Privacy Policy


Company: Instinct Sports Games SRL
Registered office: Str. Gruiului NR.2, Campulung, 115100, Romania

We at Instinct Sports Games are committed to safeguarding the privacy of our users. Our business model is to provide a paid service to users who need additional features on top of the free version and does not rely on widespread collection of general user data. We also reserve our option to serve publicity, in the form of ads on our website or within any or our digital products. We will only collect information that we need to deliver the service to you and continue to maintain and develop the service.

By using the websites tennisinstinct.com, tennisinstinct.net, tennisinstinct.info, tennisinstinct.org, installing our mobile applications or in any way using or accessing our Services, you accept the terms and conditions of this Privacy Policy and the processing of your personal data. Please take a few minutes to read this policy.

Introduction

This policy describes what information we, Instinct Sports Games, collect when you use our websites, services, mobile applications, products, and content (referred to as "Services"). It also provides information about how we store, transfer, use, and delete that information, and what choices you have with respect to the information.

This policy applies to the Instinct Sports Games online platform dedicated to tennis, social interaction with peers and experts, and other tools or games, including the websites and mobile applications, and other Instinct Sports Games websites, as well as other interaction (e.g. customer support conversations, user surveys and interviews etc.) you may have with Instinct Sports Games.

This policy applies where we are acting as a Data Controller with respect to the personal data of users of our Services; in other words, where we determine the purposes and means of the processing of that personal data. For content and data that you upload to or make available through the Service ("User Content"), you are responsible for ensuring this content is in accordance with our Terms of Service, and that the content is not violating any laws or other users rights.

Instinct Sports Games may collect, store and process various kinds of data, with different legal grounds, as listed below. For the personal data that we collect, in order to be able to provide our services, we provide easy access for you to modify this information in the dedicated user account and/or user profile sections of the Instinct Sports Games mobile app.
The overall purpose of collecting data is to operate the Instinct Sports Games platform, provide our service and to describe clearly your account or profile information as well as your information regarding tennis and social interactions with other users.
For the categories of data that require your consent, we will actively ask you for consent before collecting any data.

Information about personal data we collect

User account information

When you register for Instinct Sports Games Services, we collect personal data in the form of your email address. Later on, in a section dedicated to the user profile ("Profile"), we collect personal data such as: your email address, name, phone number, city, district/area, country, profile picture.
In order for us to provide a better, more personalized service, you have the option to provide further data in a section dedicated to the user profile ("Profile").
Please refer to our Terms and Conditions for more information about our services and the conditions under which we provide these services, regardless if they are in a free or paid form.

Notifications

An integral part of our Services is the ability for you to receive email notifications or mobile app notifications. These are used to raise your attention about actions that are taking place on the platform for example receiving a new interaction with another user or new content that might interest you based on your user profile etc. This function of our service is a useful feature as it allows you a real-time interaction with our Services and is required to deliver the Service to you as user, in the legitimate interest of our service.
The information and personal data we described and collect may be used for the purposes of operating our websites, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. This is required to deliver the Service to you as user, by taking steps, at your request, to enter into such a contract (Terms of Service) cf. GDPR art. 6 (1) b.

Transaction information

Customers that choose to purchase a paid version of the Services provide our payment processors with billing details such as credit card information, billing email, banking information, location at the time of transaction and/or a billing address..

The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. This data may be used for the purpose of delivering the Services to you. Collecting this information is required for performing the contract we entered into with you, at your request (our Terms of Service) cf. GDPR art. 6 (1) b. Additionally, this information needs to be retained in order to comply with accounting and tax regulation cf. GDPR art. 6 (1) c.

Usage information

When you as a user interact with Instinct Sports Games and while using our Services, we collect meta-data to provide additional context about the way the Service is being used. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our server software and our analytics tracking system.
When you register as a user of Instinct Sports Games Services, we collect and use Internet Protocol (IP) address and location data to determine the language you would be most likely to use and country for which we would provide our Services to.

Product Analytics data

Instinct Sports Games logs clicks when you as a user interact with our websites or apps, when you visit a page, or use a part of our Services.

