Privacy and Cookie Policy

Privacy & Cookie Policy
1. Legal Basis for Processing
2. Information We Collect
3. How We Collect Information
4. How We use, collect and share your Information
5. Your Choices and Controls
6. Children
7. Contact us
8. The DPO contacts (data protection officer)
9. California and Nevada Privacy Notice
10. The United Kingdom and Australia Privacy Notice
11. Updates and revisions
Please read this Privacy and Cookie Policy ("Policy") carefully to understand how we collect, process, use and share your personal information for the purpose of providing Services to you or when you attend live events hosted by or in connection with us.

By accessing or using any of our Services, you signify your consent to this Policy. Please note: you are not obligated by law to provide us with any information. You hereby acknowledge, warrant and agree that any information you do provide us is provided of your own free will and consent, for the purposes and uses described herein.

By "Personal Data", we consider the data that relates to you as an identified or identifiable natural person. The term "Personal Data" may include, for instance, your name, your telephone number, your e-mail address, your age, your gender, your postal address.

De-identified or Anonymous information, which we are not able to identify you, does not qualify as "Personal Data".
We use appropriate physical, technical, and organizational security safeguards to help protect your info from unauthorized access, destruction, use, modification, or disclosure both during transmission and in storage.

We process Personal Data only when necessary for the performance of a contract with you, for compliance with a legal obligation to which we are subject, or based on our legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms for which require the protection of your Personal Data.
1. Legal Basis for Processing
The information we collect depends on what Services you use and how you use them.
2. Information we Collect
2.1. Information we Collect directly
  • Your Account information in our Services, including your email address, username, real name, country, date of birth, telephone number, password, postal address;

  • Information you provide in response to surveys about our Services;

  • Information you provide when seeking help from us, such as your name, telephone number, and records (including call recordings) of the issues you experience;

  • Billing information, such as your name, payment account details, payment card number, and shipping address.

  • Personal data (we mean your photo/video or the photo/video of the person to whom our Services are intended).
We collect information that you provide us, such as:
2.1.1. We may collect other information automatically when you use our Services, such as:
  • IP address;

  • Information about your device, hardware, and software, such as your hardware identifiers, mobile device identifiers (like Apple Identifier for Advertising [IDFA], or Android Advertising ID [AAID]);

  • Approximate geolocation data (derived from IP or device settings);

  • Browser information, including your browser type and the language preference;

  • Referring and exit pages, including pages viewed and other interactions with web content;

  • Other information (such as your likeness) that you may provide as part of your participation in live events;

  • We also may collect and store information locally on your device, using mechanisms like cookies, browser web storage (including HTML 5), and application data caches.
2.2. Information We Collect indirectly
  • Anonymized browser and device information (both software and hardware),

  • Data collected through automated electronic interactions,

  • Application usage data,

  • Demographic information,

  • Geographic,

  • Geo-location information,

  • Statistical and aggregated information ("Other Information"). Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Data. For example, we may aggregate Personal Data to calculate the percentage of users in a particular country.
We indirectly collect a variety of information through your interaction with and use of our Services:
If Other Information is combined with Personal Data, we will treat the combined information as Personal Data.
We and third parties use technologies described below to collect information to deliver our Services.
3. How we Collect Information
3.1. Cookies and Similar Technologies
Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Service, analyze use, target advertisements and prevent fraud. You can disable cookies in your browser settings, but some parts of the Service may then not function properly.

If you wish to limit behaviourally targeted advertising, you can do so by limiting ad tracking in your device settings. Please note that opt-outs are specific to each browser and device and it may take a little bit of time before your opt-out choice will take effect.

For mobile advertising in apps, you can reset your Advertising Identifier and depending on your device, select to opt out of interest-based ads (Android) or turn on the Limit Ad Tracking setting (iOS).

