This Privacy Policy (hereinafter referred to as "Policy") applies to the use of our website: https://aviatorgamedesign.com and defines the types of data collected during your visit to our Website and when engaging with our offerings. It also outlines how your personal data is processed and used.
1.1. "Administration" – the authorized owner of the Website represented by Aviator Game Design, who processes personal data on behalf of the Website and determines the purposes and means of processing personal data.
1.2. "Website" – the online platform located at https://aviatorgamedesign.com.
1.3. "Website User" (hereinafter "User") – an individual who has access to the Website through the internet or other networks and interacts with or uses the Website.
1.4. "Services" – products/services listed on the Website that can be purchased by Users.
1.5. "Order" – an offer made when the User (Customer) expresses intent to purchase a Service.
1.6. "Personal Data" – information or a set of data about a physical person who can be identified or identified through the data.
1.7. "Data" – a collection of confidential information and Personal Data, including authorization details, voluntarily provided by the User when using the Website, especially during registration.
1.8. "Subject of Personal Data" – an identified or identifiable physical person whose personal data is processed.
1.9. "Consent of the User" – the full, unconditional, voluntary, informed, and unambiguous acceptance of the terms of this Privacy Policy.
1.10. "Processing of Personal Data" – any action (operation) or set of actions (operations) with personal data performed using automation tools or without such tools, including collection, registration, storage, and modification.
1.11. "Cookies" – small text files stored on the user's computer, mobile device, or other devices to retain information.
1.12. "Partners" – any entities with contractual relationships with the Administration, who may be given limited access to the Website to provide services or distribute information.
1.13. "Data Confidentiality" – the requirement to prevent the dissemination of personal data without the consent of the data subject or without a legal or contractual basis.
1.14. "Third Party" – a physical or legal person, government agency, or authority, not part of the original data processing body, authorized to process personal data.
1.15. "Referral" – a third party whose hyperlink led the User to the Website for registration.
1.16. "Recipient" – an individual or entity authorized to access personal data, including public authorities, based on applicable laws.
We take all necessary measures to ensure the safety and confidentiality of your personal data, including advanced encryption techniques, secure communication channels, and compliance with data protection laws.
2.1. Data Processing is necessary for the purposes defined in this Privacy Policy, for the performance of a contract in which the data subject is a party or intends to become a party, to fulfill the legal obligations of the Administration, to protect the vital interests of the data subject, for the legitimate interests of the Administration or a third party, unless otherwise required by applicable law.
2.2. Data Collection The personal data of Users are processed by the Administration, registered under the laws of Bangladesh, with the location at: Aviator Game Design, Dhaka, Bangladesh.
2.3. Information Collection The Administration collects personal data in the manner and method defined by this Privacy Policy and applicable law, directly and/or indirectly.
2.4. Direct Collection refers to obtaining data that the User submits through the Website and/or during communication with the Administration via web inquiries (chat), email, phone, letters, social media, messengers, etc.
2.5. Indirect Collection refers to obtaining the User’s data from third parties, including business partners, subcontractors in technical, payment, and other services, or from publicly available external sources.
2.6. Data Processing and decisions based on the results of data processing may be carried out in automated and/or non-automated forms.
2.7. Data Ownership The Administration is the controller and owner of the personal data provided by the User.
2.8. Data Security User data is processed on secure servers.
2.9. Data Storage All personal data bases owned by the Administration are stored in data centers or at the Administration’s location.
2.10. Data Records The Administration keeps a record of the personal data it processes and is responsible for them.
2.11. Data Processing Delegation The Administration may delegate the processing of personal data to Operators. When delegating personal data processing powers to Operators, the Administration takes all necessary steps required by law.
2.12. User Consent Personal data will only be processed after the "Consent" of the User, the data subject, is obtained.
2.13. Acceptance of Privacy Policy This Privacy Policy and its attachments are considered accepted by the Data Subject without reservations or exceptions through voluntary, informed, and unambiguous action, such as placing an order or registering on the Website, thereby confirming acceptance of this Privacy Policy.