Technical log data

Like most digital services, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited within the Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.

Device information

Instinct Sports Games may collect information about devices used to access the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this information depends on the type of device used and its settings.

Location information

We receive information from you and other third-parties that helps us approximate your location. We may, for example, use an IP address received from your browser or device to determine approximate location. Instinct Sports Games may also collect location information from devices in accordance with the consent process provided by your device.

The legal basis for this processing is our legitimate interests cf. GDPR art. 6 (1) f, namely using this data for the purpose of ensuring the proper administration of our website and business, analysing the use of the website and services, monitoring and improving our website and services, improving the user experience, preventing abuse, and assisting users with support inquiries.

For information about cookies and how we use cookies, please see our Cookie section later in this document.

Customer Support Information

We may process information that you send to us, should you choose to submit a feedback note, write to us a support request via email, or contact Instinct Sports Games by any means for support purposes. If you contact us, we may use your Account, Profile, Transaction or Usage Information to respond.

Collecting this information it is required for performing the contract we entered into with you, at your request (our Terms of Service), as well as our legitimate interest of handling your requests cf. GDPR art. 6 (1) f.

Product & Marketing communication

We may process information that you provide to us for the purpose of subscribing to our email newsletters or marketing communication. You can opt-in to emails such as digests, newsletters, product improvements, surveys or other marketing channels through your Account dedicated page. Marketing will only be sent to you by Instinct Sports Games; no personal data will be transferred to third parties for marketing purposes (other than possibly to service providers on assignment by Instinct Sports Games to deliver the marketing message, however these providers do not have any rights to use the data for any other purposes than to what they have been assigned to, on behalf of Instinct Sports Games).
The product and marketing data may be processed for the purposes of sending you relevant product information or newsletters. The legal basis for this processing is your consent cf. GDPR art. 6 (1) a.

Service and transactional notifications

Sometimes we'll send you emails about your account, service changes or new policies. You can't opt out of this type of "service or transactional" emails (unless you request the deletion of your account).
The legal grounds for collecting this information is that it is required for performing our commitment about communicating changes in plans, pricing and features to you in the contract we entered into with you, at your request (our Terms of Service) cf. GDPR art. 6 (1) b, and our legitimate interest of communicating important information about your account to you, cf. GDPR art. 6 (1) f.

Correspondence information

We may process information that you choose to share with us if you participate in a focus group, contest, activity or event, apply for a job, interact with our social media accounts or otherwise communicate with Instinct Sports Games.
The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests cf. GDPR art. 6 (1) f, namely the proper administration of our website and business and communications with users.

In an ongoing effort to improve our Services, additional personal data may be collected from you. In such cases, we will notify you when the personal data collection takes place.
Your privacy is important to us and we will only process your personal data in accordance with this Privacy Policy and relevant personal data regulation.

We will retain your personal data as follows:

Transaction information will be retained for a minimum period specified by the applicable taxation and accounting laws. All other data and information about you, used for delivery of Service, product and marketing, will be retained as long as you have given us consent to use this information.
The period of retention of usage information will be determined based on the need for historical data to determine statistical validity and relevance for product decisions and technical monitoring.
Regardless of the provisions above, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Cookies

Instinct Sports Games uses internet cookies in order to function properly. The use of cookies only applies to our websites. We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device for a set period of time or until you delete them).
If you do not accept cookies, you can prevent cookies from being saved on your device by changing the settings of your web browser. You can also delete cookies which have been previously stored. In such cases, please refer to the help section of your internet browser. If you choose not to accept cookies, you can still use our Services, but their functionality may severely impacted.
On your first visit on Instinct Sports Games websites you will be notified of our use of cookies.

Managing and deleting your personal information

If you have a Instinct Sports Games account that you created on our websites or mobile applications, you can access, modify or export your personal information, or delete your account by contacting Instinct Sports Games. If you request the deletion of your account, your information and content will be unrecoverable after that time. You may instruct us at any time not to process your personal information for marketing purposes. We may withhold personal information that you request to the extent permitted by law.

