personal data provided to them for purposes other than the performance of the work assigned to them by Moradiani Games. Data processors are required to comply with all instructions from Moradiani Games.

Moradiani Games takes the necessary measures to ensure that its contracted processors strictly comply with data protection laws and Moradiani Games’ instructions, as well as that they have implemented appropriate technical and organizational measures to protect personal data.

Examples of entities that process personal data include:

Courier service providers;
Providers of information system implementation and/or maintenance services, who may occasionally need to access personal data processed in the relevant systems for the purpose of providing their services;
Hosting service providers
Moradiani Games may share personal information with clients, law firms, accounting firms, or other consulting service providers when necessary to conduct Moradiani Games’ business, in the event of a dispute, or for optimization purposes;

Moradiani Games may share its customers’ personal information with banks and payment institutions. In connection with the processing of customer payments made via bank transfer or through a payment institution, it is necessary to exchange data between Moradiani Games and the relevant bank or payment institution.

Third parties in connection with a reorganization (e.g., a merger or consolidation) or a transfer of a business. In the event of a reorganization of Moradiani Games, as well as in the event of a transfer of assets in accordance with applicable law, it is possible that the personal data of users, administered by Moradiani Games may be provided to a third party—the successor entity.

Competent Authorities. The laws of the Republic of Bulgaria require Moradiani Games to retain certain personal data about users for a specified period of time. Where the conditions established by law are met, this personal data processed by Moradiani Games must be provided to the competent authorities.

What measures do we take to protect your personal information?

We work hard to protect the security of your information during transmission by using a Secure Sockets Layer (SSL) certificate, which encrypts the information you enter.

In addition to the above, we maintain physical, technical, and procedural safeguards regarding the collection, storage, and disclosure of your personal data. Our security procedures mean that we may sometimes ask for proof of identity before disclosing personal information to you.

Devices on which your personal data is stored offer security features to protect it from unauthorized access and data loss.

It is important to protect yourself against unauthorized access to your computers and devices.

How long do we retain your personal data?

Moradiani Games retains users’ personal data for as long as necessary to achieve the purposes set forth in this Privacy Policy or to comply with legal requirements.

For example: In order to comply with our obligations under tax and accounting laws, purchase data is retained for a period of 11 years.

Once the time limits for processing personal data have expired, such data is anonymized or deleted/destroyed, unless:

are necessary for pending judicial, arbitration, administrative, or enforcement proceedings, or in the event of a complaint filed by the relevant user that must be reviewed by Moradiani Games; or
the relevant user has exercised their right to request restriction of the processing of personal data concerning them;
Moradiani Games makes every effort to ensure that the personal data processed for users is kept up to date (and corrected as necessary), and that no data is retained that is not necessary to achieve the purposes described above.

General Information on the Rights of Individuals

Moradiani Games will take action in response to a request from an individual to exercise a right under this section only if it is able to identify the individual in question.

Only individuals who can be identified by Moradiani Games are entitled to exercise their rights under this section. If the purposes for which Moradiani Games processes personal data do not require or no longer require the identification of a specific individual, Moradiani Games is under no obligation to maintain, obtain, or process additional information to identify the individual for the sole purpose of taking action based on that individual’s request.

Moradiani Games notifies individuals of the actions taken within one month of receiving a request under this section; in certain cases, this period may be extended by up to two additional months.

Moradiani Games will provide individuals with information regarding the actions taken in response to their requests to exercise their rights under this section without undue delay and, in any event, within one month of receiving the request. If necessary, this period may be extended by an additional two months, taking into account the complexity and number of requests. Moradian Games shall inform the individual concerned of any such extension within one month of receiving the request, specifying the reasons for the delay.

If a request is denied, Moradiani Games notifies the individuals concerned of their rights.

If Moradiani Games does not act on a request from an individual, Moradiani Games shall notify the individual without delay, and no later than one month after receiving the request, of the reasons for not taking action, as well as of the possibility of filing a complaint with the Personal Data Protection Commission and seeking legal redress.

