Privacy Policy

This is the privacy statement of Para Bellum.

Para Bellum Games and its affiliates (together “Para Bellum”, “we”, “our”) are committed to protecting the security, privacy and accuracy with respect to the processing of any information provided to the extent possible, and always according to the provisions of EU law and pursuant to the present policy.

For the purposes of the present policy, a “user” is any person visiting and/or using any page
or website under the domain of para-bellum.com, including the Para Bellum main
website, the official Para Bellum e-shop and/or any and all official Para Bellum applications
for mobile devices (collectively called herein “the website and/or application”), for private or
business purposes, without necessarily having subscribed. A “subscriber” is any person
applying for subscription and finally subscribing to the website and/or application. Both user
and subscriber will together be referred to as “you”, except when separately mentioned
within the present policy. This policy describes and explains how we collect and use personal information about you and the types of information we may collect from you or that you may provide when you visit or use the web site, owned by Para Bellum. This policy does not apply to information collected by Para Bellum offline or through any other means that do not link to this policy.

Please read the present policy carefully. If you do not agree with the present policy, in whole or in part, you should not use Para Bellum web site. By accessing or using this web site, you also agree to this privacy policy and you give your express consent to the below. This policy may change from time to time. Your continued use of this web site, after we make changes, is deemed to be acceptance of those changes, so please check the policy periodically for updates.

If you have any questions or comments about the present Privacy Policy, please use the Contact Us page found on this web site and/or application.

Please keep in mind that only information, such as your IP, which is necessary to operate a website or application, is automatically collected when you visit this website and/or application.

Table of Contents

What information we collect

We will be collecting two types of information from you:

(I) Personal Information

Personal information is any data that can be used to identify you (as a natural person). We collect data that you provide to us. Specifically, the following information classified as personal information is collected from you: your name, mailing address, e-mail address and phone number. In addition, your IP and cookies information will also be collected.

(II) Non-personal Information

Non-personal information includes data that does not, on its own, directly or indirectly link with any specific individual. This includes occupation, language, zip code, area code, time zone, referrer URL etc. We may process non-personal information for any purpose. 

How is personal information about you collected

We collect the above personal information directly from you when you log in to our e-shop, purchase a product, contact us . IP and cookies are automatically collected when you use and/or access our web site.

How can we use your personal information we collect

We can use the personal data we collect from you for operating our business, deliver products we offer, meet our legal responsibilities and obligations, verify identity where this is required, improve our products and personalize your experience while visiting our web site and prevent and detect crime, fraud or corruption. Your personal data, specifically your e-shop or para-bellum.com account information, your email and your purchase history, will also be used to personalize and improve your experience and deliver content or features that match your profile and interests, including to show you targeted advertising as described in Traffic Data, Tracking Technologies & Advertising in Section 9 below. We also may use the data to communicate with you, for example, informing you about your account, security updates and product information.

Last, we will not use any information we collect from you for any purpose, other than to execute the transactions requested by you.

Who we share your personal information with

Para Bellum shares personal information with companies which provide services such as fulfilling customer orders and delivering products to you. These companies are obliged to protect your personal information and are mainly located within the EU. This is always done in compliance with the present Privacy Policy and any appropriate confidentiality and security measures.

We may also disclose your personal information to others – if necessary by law, legal process, litigation, national security, request from public and governmental authorities or other issues of public importance.

How to access and control your personal data

You can view, edit, or delete your personal data online through your profile that you create once you register in our e-shop. You can always choose whether you wish or not to receive promotional e-mails from Para Bellum, by signing up or not to the relevant section. The option to unsubscribe from our promotional e-mail list will be provided within every such e-mail we send to you.

How long we retain your personal information for 

We will not be retaining your personal information longer than necessary, in relation to the purpose for which data is processed. Specifically, Para Bellum will process your personal data throughout the term of the sale contract and for a period of up to six (6) months years from its conclusion, except unless otherwise specified by the applicable legal and regulatory framework and the codes of conduct adopted.