2.14. User Guarantee The User guarantees they have the necessary legal capacity and all the rights and powers necessary for entering into and fulfilling the terms of this Policy as a personal data processing agreement.
2.15. Voluntary Consent The User’s consent is voluntary and explicit.
2.16. Personal Data Verification The Administration reserves the right to verify the authenticity of the personal data provided by the User by requesting additional information or documents to confirm their identity and the provided data.
2.17. Identification of the Data Subject may include digital identification, for example, via authentication mechanisms such as matching credentials used to communicate with the Administration or access Services.
2.18. Blocked Access If the User’s personal data cannot be verified, the Administration may suspend, limit, or block access to the Website/Services.
2.19. Data Transfer When the User provides consent for their personal data processing within the Website/Services, this may also include the transfer of personal data to third parties, including outside the country, for the purpose of providing services or goods to the User.
2.20. Notification of Data Processing The User is deemed notified about their data being entered into the User database and processed, once they provide consent to this Privacy Policy.
2.21. Third-Party Links Users should be aware that when clicking on some links on the Website, they may be redirected to external websites where third parties may collect information outside the direct control of the Administration. In this case, the third parties' privacy policies will govern the processing of information obtained from Users.
3.1. Personal data of Users, once provided to the Administration, will be used for the purposes outlined in this Privacy Policy. In particular, the Administration may process personal data for the following purposes:
3.2. To fulfill any other goals for which the User has provided consent.
4.1. Orders, Agreements: As part of the Website’s operations, the Administration may process personal and contact information necessary to enter into an agreement between the User and the seller/performer of Services, including information about: geographic location, first name, middle name, last name, date of birth, gender, credit card and other financial account information, transaction data, including offered, revised, or purchased Services on the Website, phone number and associated information, including photos, education, profession, work experience, service delivery times, tasks performed and products received, language proficiency level, IP address, audio/video recording if the User contacts the seller/performer of Services via video/audio call, user-generated content (e.g., messages, reviews, etc.), skills, test results, and other information provided by the User on the Website.
4.2. Customer Service: When Users contact the Administration, the latter may collect personal information necessary to fulfill the User's request and provide feedback, including audio/video recordings if the User contacts the Administration via audio/video call, information about Services used by the User or those that the Administration believes may interest the User. The Administration may also contact the User using the existing contact information provided for this purpose. The Administration may also collect other information about interactions with Users, such as any requests made to customer support or any feedback provided by them, including reviews left by Users. Communication data may include the content of the communication and metadata related to the communication. The Website will generate metadata related to messages made through the contact forms on the website.
4.3. Website and Mobile Data, User Actions on the Website, Cookie Files Information: The Administration may automatically receive and record, or otherwise process on its servers, unique device and application identifiers, browsing history, or other usage data of the Website, information from the User's browser or any device, including IP address, user’s geolocation, software and hardware attributes, pages requested by the User, URL or advertisement that redirected the User to the Website, search terms entered by the User that led to the Website, sections of the Website visited by the User, hyperlinks clicked, pages or content viewed, how long the User spent on the site, data contained in browser databases including SQL databases, mobile identifiers (such as Google Advertisement ID, IFA or IFV), application usage data, or other system-level information. This may occur on the Website or third-party services. Additional information on cookie file collection and processing, as well as how Users can control or block such information collection, is found in the Cookie Policy.
4.4. Survey Data: The Administration may process information collected through surveys conducted by the Administration or contractors hired by the Administration, including information about: gender, age, marital status, personal preferences, etc.
4.5. Attached Information: The Administration may also add information obtained legally from business partners or third parties, including existing User data.
4.6. Information Needed to Provide Services/Products by Third Parties: As part of the Website’s operations, the Administration may process personal and contact information necessary to enter into an agreement between the User and a third-party service/product provider, whose services/products the User is receiving or intends to receive, including information about: first name, last name, phone number, email address, date of birth (day and month), gender, methods of identity verification, IP address.
4.7. Non-identifiable Information: The Administration may process other information that does not directly identify the User, such as postal codes, demographic data, and other data depending on the purpose.
4.8. The Administration may also collect/process any other personal data the User wishes to share with the Administration.