Portability

You have the right to receive your personal data which you have provided to Instinct Sports Games by requesting the files, in accordance with relevant personal data regulation, provided that such request does not adversely affect the rights and freedoms of others. Please contact us directly by using the Feedback option provided in the main menu of our app.

As an individual you are granted rights according to the applicable data protection law:
The right to access to your personal data,
The right to rectification of your personal data,
The right to object to and restriction of our processing of your personal data,
The also right to be forgotten; erasure of your data,
The right to data portability.

The rights are not absolute, and you may read more about your rights in the EU general data protection regulation Chapter III, or at https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en

Transfer of data

Personal data collected from you may be shared with third-party providers of Instinct Sports Games that process personal data on behalf of Instinct Sports Games; such as and not limited to server hosting providers, data storage providers, companies carrying out system and sales performance monitoring, customer support systems - and payment service providers. These service providers will be considered processors of your personal data. In the case we do need to share data with the mentioned external providers, Instinct Sports Games will have a valid contract of service with these providers.
Instinct Sports Games will always apply safeguards to protect your personal data from unauthorized disclosure. We may also transfer your personal data in the event that our business (or part of it) is sold, for instance as part of a merger or acquisition. In case of transfer of data to third parties that are outside of the EU or EEA and that do not offer an adequate level of data protection, Instinct Sports Games will apply the EU Commission's model clauses and/or binding corporate rules, or similar instruments/mechanism, for the safeguarding of integrity and security.
In no event does Instinct Sports Games transfer personal data to third parties with the right for such parties to use the data other than on behalf of Instinct Sports Games.
Instinct Sports Games may further disclose your personal data in order to comply with a legal or regulatory obligation, if we reasonably believe that this is required by law, regulation or other legislation, or in order to protect and defend Instinct Sports Games, our business partners or users’ rights and interests, subject always to relevant applicable personal data regulation.
You acknowledge that personal data that you submit for sharing or publication purposes through our website or services may be available, via the internet, around the world. Included in our Services is offering you the ability to share parts of your data with Instinct Sports Games, other users, visitors or general public. In these cases, you are the sole responsible of cautious use of the sharing abilities and the data shared. We cannot prevent the misuse of data that you share with other parties via our Services.
In some circumstances your personal data may be transferred to countries outside the European Economic Area (EEA). Instinct Sports Games uses partner hosting facilities for storing all Services related data, including personal data we collect, that are situated in the European Union. The hosting partner is ISO certified in industry specific standards. The hosting facilities for backup of data are also situated in the European Union. For temporary hosting needs, fail-safe or backup measures we may need to transfer data to data-centers or providers located in the United States. Transfers to the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

Questions or complaints

If you have any questions, feedback or complaints about our processing of your personal data, you are welcome to contact us at office@tennisinstinct.com. You also have the right to lodge a complaint with a supervisory authority.

Security of the personal data we process

The security and integrity of your personal data are very important to us. In addition to complying with applicable relevant personal data regulation, we use accepted industry standards, technologies, and procedures, such as encryption, secure communication over domains, security software, etc., in order to protect the integrity of your personal data and to prevent any unauthorized access.
Instinct Sports Games Services, web sites or mobile applications may encounter performance or development errors. Instinct Sports Games does not take responsibility for the errors that you may encounter. Instinct Sports Games will endeavour to minimize the number and the gravity of these situations and asks all users to report the encountered errors to the Instinct Sports Games team as quickly as possible.
Despite our best efforts and safeguards, there is always a risk of unauthorized access to your personal data. By using our Services, you assume this risk of no system being 100% safe.
As a user you should also take security measures such as securely setting and storing strong passwords, limiting access to your computer and browser and logging out after having used the Instinct Sports Games Services on shared devices.

Changes to our Privacy Policy

From time to time, it may become necessary to make changes to this Privacy Policy. Therefore, we reserve the right to update and/or modify this Privacy Policy at any time without giving notice to you. Please review this Privacy Policy frequently, and especially before you register an account with us.

The date of the last modification is listed at the bottom of this document.

01.12.2021