Transferring your data outside the EU

We are committed in respecting the relevant GDPR rules and restrictions when and if transferring any of your personal data outside the EU. By doing so, we ensure that the level of protection of your personal data afforded by the GDPR is not undermined. 
In brief, we may be transferring any of your personal data outside the EU, only if:

(a) The Commission has decided that a third country (i.e. a country outside the EU), a territory or one or more specific sectors in the third country, or an international organization ensures an adequate level of protection, or
(b) The organization that will be receiving any of your personal data has provided adequate safeguards – ensuring that your individual rights remain enforceable and effective legal remedies will still be available to you following such transfer, or
(c) a transfer, or set of transfers, are: (i) made with your informed consent; (ii) are necessary for the performance of a contract between you and Para Bellum or for pre-contractual steps taken at the your request; (iii) necessary for the performance of a contract made in your interests of the individual between Para Bellum and any third party legally acting on our behalf; (iv) necessary for important reasons of public interest; (v) necessary for the establishment, exercise or defence of any legal claims; (vi) necessary to protect your or any other person’s vital interests, where you are physically or legally incapable of giving your consent; or (vii) made from a register which under Cyprus or EU law is intended to provide information to the public (and which is open to consultation by either the public in general or those able to show a legitimate interest in inspecting the register).

Cookies

Generally, a cookie is a small file that asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. We only use cookies information for statistical analysis purposes and then the data is removed from the system.

Before entering our web site, you can choose to accept or decline cookies.

Traffic data & Advertising 

Traffic data means any data processed for the purpose of the conveyance of a communication on an electronic communications network or for the billing thereof. Any traffic data relating to you that may be processed and stored by us, it will be erased or made anonymous when it is no longer needed for the purpose of the transmission of a communication, except if necessary by law. Traffic data necessary for the purposes of your billing and interconnection payments may be processed. Such processing is permissible only up to the end of the period during which the bill may lawfully be challenged or payment pursued. You may withdraw your consent at any time for the processing of traffic data for the purpose of marketing electronic communications services or for the provision of value added services. Any data provided during your subscription will stop being processed for the aforementioned purposes once you unsubscribe, if you withdraw your consent.

Targeted Advertising: We may use your e-shop or para-bellum.com account information when you use or interact with our Services, marketing communications, advertising content and/or third party websites, in order to provide you with targeted advertising based on your browsing activities and interests. These third parties automatically receive your IP address or mobile device identifier when you access the Services or third party websites. They may also use Tracking Technologies to measure the effectiveness of advertisements, to personalize the advertising content, and to serve you advertisements that are relevant to your regional location. We may also use information collected using third party cookies and beacons on the Services and in our emails to deliver advertising about our Services when you visit third party websites. Please note opting out of targeted advertising does not opt you out of being served ads. You will continue to receive untargeted generic ads.

Location data other than traffic data

Location data means any data processed in an electronic communications network, indicating the geographic position of the terminal equipment of a user of a publicly available electronic communications service.

Where location data other than traffic data, relating to you, may be processed, such data will only be processed when they are made anonymous, or with your consent and only to the extent and for the duration necessary. Para Bellum will inform you, prior to obtaining your consent, of the type of location data other than traffic data which will be processed, of the purposes and duration of the processing and whether the data will be transmitted to a third party. You are given the right to withdraw your consent for the processing of your location data other than traffic data at any time.

Even if consent has been obtained for the processing of location data other than traffic data, you will continue to have the right, using a simple means and free of charge, of temporarily refusing the processing of such data for each connection to the network or for each transmission of a communication.

Links to other sites

Similarly to what is mentioned in our Terms of Use, our web site may contain links to other web sites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other web site. Therefore, we cannot be responsible for the protection and privacy of any information that you provide whilst visiting such sites and such sites are not governed by this privacy policy. You should exercise caution and carefully check the privacy policy applicable to the web site in question.

Confidentiality of the communications

Para Bellum will take all available steps to ensure the confidentiality of all communications and the related traffic data, in order to safeguard such communications and related traffic data from listening, tapping, storage or other kinds of interception or surveillance of communications and the related traffic data by persons other than users, without the consent of the users concerned, except when is deemed, by Para Bellum, necessary, appropriate and proportionate measure to safeguard national security, defence, public security, and the prevention, investigation, detection and prosecution of criminal offences or of unauthorised use of the electronic communication system, as referred to EU law.