4.9. The User, acting as the owner or recipient of personal data under the Law of Bangladesh “On Personal Data Protection”, undertakes to comply with the provisions of the specified law regarding personal data processing (including via information (automated) systems).
4.10. The User, by accepting this Policy, guarantees that they have obtained and possess all the necessary legal grounds (permissions and consents) to collect, record, accumulate, store, adapt, modify, update, use, and distribute (publish, transfer), anonymize, destroy, and otherwise process personal data and other information related to third parties using the Services/Website, and guarantees the full and unconditional consent of these individuals to all provisions of this Privacy Policy.
4.11. The User undertakes to provide the Administration with accurate and updated information (personal data) in a timely manner, and, upon the Administration's request, provide originals of relevant documents for updating the personal data provided.
4.12. Information Not Collected or Processed by the Administration: The Administration does not collect or process personal data regarding racial or ethnic origin, political, religious, or philosophical beliefs, membership in political parties or trade unions, genetic data, biometric data for the purpose of identifying individuals, data on health status or sexual life or sexual orientation of individuals, or personal data of children (when information about the relevant age of the individual is available).
4.12.1. The provision of Section 4.12 does not apply if the data subject has explicitly consented to the processing of such personal data for one or more specified purposes, and/or in other cases defined by law.
4.13. If the Administration becomes aware that a child under 18 years of age (for personal data subjects located in Bangladesh) has provided personal data to the Administration, the Administration must take all necessary steps to delete such information. If you are a legal guardian or the individual holding parental rights concerning the child and believe that the Administration is processing your child’s personal data, please contact us using the contact details provided in this Policy.
4.14. The Administration, considering available technical and administrative capabilities, makes reasonable efforts to verify, in the cases outlined in Section 4.15 of the Policy, that the consent of the User has been provided or its provision has been authorized by the legal guardian or parent of the child (holder of parental responsibility over the child).
5.1. Cookies and Other Technologies: In the course of the Website’s operations, the Administration may collect certain information using technologies such as cookies (cookies, pixel tags, cookies, cookies), pixels, local storage, and other similar technologies.
5.2. Cookie Processing: The User can learn more about the processing of cookies by reviewing the Cookie Usage Policy.
5.3. Cookie Usage Policy: The Cookie Usage Policy is an appendix to this Privacy Policy and is an integral part of it.
6.1. Retention Period: The Administration will retain Users' personal data for as long as necessary to fulfill the purposes for which it was collected, including for legal, accounting, or reporting requirements, as well as for ongoing fraud prevention, backup, and business continuity. Personal data will not be stored longer than necessary for these purposes. The Administration retains personal data for the time (period) required to provide access to the Website and associated services, the Services, delivery of services/goods to the User by third parties, and during the legitimate interest of the Administration in storing this data.
6.2. Identification and Data Deletion: Personal data will be stored in a form that allows identification of data subjects no longer than necessary for processing purposes. In any case, the Administration will delete personal data, except those necessary to comply with its legal obligations (e.g., mandatory retention periods).
6.3. Extended Retention for Public or Research Purposes: Users' personal data may be stored for longer periods than indicated in sections 6.1.-6.2. of this Policy, if processed solely for public interest, scientific or historical research, or statistical purposes, along with the implementation of appropriate technical and organizational measures to ensure data subject rights and freedoms (“storage limitation”).
6.4. Periodic Review: To ensure personal data is not stored longer than necessary, the Administration periodically reviews stored personal data.
6.5. Legal and Vital Interests: Notwithstanding other provisions of this section, the Administration may retain Users' personal data if necessary for compliance with a legal obligation or for the protection of the vital interests of Users or another person.
6.6. Determining the Retention Period: The Administration takes into account the volume, nature, and sensitivity of personal data, the potential risk of harm from unauthorized use or disclosure of Users' personal data, the purpose for which the data is processed, whether the Administration can achieve these purposes by other means, and applicable legal requirements when determining the appropriate retention period.
6.7. Opting Out of Communications: If the User no longer wishes to receive contacts from the Administration, the Administration will retain the User's basic information to fulfill the User's request and avoid sending unwanted materials in the future.