For display advertising on the Web, you can also adjust your browser settings to limit certain tracking by means of cookies
Your browser settings may allow you to automatically transmit a "Do Not Track" signal to online services you visit. Note, however, there is no industry consensus as to what Website and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to "Do Not Track" signals. For more information on "Do Not Track" visit .
3.2. Ad Serving Technologies
Some of our Services employ ad serving technologies that use cookies, clear GIFs, web beacons, tracking pixels, SDK, API, and other similar technologies to deliver offers and advertising to you within our Services as well as on third-party platforms and sites, and to measure the performance of our advertising campaigns, such as:
  • Advertisements served and the location of the ad;

  • Length of time an advertisement was visible;

  • Domain type, IP address, size of the advertisement;

  • Your interaction, if any, with the ad; and

  • Advertisement response.
3.3. Third-Party Advertising Companies
Third-party advertising companies may combine the information collected in the context of delivering an offer to you via our Services with other information they have independently collected over time and/or across different websites. Many of these companies collect and use information pursuant to their own privacy policies. Please, note that opting out does not mean you won't see ads; rather, it means that the advertising you see may not be as relevant to you.
3.4. Information from publicly available online resources
We may use the information made publicly available, e.g. through YouTube, Facebook, Instagram and Twitter, in order to find out your opinion about our Services, so that we could take them into account while improving our Services. Such data collection can be carried out by System Concept LLC independently, or received from our partners making analysis of public sentiments on various issues.
3.5. Information from our partners
In some cases, System Concept LLC receives your personal data as a data processor, which means that the data are controlled by our partners and we use them only in accordance with their instructions and applicable laws. We use this data in order to fulfil our obligation under the EULA, improve the Services, and when processing is required in order to comply with a legal obligation to which we are subject.

Payment partners
When you purchase our Services with your credit card, we may receive from our payment partners and process a part of your credit card number, information about your credit card issuer, as well as your full address for billing purposes.

Social networks
We could register certain accounts and pages at Facebook, YouTube, Instagram, and other social networks to better communicate with our Clients, Partners, Customers in case they have questions about our Services, as well as prefer to learn about news about our Services through the social networks.
4.1. To operate our business and to enhance and personalize your purchase experience, including to:
4. How We use, collect and share your Information
  • Help identify and troubleshoot problems with your account or Services;

  • Facilitate surveys or questionnaires;

  • Communicate with you and respond to your specific requests or questions; and

  • Manage and send you confirmations and important information about your account, Services, purchases, subscriptions, and warranties.
4.2. To personalize our communications with you, including to:
  • Present offers and/or information relating to Services you might like;

  • Other Service recommendations to you; and

  • Provide you with Service updates.
4.3. We retain the information we collect for as long as necessary to provide our Services, and we may retain that information beyond that period if necessary for legal, operational, or other legitimate reasons.

We may also de-identify, anonymize, or aggregate the information we collect, or collect it in a way that does not directly identify you. We may use and share such information as necessary for our business purposes and as permitted by applicable law.

5. Your Choices and Controls
You have choices when it comes to the technology you use and the data you share. When we ask you to provide personal data, you can decline. Our Services require some personal data to provide you with a Service. If you choose not to provide data required to provide you with a Service or feature, you cannot use that Service or feature. Likewise, where we need to collect personal data by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing Service you're using, we may have to suspend or cancel it. We will notify you if this is the case at the time. Where providing the data is optional, and you choose not to share personal data, features like personalization that use such data will not work for you.

If you're concerned with the way we're handling your info, or if you would like to request to access, correct, update, restrict or delete your personal info, object to or opt out of the processing of your personal info, withdraw your consent to our use of your info, or if you would like to request a copy of your personal info for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), please Contact Us. Your right to object includes where we process your info for direct marketing, for performing a task in the public interest or pursuing our legitimate interests or those of a third party. You can also learn more about how to request access to your account info, or about how to delete your account. You also have the right not to be discriminated against for exercising any of these rights.

If you withdraw your consent (including for marketing purposes), it does not affect the lawfulness of what we did up until that point.

