PRIVACY POLICY of the GoBot


1. INTRODUCTION
1.1. This Privacy policy of the GoBot (hereinafter referred to as the “Privacy policy”) is a document that sets and defines terms of processing of personal data of users of the website gobot.ae and / or the mobile application named “GoBot” that is available on Google Play for Android platform (via the following link https://play.google.com/store/apps/details?id=ct.pro.goball&hl=ru) and on Apple Store for IOs platform (via the following link https://apps.apple.com/ru/app/goball-next-sport/id6743632607) (hereinafter referred to as the “GoBot” or the “Platform”) developed and operated by E.Z.F - INVENT Free Zone Establishment - Limited Liability (registration number (Business License) 40137) (hereinafter referred to as the “Service provider”, “we”, “us”) - a legal entity incorporated under the laws of the United Arab Emirates address at: Ajman Free Zone C1 Building, UAE.
1.2. The Privacy policy might be considered both as a separate document and as an integral part of the User agreement of the GoBot (available via the following link https://gobot.ae/privacy_policy) (hereinafter referred to as the “User agreement”) for users who accepted the User agreement and continue using the GoBot. The terms mentioned in the Privacy policy are used in their meanings and definitions set both in the Privacy policy and in the User agreement, in the event of any conflict between the provisions or terms meanings and definitions of the Privacy policy and the User agreement the provisions and terms meanings and definitions of the Privacy policy for purposes of personal data processing regulation shall prevail.

2. DEFINITIONS
“You” (also the “User”) - the individual, or the company, or other legal entity on behalf of which such individual is accessing or using the GoBot.
“Account” - a unique account created for and or by the User on the GoBot to access the GoBot and the Services.
“Services” – services offered, performed or executed on the GoBot regardless by the Service provider, by third parties and by other Users.
“Cookies” - small text files that are placed on your computer, mobile device (e.g. phone or smart phone etc.), a digital tablet or other device, containing the details of your browsing history as You are browsing on website. They are processed and stored by your web browser. In and of themselves, cookies are harmless and serve crucial functions for websites. Cookies can also generally be easily viewed and deleted.
“Device” - any device that can access the GoBot such as a computer, a mobile device (e.g. phone or smart phone etc.), a digital tablet or other device.
“Data” (also the “information”, “data”, “personal data”, “non-personal data”, “personally identifiable information”) - any information relating to (1) an identified or identifiable natural person (“data subject”) - who can be identified, directly or indirectly, in particular by reference to an identifier such as a full name (nickname, informal designations), an identification number, location data, occupation, gender, date of birth, photos, email address, phone number, 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; or (2) technical and related information that is not personally identifiable, including, but not limited to, the operating system type and version, origin and nature of identified malicious system threats, and the software modules installed on an endpoint device.
“Processing” - any operation or set of operations which is performed on Data 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.
“Usage data” refers to data that is collecting automatically, either generated by the use of website or from the website structure itself (e.g. the duration of a web page visit).

3. GENERAL PROVISIONS
3.1. The Privacy policy defines the policy of the Service provider of the GoBot, concerning the processing of Data of Users of the GoBot.
3.2. The Privacy policy defines what data the Service provider collects and how we use, process, disclose, share, transfer, store and protect Data obtained by the Service provider.
3.3. You should fully and carefully read the Privacy policy before using the GoBot and make sure that You acknowledge, understand and consent to all its articles. Using the GoBot and filling out any forms by the User shall mean full and unconditional acceptance of the Privacy policy by the User. If You do not fully understand and / or do not fully accept and agree with terms of the Privacy policy and / or changes, additions and / or amendments thereto – You should immediately stop using the Platform and / or to contact the Service provider as set in chapter 11 of the Privacy policy – “How to contact us” – for further explanations and instructions. By using the Platform and our services You agree to collection and use of Your personal data and the Data in accordance with the Privacy policy.
3.4. The Privacy policy is publicly available on the Service provider official website: gobot.ae and in the mobile application mentioned in clause 1.1 of the Privacy policy.
3.5. We keep the Privacy policy under regular review and make changes reasons related to working practices or regulatory changes or the Platform inner operational and service development reasons and We place corresponding updates on the Platform. We will notify You at our sole discretion of the addition and / or modification of the Privacy policy in the manner that the GoBot deems most appropriate about all changes and amendments to the Privacy policy via pop-up windows and / or notifications on the Platform and / or by email. The User shall acknowledge and comply with all changes to the Privacy policy when using the Platform after those changes posted. Further use of the Platform, materials and functions offered on it at any time means (including by simply accessing and reviewing it) means for us that You have unconditionally accepted and agreed with any alterations made to the Privacy policy and with current version of the Privacy policy whole or in part, if You did not – please stop using the Platform immediately, if You changed your mind – please immediately request the Service provider to delete Your account as set in chapter 11 of the Privacy policy and stop using the GoBot until this account is deleted.
3.6. Using the Platform the User fully and unconditionally accepts the Privacy policy, including by downloading, installing, using the Platform and filling out any forms posted on it, the User confirms his consent to the GoBot processing of personal data and the Data and other information provided during registration, collected automatically, as well as placed by the User voluntarily on his personal page in the Account, including, but not limited to User generated content: comments, reviews, descriptions, revisions, design elements, photos, videos, images, drawings, sound files, links to third-party resources.
3.7. You acknowledge and agree that it is Your responsibility to review the Privacy policy periodically and become aware of any modifications and changes.