Technical storage which is necessary for the conveyance of a communication without prejudice to the principle of confidentiality is not prevented. Moreover, we are allowed to use any legally authorised recording of communications and the related traffic data when carried out in the course of lawful business practice for the purpose of providing evidence of a commercial transaction or of any other business communication.

Your rights

Pursuant to the General Data Protection Rules (EU Regulation 2016/679), you have the following rights:

Access to your information – You have the right to access your information and request a copy of the personal information about you that we hold.

Correcting your information – We want to make sure that your personal information is accurate, complete and up to date. To this end you can manually change any inaccurate information about you that we hold or you may ask us to correct any personal information about you that you believe does not meet these standards.

Deletion of your information – You have the right to ask us to delete personal information about you if:

(a) You consider that we no longer require the information for the purposes for which it was obtained.
(b) We are using that information with your consent and you have withdrawn your consent – see withdrawing consent to using your information below.
(c) You have validly objected to our use of your personal information – see Objecting to how we may use your information below.
(d) Our use of your personal information is contrary to the applicable law (national and/or EU law) or our other legal obligations.
However, your right to request deletion of your information cannot be justified if one of the following reasons apply:
(a) to exercise the right of freedom of expression and information;
(b) to comply with legal obligation;
(c) for us to perform a task carried out in the public interest or in the exercise of official authority;
(d) for archiving purposes in the public interest, scientific research, historical research or statistical purposes where deletion is likely to render impossible or seriously impair the achievement of that processing; or
(e) for the establishment, exercise or defence of legal claims.

Objecting to how we may use your information – You have the right at any time to require us to stop using your personal information for any purposes that we collect them. In addition, where we use your personal information to perform tasks carried out in the public interest then, if you ask us to, we will stop using that personal information unless there are overriding legitimate grounds to continue.

Restricting how we may use your information – In some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to our use of your information. The right might also apply where this is no longer a basis for using your personal information but you don’t want us to delete the data. Where this right to validly exercised, we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.

Automated processing – If we use or we will be using your personal information on an automated basis to make decisions which significantly affect you, you have the right to ask that the decision be reviewed by an individual to whom you may make representations and contest the decision. This right only applies where we use your information with your consent or as part of a contractual relationship with you.

Withdrawing consent using your information – Where we use your personal information with your consent you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which consent was given, unless we are required by law to process your personal data or there are other lawful basis under which your personal data can be processed by us. If any of the latter applies, you will be informed accordingly.

Please contact us in any of the ways set out in the Contact Us page and further advice section if you wish to exercise any of these rights. 

Amendments

We reserve the right to unilaterally change this privacy policy at any time and for any reason. We encourage you to review this privacy policy each time you visit the web site. If an amendment is deemed to be material, this will be communicated with a relevant announcement at least 30 days notice prior to the implementation of the change. What constitutes a material change will be determined at our sole discretion. 

This privacy statement was last updated on January 26 2021.

Data protection and network security

Without limiting our other obligations under this policy, and pursuant to the General Data Protection Rules (EU Regulation 2016/679), Para Bellum commits that all information will be secured from unauthorized access, use, disclosure and loss using commercially acceptable security practices and technologies. We have taken all appropriate technical and organizational measures to safeguard security of our services. Having regard to the state of the art and the cost of their implementation, these measures ensure a level of security appropriate to the risk presented.

In case of a particular breach of security of the network, Para Bellum will notify the subscribers and the competent national Authority – not later than 72 hours from when such risk became known to Para Bellum – concerning such risk, in due course, after becoming aware of such breach. Where the risk lies outside the scope of the measures to be taken by us, a notification of any possible remedies, including an indication of the likely costs involved, will be made.

Complaints

We seek to resolve directly all complaints about how we handle personal information but you also have the right to lodge a complaint with the Commissioner for Personal Data Protection, whose contact details are as follows:

Commissioner for Personal Data Protection
1 Iasonos Street,
1082 Nicosia
P.O. Box 23378, CY-1682 Nicosia
Tel. +357 22 818 456
Fax +357 22 304 565

e-mail: commissioner@dataprotection.gov.cy
Website: http://www.dataprotection.gov.cy/