Before we process such requests, we may ask you to verify your identity (like by logging-in to your account or providing us with certain info to help us confirm ownership). Note that asking us to remove personal info or refrain from processing it may also result in account suspension or termination where this info is necessary to make Our Services available to you (we normally tell you this at the point we collect the info), in which case you'll no longer be able to access Our Services. We may also retain certain info associated with your account for purposes like complying with our legal obligations, managing internal books and records, preventing fraud, resolving disputes, and enforcing our contracts and terms, such as this notice and the Terms of Service.5. Your Choices and Controls
5.1. Data retention
We keep most of your Personal Data collected and processed for the purposes described in this Policy for as long as you continue to use our Services, e.g. you have an active Account in one of our Services. We will delete your Personal Data after you request your Account to be deleted via the Account Management and the grace period of 45 (forty-five) calendar days, during which we can restore your Account, expires. The process of erasing your Personal Data can take up to one month from expiry of the grace period and, considering the complexity and number of requests, may be extended by a further two months. Please read more in Section 5.4. "Right to erasure".
5.2. Right of access
You have the right to access your Personal Data that we hold about you, i.e. the right to require free of charge (i) information whether your Personal Data is retained, (ii) access to and/or (iii) duplicates of the Personal Data retained. You can use the right to access your Personal Data through the "Data Export" tool available in the Account Management tools here and – for our Services – here. Normally, we provide the duplicate of the Personal Data retained within 30 (thirty) days upon your request. Once the archive with the Personal Data we retain is ready, you will be able to download it from our resources. If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request. We also will not be able to provide you with some Personal Data that you may post or provide using our Services regardless of our request not to provide the Personal Data in this particular field, Website, etc.
5.3. Right to rectification
You control which nickname, email, phone number, country (only in exceptional circumstances), social networks accounts, trusted Websites and payment methods we associate with your Account. If they change, please modify the data in the Personal Account directly. Please inform us if any of the Personal Data we retain about you is inaccurate.
5.4. Right to Erasure
You have the right to obtain deletion by us of Personal Data concerning you.

As a result of deleting your Account, you will lose access to most Services, including the Account and Service-Related Information.
5.5. Grace period
We allow you to restore your Account during a grace period of 45 (forty-five) days from the moment you request deletion of your Account. This functionality allows you not to lose various Service-Related Information and other important information and options by mistake. During the suspension period, we will be able to finalize financial and other activities that you may have initiated before sending the Account deletion request.
6. Children
We recognise that we have a special obligation to protect personal information obtained from children. We do not knowingly collect Personal Data from any child, or process such information, without parental consent. For the purpose of this Policy, a child means any individual who is under the age of 18 (or the minimum legal age to consent to the collection and processing of Personal Data where this is different under applicable law). If you are a parent or guardian and believe we have collected your child's information in violation of applicable law, contact us at _______. We will remove the information in accordance with applicable law.
7. Contact us
The data controller in respect of our Services is: System Concept LLC

Controller's address: Vecāķu prospekts 205B - 17, Rīga, LV-1030, Latvia

Controller's registration number: 40203245897

Controller's website "Website", "Site": ___________

Сontact e-mail: _____________

If you have any issues with our compliance you may contact our Data Protection Officer as set out above. You also have the right to lodge a complaint with the data protection regulator in your jurisdiction.
8. The DPO contacts (Data Protection Officer)
If you have questions regarding this Policy, our data practices, or our compliance with applicable laws, please contact our Data Protection Officer as follows:

System Concept LLC Data Protection Officer


9. California and Nevada Privacy Notice
9.1. We are required under California and Nevada law to provide specific disclosures to residents of those states about how we treat personal information that we collect in the course of developing and providing our services, including personal information collected through our Services. The present California and Nevada Privacy Notice (the "Notice") is intended to supplement the disclosures we make in our Policy.

9.2. The California Consumer Privacy Act ("CCPA") requires us to make specific disclosures about how we collect, use and share the personal information of California residents who are subject to CCPA. CCPA also grants such California residents certain rights related to their personal information. This section describes our personal information practices, and contains these required disclosures and instructions for California residents who wish to exercise their rights under CCPA.

9.3. Please note that, to the extent permitted under CCPA, this Notice does not apply to the personal information of California residents that we collect:
  • From our workforce members for employment-related purposes;

  • In the course of certain business-to-business transactions; or

  • For or on behalf of our Clients, where we are acting only as a service provider to that Client.
If you have questions about the privacy practices of our Clients, please contact them directly.
9.4. We are required under CCPA to tell you which categories of "personal information" we collect, and which of these categories we disclose for "business purposes" or for "sale" purposes as these terms are defined under CCPA.
  1. In the past 12 months, we may have collected and sold the following categories of personal information from California residents:

  • identifiers (IDs);

  • categories of personal information described in Section 2;

  • commercial information;

  • internet or other electronic network activity information; audio, electronic and visual information;

  • professional or employment-related information;

  • If you would like to limit the cookies and other tracking tools, please read Section 3.