4. PURPOSES OF DATA COLLECTION AND PROCESSING
4.1. GoBot on terms of the Privacy policy collects and / or processes personal data and the Data when the User uses the Platform and the Services, as also when using or otherwise interacting with the GoBot’ products.
4.2. GoBot collects and / or processes personal data and the Data for the purposes of registering the User on the GoBot, enabling its full use, providing the User with the Services, participating in research and marketing activities conducted by the GoBot.
4.3. GoBot collects, stores and processes only the Data that is necessary for the provision of the Services to the Users or the performance of agreements and contracts with the User, except in cases where the law provides for mandatory storage of personal data and the Data for a period specified by law, including for the purposes of:
  • identification;
  • providing the User with personalized services and facilities;
  • communication with the User, including sending notifications, requests and information related to the use of the GoBot, the provision of the Services, as well as processing User's requests and applications;
  • conducting statistical and other research based on depersonalized data;
  • conducting marketing campaigns for users, including for the purposes of distributing offers to participate in the promotion and receiving prizes / rewards provided for the promotion;
  • distribution of advertising and information materials over communication networks, including through the use of phone, Internet, mobile radiotelephone communications, or through direct contacts;
  • to resolve disputes and identify problems;
  • to prevent potentially prohibited and illegal actions as fraudulent activities, misuse of the Services;
  • targeting newsletters, advertising materials and other information brought to the attention of the Users.
5. THE VOLUME OF PROCESSED DATA
5.1. As part of execution of the Privacy policy and the User agreement, when the User uses or accesses the GoBot the User may provide and the GoBot may store and process the Data in volume set in it’s definition in the Privacy policy.
5.2. In the background mode and by consent of the User we store and process data that is automatically transmitted to the GoBot in the course of using the Platform by the software installed on the User's Device, including: IP-address, information from the Cookies, information about the User's browser (or other program through which the Platform's facilities are accessed), geolocation, access time, the address of the requested page, as well as other data, including those provided by the User after the registration of the User (creating the Account) in the process of using the Platform and the Services.
5.3. GoBot, for its part, synchronizes the search history, settings and favorites in the User's Account.

6. PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA
6.1. GoBot shall be entitled to:
  • perform any actions (transactions) using automation tools or without using automation tools with the User’s Data including collection, recording, copying, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (provision, access) to third parties, as well as in cases of disclosure due country authorities requests (request of the court, law enforcement agencies, etc.), in compliance with the requirements of information confidentiality, depersonalization, blocking, deletion, destruction of the Data;
  • use the Cookies and similar technologies (including: pixel tags, web beacons, transparent GIF files, JavaScript and local data storage, etc.) to collect personal identification information or information that can become personal identification information in combination with other information, in compliance with all necessary legal requirements regarding the privacy of the Users' Data by identifying Users and their representatives when it is applicable, counting and sorting them by the Service provider’s sole discretion and observing which pages of the Platform they visit, to ensure User a maximum experience by providing personalized information, remembering preferences in marketing and products, as well as helping to get the right information (including for entering the certain blocks of the Platform or for using the Account), analyzing User's actions on the GoBot, in order to improve and optimize the Services, including, to make it easier for the Users to find the necessary information on the GoBot;
  • provide advertising, messages and content, including by sending push or short-message-service (sms) notifications (messages), advertising notifications and messages, via e-mail on the Internet, using the services and databases of both the GoBot itself and the services of third-party (external) services and resources on the Internet with full respect of General Data Protection Regulation (GDPR) rules;
  • communicate directly with the User, including via phone.
6.2. GoBot may use the User-provided information, including the Data, to ensure compliance with the requirements of applicable law (including for the prevention and / or suppression of Users' illicit and/or illegal actions).
6.3. The Data shall be processed upon the User accepts the Privacy policy and fills out the appropriate form for providing services on the Platform or provides the Data in another form and shall be stored until purpose of processing is achieved or the termination of the relationship between the GoBot and the User as a result of deleting his account, or even of withdrawing consent to the processing of the Data by the User or person who provided such data.
6.4. GoBot may share your personal information with third party service providers when:
  • the User has expressed his consent to such actions;
  • the User has independently openly shared his information with other Users, including through the publication of user-generated content or by choosing the «visibility for all» function;
  • the transfer is necessary to use a certain function / service of the Platform and User is informed of this transfer and accepted it or gave a corresponding order;
  • the transfer is provided for by applicable law within the limits and purposes of the procedure established by law;
  • the transfer takes place as part of the sale or other transfer of rights for the Platform (in whole or in part), while all obligations to comply with the terms of the Privacy policy in relation to the information received by the acquirer are transferred to the acquirer.
6.5. GoBot shall not sell, lease or disclose the Data to third parties for marketing purposes without obtaining the User's permission on a preliminarily basis.
6.6. Access to the Users' Data shall be possible within the Platform and the Service provider employees.
6.7. GoBot shall make every reasonable effort to ensure that:
  • information about the Users, including their Data, is collected by the GoBot only to the minimum required to provide the Services;
  • The Data is used exclusively for the purposes stated for its collection;
  • information about the Users is not transferred to third parties or disclosed, except as specified in the Privacy policy or applicable law.
6.8. GoBot shall store the Data and protect it from unauthorized access and distribution in accordance with internal rules and policies. The User's Data shall be kept confidential, except for cases set in the Privacy policy.
6.9. The User's Data shall be kept confidential, except for cases when the User voluntarily provides information about himself or on his behalf for public access.
6.10. The Service provider as a controller and processor due GDPR ensures the confidentiality and security of the Data when processing it in accordance with the requirements of applicable laws. GoBot shall apply appropriate technological and operational security standards to protect information provided by the Users to the Platform from unauthorized access, disclosure, distortion or destruction.
6.11. The Data is stored on the servers within Bahrain, UAE, Netherlands, and Bangalore, Uzbekistan. In case of deletion of Data from the Platform on any reasons and / or Account of the User is deleted, the corresponding Data would be stored by the GoBot for no more than 30 (thirty) days in accordance with right of the User to restore the corresponding Data. The period of time set in this clause is considered as a minimal possible for reasons to perform all the compliance checks, and confirmation of the User’ will.
6.12. After the above-mentioned period of storage of the User's Data expires, the User's Data shall be fully erased. The Data shall be destroyed by erasing information using certified software with guaranteed destruction (in accordance with the specified characteristics for the installed software with guaranteed destruction).
6.13. The User's Data shall be kept by GoBot exclusively on servers and processed using automated systems, except for cases when non-automated processing of the Data is necessary in connection with the implementation of the requirements of the applicable law.
6.14. The User agrees that images placed (uploaded) by him within the Platform can be used by the GoBot on following GoBot services as part of one Platform: GoBotMarketPlace (GoBotMarket), GoBotNFT (pNFT) and resources, as well as in advertising or marketing materials posted on GoBot resources on the Internet to attract the attention of other Users to the Services or to other GoBot resources and services, both with stating the User’s full name (will be specified as the full name (nickname, informal designations) of the User which he specified during registration of the Account) and without it, without the need to obtain special User's permission and without paying royalties. If the User does not have the right to grant the GoBot the right to use any image in the specified above ways, he shall refrain from uploading such an image.
6.15. The User understands and does not object to the fact that the GoBot is a resource that is operated by an international company (the Service provider) that is operating in many countries of the world. It means that this information may be transferred to – and maintained on – computers located outside of Your country, state, or other governmental jurisdiction where the personal data protection laws may differ than those from Your jurisdiction. Your consent to the Privacy policy followed by Your submission of such information represents Your agreement to such a transfer.
6.16. The GoBot and the Service provider will take all steps reasonably necessary to ensure that Your personal data and the Data are treated securely and in accordance with the Privacy Policy and no transfer of Your personal information will take place to any organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

