PRIVACY NOTICE

LAST UPDATED: 2019-07-26

This Privacy Notice (hereinafter referred to as " Privacy Notice") is drafted in compliance with applicable data protection legislation, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and of the free movement of such data, issued on 27 April 2016 ("GDPR"). The terms "data subject", "controller", "processing", "processor", "third parties", "personal data", "data transfer", "Personal Data Breach","consent", "cross-border data transfer", " recipient", "Supervisory authority / Data Protection Authority (DPA)" shall have the meaning given in the GDPR.

TDA SOFT INTERNATIONAL SRL , with its registered headquarters in Bucharest, registered with the Trade Registry under no. J40/1176/2012, EUID: ROONRC.J40/1176/2012, sole identification code 29663320, (hereinafter referred to as "TDA Soft", "we", "our" or "us") processes your personal data collected in relation to the ARES-APLPHA app.

We thank you for reading this Privacy Notice carefully. If for any reason you have concerns or enquiries about how we process your personal data, please contact us at support@ares-alpha.com.

COLLECTING YOUR PERSONAL DATA

We collect your personal data in an adequate and relevant way, limited to what is necessary for the optimum functioning of this app, as follows:

(i) identification data, when you create an account to use ARES-ALPHA: name, surname, nickname, e-mail address, town and country of origin, membership club (optional);

(ii) geolocation data within ARES-ALPHA, for providing real time tracking within your game and for you to be able to access your history;

(iii) any other information transmitted within the application by using the communication facility for team members, that may be considered personal data.

All Users of ARES-ALPHA must be at least 16 years of age at the time of creating an Account for using the application and communicate their personal data through it.

PURPOSES OF THE PROCESSING

We process personal data as follows:

a) for the purpose of providing the services offered through the app, ensuring its optimum functioning, managing troubleshooting; carrying out customer management and protecting our rights in regard of the app and related content, especially intellectual property rights.

Refusal to provide the personal data in a correct and complete manner, for the abovementioned purposes, makes the proper functioning and use of the app impossible.

b) for fulfilling our legal obligations, especially in regard of economic and financial management, fiscal obligations, reporting and informing authorities and / or institutions or other public bodies where disclosure of personal data is required under applicable law;

c) Additionally, we may process, based on your free consent, personal data for targeted or non-targeted advertising and direct marketing purposes (e.g. newsletters), in particular for the transmission of communications related to relevant services or products offered by us or third parties.

Your consent in this regard is requested when creating your account and can be managed/modified in the Account Management section. Consent may be withdrawn any time without any prejudice.

We may use anonymized data in order to improve the application's design and develop/upgrade it according to general user preferences, for research purposes, new product development, carrying out market studies and / or analysis, as well as for statistical purposes.

We also use general location information (country/region), in order to optimise the use of the application (automated fill-in of certain fields when creating an account). Such data is not stored.

DISCLOSING YOUR PERSONAL DATA

Where necessary, we may transfer personal data to other legal entities in the context of a merger or acquisition, when your personal data may be transferred to an organization which has acquired the stocks or assets of TDA Soft, or one of our businesses, if the case may be. In this event, you will be duly informed about the impact that these organizational changes may have on the manner we process your personal data and the content of this Privacy Notice, if the case.

Your personal data may also be disclosed to third parties in one of the following cases:

- your nickname and location to the organizer of a specific game and to your team-members, when your application is on; we recommend you to close your app each time you finish your game;

- if we have your consent in this respect;

- if we have to comply with obligations imposed by the applicable laws on the transmission of data to authorities, agencies, public bodies or other third parties, in case of which disclosure of personal data is required;

- if disclosure is necessary in the context of the provision of services contracted by you through downloading this app and creating an account, to the following categories of third parties:

STORING YOUR PERSONAL DATA

We intend to keep your personal data accurate and up-to-date. We do not wish to store your data for longer than is necessary for the relevant purposes in relation to the use of our ARES-ALPHA application. The data provided by you for the creation of your account is retained as long as your account is not deleted, unless a specific legal provision imposes a longer period of time.