  1. We may disclose any of the above categories of personal information for either a "commercial purpose" or a "business purposes" as these terms are defined in CCPA.

  2. We may collect personal information as described in the "How We use, collect and share your Information" section of our Policy

  3. We may use personal information we collect for "business purposes" and "commercial purposes" as these terms are defined in CCPA. These purposes are as described in the "How We use, collect and share your Information" section of our Policy.

  4. We may share personal information we collect with third parties as described in the "How We use, collect and share your Information" section of our Policy.
9.5. California resident rights under CCPA. Subject to certain exclusions included in CCPA, and as relevant to our operations, California residents have the rights listed below. We may take steps to verify your identity, as permitted or required under CCPA, before we process your request. Verification may include asking you to provide information about yourself that we can match against information already in our possession.
  • Notice. This means that you can request that we disclose the categories of personal information we have collected about you; the categories of sources from which such personal information is collected; the categories of personal information we have "sold" or disclosed for a business purpose; the categories of third parties to whom the personal information was "sold" or disclosed for a business purpose; and the specific pieces of personal information we have collected about you in the last 12 months.

  • Deletion. This means that you can request that we delete personal information about you which we have collected from you.

  • Opt-Out. CCPA provides a right to opt-out of the "sale" of personal information as that "sale" is defined in CCPA. If you would like to limit the cookies and other tracking tools, please visit our About Our Ads policy.

  • Equal prices and services. This means that we are prohibited from discriminating against you if you exercise your rights under CCPA.
9.6. Agents that you have authorized to act on your behalf may also submit CCPA requests as instructed below. The agent must also provide evidence that they have your written permission to submit a request on your behalf. If we are unable to verify the authenticity of a request, we may ask you for more information or may deny the request.
9.7. California residents who wish to exercise their rights under this section can email us at _______ Please indicate you are a California resident making a "CCPA" request, specify which right you are exercising, and include your name, telephone number and the email address you used to access our Services.
9.8. You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent's permission to do so and verify your identity directly.

You have the right not to receive discriminatory treatment by us for the exercise of any your rights.

The CCPA allows businesses to offer consumers financial incentives for sharing personal information. For example, a business can offer a reward program or provide other benefits or offerings to consumers as compensation for the personal information. Where we offer these programs, your participation is optional. If you choose to participate, your participation will be subject to any applicable terms.
9.9. If you reside in California, you also have the right to ask us one time each year if we have shared personal information with third-parties for their direct marketing purposes. California residents who wish to exercise their rights under this section can email us at _________________. Please indicate you are a California resident making a "Shine the Light" request, and include your name, telephone number and the email address you used to access our Services.
9.10. If you are a California resident under 18 years old and registered to use the Services, you can ask us to remove any content or information you have posted on the Services. To make a request, email us at ____________ with "California Under 18 Content Removal Request" in the subject line, and tell us what you want removed. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
10. The United Kingdom and Australia Privacy Notice
10.1. If you're in the EEA/UK, you may lodge a complaint with an EU/UK/EEA data protection authority for your country or region where an alleged infringement of applicable data protection law occurs. The lead supervisory authority under the GDPR is the Irish Data Protection Commission [].
10.2. If you're in Australia, please note that you generally have the right to deal with us anonymously or using a pseudonym (unless it's not practicable for us to deal with you on this basis). Also, please Contact us if you would like to complain that we have breached the Australian Privacy Principles or any applicable code.
11. Updates and revisions
We'll make changes to this Policy over time to keep you better informed about how we handle customer info.