7. COOKIES AND OTHER TRACKING TECHNOLOGIES
7.1. When You visit the Platform, we may collect certain information from you automatically through cookies or similar technology and store it.
7.2. Cookies are text files placed on your computer to collect standard Internet log information and visitor behaving information. The Platform uses a cookie to identify the User’s session and to synchronize User’s responses to one form with other relevant forms.
7.3. Cookies enable the Platform to identify Your Device as You, view different pages on the Platform.
7.4. We use cookies in a range of ways to improve Your experience on our website, including:
  • Keeping You signed in;
  • Understanding how You use the Platform;
  • Understanding your preferences in order to present content, options or functions that are specific to you.
7.5. You may control the Cookies - You can configure Your browser to determine how the Platform uses cookies or to reject cookies, but if You do so, You might not be able to experience all the interactive features of the Platform, some pages and Services may become unavailable to You.
7.6. For further information on the Cookies we use, please see the GoBot Cookie Policy via the following link https://gobot.ae/cookies_policy.

8. HOW WE STORE AND PROTECT THE DATA
8.1. The Service provider undertakes appropriate technical and organizational measures to maintain the safety of the Data against unauthorized or unlawful use or accidental loss or destruction, alteration, or unauthorized modification, disclosure or access and against all other unlawful forms of processing.
8.2. But still we warn You, that no method of transmission over the internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect Your data, we cannot guarantee its absolute security.
8.3. We are:
  • using secure servers to store Your Data;
  • sharing and providing access to Your information only to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymized basis wherever it is possible;
  • verifying the identity of any individual who requests access to information prior giving them access to information;
  • using encryption technologies.
8.4. While securing Your Data we rely on the following principles:
  • confidentiality. Within the Platform access to Your Data shall be limited to a subset of employees who work on compliance and identity verification matters. All our staff is subject to full confidentiality and any subcontractors and sub-processors are required to sign a confidentiality agreement if not full confidentiality is part of the main agreement between the parties. Whenever information is accessed by authorized employee the access is only possible over the encrypted connection. When accessing the information in a database, the IP number of the person accessing the data must be pre-authorized to obtain access. Any deviсe being used to access personal data is login protected and has the Service provider’s corporate antivirus solution installed. All premise devices storing personal data temporally are at all times, except when not being actively used or relocated under uninterrupted supervision, locked in a safe room. Your Data is never stored on mobile carrier like USB sticks and DVD’s.
  • transparency. We will any time keep You informed about the changes to the processes to protect data privacy and security, including practices and policies. You have the right at any time request information on where and how the Data is stored, secured and used.
  • integrity. All data transits are encrypted to align with best practices for protecting confidentiality and data integrity.
  • isolation. All access to Your Data is blocked by default. Access to Data is restricted to individually authorized employees, who are granted to a minimum access on a need-to-have basis.
  • the ability to intervene. We enable Your rights of access, erasure, rectification, blocking and objection either by providing built-in functions for data handling by offering the option to send instructions through the Platform’s Contacts via the following link hello@gobot.ae or also by informing and offering the Users the possibility of objection when the GoBot is planning to implement changes to relevant practices and policies.
  • monitoring. We use security reports to monitor access patterns and to proactively identify and diminish potential threats. All administrative operations and system access are logged to provide an audit trail if unauthorized or any accidental changes are made. Both internal and external monitoring services monitor system performance and availability.
8.5. The Data breach notification. “The Data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized access to or disclosure of personal data transmitted, stored or in other way processed in connection with the provision of the Platform and the Services. If occurs that Your Data is compromised, the GoBot will notify You and complement Supervisory Authority within 72 hours by e-mail with information about the extent of the breach, affected data, any impact on the Platform and the Service provider’ action plan for measures to secure the personal data and limit any possible detrimental effect on the data subjects.