6.8. Data Retention Queries: If the User has questions regarding the data retention period, they may contact the Administration using the contact details provided in this Policy.
7.1. Sharing with Third Parties: The Administration does not sell, rent, or share Users' personal data with third parties for marketing purposes. However, the Administration may disclose personal data to selected third parties for the purposes defined in this Privacy Policy.
7.2. Sharing with Partners: The Administration may transfer data collected under this Policy to its Partners, among relevant Websites and programs owned or operated by the Administration. Data collected according to the Website’s Terms of Use and this Privacy Policy is always protected according to this Policy and the laws of Bangladesh. Partners/third parties are responsible for ensuring compliance with data processing legal requirements.
7.3. Sharing with Affiliates and Other Entities: The Administration may share information it collects:
7.4. Third-Party Service Providers: The Administration may use third-party service providers to deliver certain components of its services. In such cases, the service providers are not authorized to use the personal data collected through the Website other than to provide services to the Administration. The personal data remains subject to this Privacy Policy.
7.5. Legal Compliance and Fraud Prevention: The Administration reserves the right to share information with private individuals and government agencies as required by law, including for:
7.6. Requests from Authorities: The Administration may provide personal data to competent authorities upon request, where the request complies with applicable legal requirements and is made with lawful grounds.
7.7. Business Transactions: In the event that the Administration’s business or part of it is sold or reorganized, and the Administration transfers all or nearly all of its assets to a new owner, User personal data may be transferred to the buyer to ensure continuity of the Website’s/Services’ offerings.
7.8. Sharing De-Identified Information: The Administration may share certain anonymized information (data that does not allow identifying Users individually) with third-party service providers, trusted partners, or authorized researchers to enhance the understanding of User preferences, improve services, or contribute to research deemed to have social benefits.
7.9. Research and Service Providers: The Administration may share information it collects with third parties providing services to the Administration for research or to provide services to Users, with the understanding that such data remains subject to this Privacy Policy, and the third parties may not use the data for purposes other than providing services to the Administration.
7.10. Third-Party Service/Products: The Administration may transfer personal data to third parties providing services/products to Users or services/products that the User intends to obtain. The transferred data remains subject to this Privacy Policy, and the third parties may only use the information for providing services/products and fulfilling agreements between the User and the third party.
7.10.1. Conditions for Disclosure to Third Parties: Users agree that when following a referral link and registering on the Website through such a link, they authorize the Administration to transfer their personal data to the third party (Referral Party) responsible for processing the data in accordance with this Privacy Policy. The transfer occurs after registration and is limited to data necessary for User identification and provision of services/products by the third party.
7.11. Data Transfer Outside the Country: Personal data may be transferred outside of the data processing country in cases including:
7.12. Data Protection Outside the Country: Personal data may only be transferred to foreign entities if the receiving country provides an adequate level of data protection according to applicable law.
7.13. Disclosure for Legal Protection: The Administration reserves the right to disclose personal data to third parties, including to protect the rights, property, or safety of the Administration, its staff, Users, and others.
7.14. User Notification of Data Disclosure: The Administration may not notify the User of the disclosure of personal data to third parties unless required by law or as stated in this Policy.
7.15. Voluntary Disclosure: Users should be aware that when they voluntarily disclose personal data in public areas of the Website, this information may be collected and used by third parties, leading to unsolicited communications. This activity is outside the Administration's control, and this Policy does not apply to such information.
7.16. Additional Data Collection: The Administration may collect additional information from external sources to fulfill the purposes defined in this Privacy Policy.
8.1. User Rights: Users can access their personal data and other information defined by law, limit the processing of their personal data, correct, update, or delete the data they have provided. Users are responsible for the accuracy of the data or messages on the Website. The Administration may cease processing the User's personal data upon receiving a written request from the User to withdraw consent for data processing.
8.1.1. Exercising Rights: To exercise the rights outlined in paragraph 8.1 of this Policy, the User must send a relevant request to the Administration using the contact details provided in this Policy.