We'll update our Policy from time to time to reflect changes in technology, law, our business operations, or any other reason we determine is necessary or appropriate. This Policy may change from time to time; any changes we make to this Policy will be posted on Website we may also take any other steps, to the extent required by applicable law, including notifying you and/or seeking your explicit consent to material changes. Changes to this Policy are effective as of the stated "Last Modified" date. Other than where we have sought such explicit consent from you, your continued use of the Website after we make changes will constitute acceptance of, and agreement to be bound by, those changes, so please check the Policy periodically for any updates or changes. This will help ensure you better understand your relationship with System Concept LLC, including the ways we process your info.
12. Right to Erasure Request Form
You are entitled to request us to erase any personal data we hold about you under EU General Data Protection Regulation (GDPR).

We will do our best to respond promptly and in any event within one month of the following:
  • Our receipt of your written request; or

  • Our receipt of any further information we may ask you to provide to enable us to comply with your request, whichever happens to be later.

  • The information you supply in this form will only be used for the purposes of identifying the personal data you are requesting that we erase and responding to your request. You are not obliged to complete this form to make a request, but doing so will make it easier for us to process your request quickly.
Section 12.1: Details of the person requesting information
  • Full name:

  • Address:

  • Contact telephone number:

  • Email address:
Section 12.2: Are you the data subject?
Please tick the appropriate box and read the instructions which follow it.

YES: I am the data subject. I enclose proof of my identity (see below). (Please go to Section 12.4)

NO: I am acting on behalf of the data subject. I have enclosed the data subject's written authority and proof of the data subject's identity and my own identity (see below). (Please go to Section 3)

To ensure we are erasing data of the right person we require you to provide us with proof of your identity and of your address. Please supply us with a photocopy or scanned image (do not send the originals) of one or both of the following:
1) Proof of Identity
Passport, photo driver's license, national identity card, birth certificate.

2) Proof of Address
Utility bill, bank statement, credit card statement (no more than 3 months old); current driver's license;

If we are not satisfied you are who you claim to be, we reserve the right to refuse to grant your request.
Section 12.3: Details of the data subject (if different from section 12.1)
  • Full name:

  • Address:

  • Contact telephone number:

  • Email address:
Section 12.4: Reason for erasure request
Given the sensitive nature of erasing personal data, GDPR Article 17(1) requires certain conditions to be met before a request may be considered. Please supply us with the reason you wish your data to be erased and please attach any justifying documents to this one.

Please tick the appropriate box:
  • You feel your personal data is no longer necessary for the purposes for which we originally collected it.

  • You no longer consent to our processing of your personal data.

  • You object to our processing of your personal data as is your right under Article 21 of the GDPR.

  • You feel your personal data has been unlawfully processed.

  • You feel we are subject to a legal obligation of the EU or Member State that requires the erasure of your personal data.

  • You are a child, you represent a child, or you were a child at the time of the data processing and you feel your personal data was used to offer you information society services.
Section 12.5: What information do you wish to erase?
Please describe the information you wish to erase. Please provide any relevant details you think will help us to identify the information. Providing the URL for each link you wish to be removed would be helpful.

Also, please explain, if it is not abundantly clear, why the linked page is about you or the person you are representing on this form.

Please note that. In certain circumstances, where erasure would adversely affect the freedom of expression, contradict a legal obligation, act against the public interest in the area of public health, act against the public interest in the area of scientific or historical research, or prohibit the establishment of a legal defense or exercise of other legal claims, we may not be able to erase the information you requested in accordance with article 17(3) of the GDPR. In such cases you will be informed promptly and given full reasons for that decision.

While in most cases we will be happy to erase the personal data you request, we nevertheless reserve the right, in accordance with Article 12(5) of the GDPR, to charge a fee or refuse the request if it is considered to be "manifestly unfounded or excessive." However we will make every effort to provide you with the erasure of your personal data if suitable.
Section 12.6: Declaration
Please note that any attempt to mislead may result in prosecution.

I confirm that I have read and understood the terms of this subject access form and certify that the information given in this application to ______________ is true. I understand that it is necessary for ________________ to confirm my/the data subject's identity and it may be necessary to obtain more detailed information in order to locate the correct personal data.

Signed: ………………………………………… Date: ……………..

Documents which must accompany this application:
  • Evidence of your identity (see section 12.2)

  • Evidence of the data subject's identity (if different from above)

  • Authorization from the data subject to act on their behalf (if applicable)

  • Justification for erasure of data (see section 12.4).
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