9. USER'S RIGHTS
9.1. The GoBot would like to make sure You are fully aware of all Your data protection rights. Every User is entitled to the following:
  • The right to request access to Your personal data, the Data and information related to our use and processing information named in this sub-clause;
  • The right to request the correction – You have the right to request the GoBot to correct any Data You believe is inaccurate. You also have the right to request us to complete information you believe is incomplete. You can at any time change (update, supplement) the Data provided by You in whole or part of it, as well as the parameters of its privacy, using the function of editing in the Account.
  • The right to erasure – You have the right to request the GoBot to erase Your Data, under certain conditions.
  • The right to restrict our use of your information;
  • The right to object to processing of your personal data for certain purposes;
  • The right to data portability – You have the right to request the GoBot to transfer Your Data that we have collected to another organization, or directly to You, under certain conditions;
  • The right to withdraw Your consent to our use of Your Data at any time where we rely on Your consent to use or process that information at least 30 days before the expected date of termination of processing and use of the Data. Please note that if You withdraw Your consent, this will not affect the lawfulness of our use and processing of Your Data on the basis of the consent before the moment when You withdraw the corresponding consent;
  • You also have the right to lodge a complaint with a supervisory authority in accordance with Article 77 of the GDPR.
9.2. If You want to make a request, we have 30 days to respond to You. If You would like to exercise any of the rights named above, please contact the Service provider as set in chapter 11 of the Privacy policy.

10. FINAL PROVISIONS
10.1. The Platform may contain links to the services and other information resources of third parties on the Internet, posted solely for the convenience of the Users. The GoBot does not state its endorsement and does not make any assessments of the services of third parties or the information contained on these services, as well as the possible results of their use, nor does it verify the accuracy and relevance of the information provided. Responsibility for the consequences of use of the services named in this clause lies entirely with the User.
10.2. This Policy shall apply only to the Platform and to the Services. The GoBot and the Service provider shall not control and not be responsible for the services and offers of third parties to which the User can get access by clicking on external links available on the Platform, including the protection of data and information provided by the User to those third parties.
10.3. The User shall be solely responsible for the security (resistance to selection) of the means chosen by him for accessing the Account, and also independently ensure their confidentiality. The User shall be solely responsible for all actions (as well as their consequences) within or using the Service's functionality under the User's Account, including cases where the User voluntarily transfers any data and the Data for accessing the User's Account to third parties on any terms (including under contracts or agreements). In this case all actions within or using the Services on the Platform under the User's Account shall be considered to be performed by the User himself.
10.4. Data processors and sub-processors are required to comply with the Privacy policy and GDPR.
10.5. CHILDREN’S PRIVACY. If You are under 18 years old, You cannot use the Platform and the Services and be a User. We do not knowingly and / or intentionally collect or storage information from anyone under 18 years old. If we become aware that a person under the age of 16 has provided us with personal information, we will delete it immediately.

11. HOW TO CONTACT US
11.1. If You have any questions about the Privacy policy, the data we hold on You, or You would like to exercise one of Your data protection rights, please do not hesitate to contact us via the communication channels specified on the Platform in the sections «Help» and «Contacts» or on the following emails:
  • hello@gobot.ae
Contact person (Data Protection Officer): NAME SURNAME . The data controller in respect to the Platform is the Service provider, as we alone determine the purposes and means of the processing of personal data.
11.2. How we verify Your identity. If and when You make a request to have an access to Your data we will attempt to verify Your identity for using that information. If it will not be possible to identify You from such information, or if we have insufficient information about You, we may require original or certified copies of certain documentation in order to be able to verify Your identity before we are able to provide You with access to Your information.

12. HOW TO CONTACT THE APPROPRIATE AUTHORITY
Should You wish to report a complaint or if You feel that the Service provider or the Platform has not addressed Your concern in a satisfactory manner, You may contact the Information Commissioner’s Office: https://ec.europa.eu/info/ or Privacy Commissioner of Canada via https://priv.gc.ca/ if applicable.