8.1.2. Request for Data Correction: In requests for data correction, update, or deletion, Users must clearly specify which information they wish to correct, update, or delete.
8.1.3. Processing of Requests: The Administration will address the User’s request within the timeframe established by law.
8.2. Cookies: Most desktop and mobile web browsers (e.g., Safari, Firefox, Internet Explorer, Chrome, Opera) provide controls allowing Users to limit or block the installation of Cookies on their systems. Please note that disabling Cookies related to first-party domains (visited sites) and other domains (related sites) may, in some cases, result in limited functionality of these websites.
8.3. Other (non-exhaustive) User Rights regarding the processing of personal data by the Administration:
8.7. Legal Limitations: Ukrainian legislation, applicable to the controller, owner, or operator, may restrict the scope of rights and duties outlined by law through legal instruments. Such restrictions must preserve the essence of fundamental rights and freedoms and be necessary and proportional in a democratic society to ensure compliance with legal requirements.
9.1. Security Measures: All information collected by the Administration, within reasonable limits, is protected by technical, administrative, and physical security measures and procedures to prevent unauthorized or illegal access or use of personal data, as well as to protect against accidental loss, destruction, or harm to personal data, in accordance with the associated risks.
9.2. Data Processing Security: Personal data is processed in a manner that ensures proper security of personal data.
9.3. Affiliated Entities and Third Parties: Affiliated entities, trusted partners, and independent service/product providers, as well as third parties defined in this Policy, are required to use the information received from the Administration in compliance with security requirements and the terms of this Privacy Policy.
10.1. Last Updated: This Privacy Policy was last updated on 02.02.2024.
10.2. Updates: The Administration may update this Privacy Policy from time to time. The new version of the Privacy Policy will take effect once it is posted on the Website at the address indicated in this section, unless otherwise specified in the new version of the Privacy Policy.
10.3. Current Version: The current version of the Privacy Policy is always available on the Website at: https://aviatorgamedesign.com/privacy-policy/.
10.4. Reviewing Updates: In case of an update to the Privacy Policy, the User can review the updated version by following the link: https://aviatorgamedesign.com/privacy-policy/.
10.5. Disagreement: If the Administration makes any changes to the Privacy Policy that the User does not agree with, the User is required to cease using the Website and its Services.
11.1. User Responsibility: The User is responsible for non-compliance with the obligations under this Privacy Policy, as defined by applicable law.
11.2. Compensation: The User is obligated to compensate the Administration for any losses directly or indirectly caused by the User's breach of obligations.
11.3. User Liability: The User is solely responsible for distributing access credentials (such as identifiers, passwords, etc.) for the Service/Website, for the dissemination of third-party personal data (including Administration's data), and for the content provided, including compliance with the current legislation.
12.1. Applicability: This Privacy Policy is binding for Operators, Partners, the Administration, third parties defined by this Policy, and others directly involved in processing personal data and/or having access to data in the course of performing their duties and/or contractual obligations to ensure the confidentiality of data obtained from the Administration.
12.2. Inquiries: All inquiries or questions regarding this Privacy Policy should be directed to the feedback section in accordance with Section 13 of this Privacy Policy.
12.3. Applicable Law: For the processing and protection of personal data, the User agrees to the use of the legislation of Bangladesh.
12.4. Jurisdiction: Regarding any issue directly or indirectly related to the Privacy Policy, the User agrees that disputes shall be resolved in the competent courts of Bangladesh in accordance with the procedures established by Ukrainian law.
12.5. Severability: If any part of this Privacy Policy is deemed invalid, it will not affect the validity of the remaining provisions. In case of any changes, cancellation, or invalidation of certain provisions, the remaining provisions remain in effect and binding on the Parties to the data processing agreement.
12.6. Governing Law: In the absence of provisions regulating specific rights and obligations in this Privacy Policy, they shall be governed and established by the applicable laws of Bangladesh.
The User can contact the Administration through the following methods:
AVIATOR
Email: [email protected]
Phone: +33 1 23 45 67 89
Address: Aviator Game Design Studio, 75 Rue de Rivoli. 75001 Paris