In certain cases, Moradiani Games may request additional information to verify the identity of individuals

If Moradiani Games has reasonable grounds for concern regarding the identity of the individual submitting a request under this section, Moradiani Games may request additional information necessary to verify the individual’s identity.

The actions taken by Moradiani Games in connection with requests to exercise rights under this section are provided free of charge to individuals, unless their requests are manifestly unfounded or excessive. When an individual’s request is manifestly unfounded or excessive (for example, due to its repetitive nature), Moradiani Games has the right, at its discretion: (a) to refuse to comply with the request; or (b) to require payment of a reasonable fee, determined based on the administrative costs necessary to provide the requested information or to take the requested actions.

Consumers have the right to:

Access to their personal data

Users have the right to request information from Moradiani Games regarding whether personal data related to them is being processed. If so, users have the right to access that data.

Correcting Inaccurate or Outdated Personal Data

If the personal data processed by Moradiani Games is inaccurate or out of date, users have the right to request that Moradiani Games correct it.

Deletion of My Personal Data (“Right to Be Forgotten”)

Users have the right to request that Moradiani Games delete their personal data in the following cases:
• the personal data is no longer necessary for the purposes for which it was collected or processed;
• the user has withdrawn the consent on which the processing of personal data is based, and there is no other legal basis for the processing of such data;
• the user has objected to the processing of personal data based on Moradiani Games’ legitimate interest, unless there are other legitimate grounds for the processing that override the user’s interests, the user’s rights and freedoms, or the processing is necessary for the establishment, exercise, or defense of legal claims;
• the user has objected to the processing of personal data for direct marketing purposes and there are no other legitimate grounds for processing such data;
• the personal data relating to the user in question has been processed unlawfully;
• the personal data must be erased by Moradiani Games in order to comply with a legal obligation under the law of the Republic of Bulgaria or the law of the European Union.

Restricting the Processing of My Personal Data

Users have the right to request that Moradiani Games restrict the processing of their personal data in the following cases:
• the accuracy of the personal data is contested by the user, for a period allowing Moradiani Games to verify the accuracy of the personal data;
• the processing is unlawful, but the user does not want the personal data to be erased and instead requests that its use be restricted;
• Moradiani Games no longer needs the personal data for the purposes of the processing, but the user requires it for the establishment, exercise, or defense of legal claims;
• The user has objected to the processing of personal data based on Moradiani Games’ legitimate interest, pending verification of whether Moradiani Games’ legitimate grounds override the user’s interests.

Portability of My Personal Data

Users have the right to receive from Moradiani Games the personal data they have provided, in a structured, commonly used, and machine-readable format, as well as to transfer that data to another controller without hindrance from Moradiani Games, provided that:
• Moradiani Games processes such data for the purposes of entering into or performing a contract with the user, or based on the user’s consent; and
• the processing of the relevant data is carried out by automated means.

Users have the right to request that Moradiani Games transfer their personal data directly to another controller, when this is technically feasible.

Objection to the Processing of Personal Data

Users have the right, at any time and on grounds related to their specific situation, to object to the processing of personal data concerning them when Moradiani Games processes their data to protect its legitimate interests.

In certain cases, this right is unconditional, and Moradiani Games will always cease processing data when users object.

For example, these are the cases in which Moradiani Games processes personal data for direct marketing purposes.

In all other cases, depending on the nature of the objection and the circumstances described by the user in question, Moradiani Games will conduct an internal review of the objection and rule on it in accordance with this section by: (a) notifying the user that it will cease processing his or her personal data; or (b) providing a reasoned refusal to cease processing his or her personal data, where there is a legal basis for doing so.

You can exercise your right to access, correct, delete, restrict the processing of, and transfer your personal data through our built-in GDPR module.

Right to File a Complaint with a Supervisory Authority

Users have the right to file complaints or reports with the Commission for Personal Data Protection (CPDP) if they believe that Moradiani Games is violating personal data protection laws. Instructions for filing complaints are published on the CPDP’s website at https://www.cpdp.bg

As of May 25, 2018, consumers may file complaints with other supervisory authorities within the European Union, as provided for in Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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), also known as the “GDPR”