The default retention period of your data related to the use of the app (game history, communication history etc.), within the settings of ARES-ALPHA, is of 1 year as of the date of use. You can modify the retention period when creating your account or afterwards [here], as follows:

- no history - please note that if choosing this setting, certain features of the app will not be available to you (game history, track records, communications history etc.); you will be able to use the app in real-time mode only, during a specific game.

- 3 months

- 1 year

- 5 years

At the end of the chosen period, your data within the application is deleted (unless you opted for manual clearing of the history, in which case your data will only be deleted when you decide to delete it).

TRANSFER TO COUNTRIES OUTSIDE THE EU/EEA AND SAFETY MEASURES

Your personal data are kept on servers located in the EU and are not normally transferred outside the EU/EEA. However, in exceptional cases, such transfer may be necessary or may incidentally occur. When personal data are transferred outside of the European Economic Area (EEA), where the level of personal data protection is not the same as in the EEA, we take appropriate measures to ensure that personal data will be adequately protected in the recipient country and to ensure that your personal data will be processed with the same degree of care as in country of your residence.

Personal data may be transferred by you to the United States of America when purchasing or downloading for free the ARES-ALPHA application using Apple Play, independently of TDA Soft. In this regard, we strongly recommend that you visit the following addresses: https://www.apple.com/legal/privacy/en-ww/ to get acquainted with the data processing conditions by these special partners of TDA Soft.

YOUR RIGHTS AS A DATA SUBJECT WITH RESPECT TO YOUR PERSONAL DATA

Under the applicable legislation, as a data subject, you have a number of rights with respect to your personal data, including the following:

Right of access - in particular, the right to obtain from us a confirmation that personal data is processed or not, and, if so, access to such data and relevant information in relation to such data, such as: the purposes processing; the target data categories; the recipients or categories of recipients to whom data have been or are to be disclosed, in particular recipients from third countries or international organizations; where possible, the period for which data is expected to be stored or, if that is not possible, the criteria used to determine that period; or, if the data is not collected from you, any available information on their source.

Right to rectification - in particular, the right to obtain the rectification of inaccurate personal data concerning you. Taking into account the purposes for which data was processed, you have the right to obtain the completion of incomplete personal data, including by providing an additional statement.

Right to delete data - in particular, the right to obtain the deletion of personal data concerning you without undue delay if personal data are no longer necessary for the purposes for which they were collected or processed; or if you withdraw your consent on the basis of which processing takes place and there is no other legal basis for processing; or if personal data has to be deleted for compliance with a legal obligation.

The right to restrict the processing - more precisely, the right to obtain the restriction of your personal data processing in the cases and under the conditions provided by the law, such as when you contest the accuracy of the data.

The right to data portability - namely, the right to receive the personal data that you provided to us, in a structured, commonly used and readable manner, and to transmit these data to another operator, without any barriers on our part, if the processing is based on your consent or the need to execute a contract and the processing is done by automatic means. The exercise of this right is without prejudice to the right to delete data, or to the rights and freedoms of others.

Right to Opposition - More specifically, you have the right to oppose at any time, for reasons related to your particular situation, the processing based on the legitimate interest of TDA Soft. Also, if the processing is based on your consent, you have the right to withdraw your consent any time, without being prejudiced in any way.

The right to file a complaint . - More specifically, you have the right to address, at any time, a complaint or notice to the National Supervisory Authority for Personal Data Processing of Romania (email: anspdcp@dataprotection.ro) or to the National Supervisory Authority for Personal Data Processing of your country of residence, if the case, if you consider that your rights as a data subject have been infringed.

SECURITY OF PERSONAL DATA

TDA Soft makes every effort to ensure the confidentiality and protection of personal data in our possession or under our control by establishing appropriate security measures to prevent unauthorized access, collection, use, disclosure, copying, modification or disposal, and other similar risks. These security measures are constantly updated and evaluated to ensure that your data is processed safely at all times.

UPDATES TO THIS PRIVACY NOTICE

You can verify when this Privacy Notice was last amended by checking "LAST UPDATED" at the top of this page.