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Privacy Policy

The Foreword

Here, at stroke-of-luck.com (“Website”), we value in particular your privacy and do every possible effort to make the processing of your data lawful and secure. In this Policy you can find the information on how do we process your data: the purposes of the processing, types of the data we collect from you, the storage period of the data we receive from you, the recipients of your data, your rights and other information you should know about the processing of your data.

1.  Who we are?

The Website is maintained and operated by NITAYA INVESTMENTS LIMITED (“The Company”, “We”, “Our”), incorporated under the laws of Cyprus, with its registered number ΗΕ 384793, with its registered address at Veroias, 3 Monovolikos 4, Kato Polemidia, 4150, Limassol, Cyprus. The Company is the Data Controller in accordance with the Regulation 2016/679 of the European Union and the Council (“GDPR”).

1.1   How can you contact us?

Should you have any question about your privacy or your personal data processing, or you faced a problem, or want to lodge a complaint, please, contact our Support team via e-mail manager@stroke-of-luck.com and specify your issue. Your inquiry will be directed to the relevant department, which will assist you with your issue.

2.  What personal data about you do we Collect and when?

2.1 When you browse or use the Website, the following data about you is automatically collected (“Automatically collected data”):

-  Your Device information. When you browse the Website, we track the information about your device (mobile device or computer), device unique ID (if applicable), operating system, browser type and its version, opted time-zone, installed language.

-  Your IP address, your location data, information about your mobile carrier operator or internet provider.

-  Information about the source, from which you got into the Website.

-  Information received and collected by cookies (to find out how the Website uses cookies, please, follow the cookies section or follow our Cookies Policy).

-  We also track the information on your behaviour on the Website, including the number of times you visited the Website, the subpages you visited, access time and other information about your browsing session.

-  Information on whether or not have you consented to receive personalised content, or materials, or whether or not you have agreed to our Privacy Policy, Cookies Policy and other related documents.

2.2 When sending a message to us via the interface of the Website or when you send an e-mail to us directly, or when you subscribe to our weekly mailing list, you submit to us the following information (“Message data”):

-  Information about your e-mail address.

-  Information on the status of your subscription to our weekly mailing list.

-  The subject of your inquiry.

3. How do we use your data and in what legal grounds?

The data, collected from you shall be used by the Company for the following purposes and on the following legal grounds:

Purposes of the processing

Legal Ground of the processing

To administer the Website and protect our business. We use your data for the purposes of prevention of fraud, unlawful or illegal activity, to protect the Website and the technical infrastructure of the Company. 

The processing is necessary for the purposes of the legitimate interests pursued by Company.

To provide you with the Website, tailored for your interests, geography and preferences. Examples include, but not limited to the following: a) we may provide you with the Website in your language; b) we may provide you with the Website, tailored for your geography and preferences.

The processing is necessary for the purposes of the legitimate interests pursued by Company.

To deliver you the content, reviews and materials, tailored for your interest and preferences (upon your explicit consent).

Your Consent.

To develop new features of the Website. We may anonymize your data (by removing personally identifiable information from data sets) and conduct research and analysis. This analysis will help us to find out how people of specific audiences use the Website. By using this information, we will develop the Website in the manner, which fits the interest of our audiences.  

After the anonymization, your data shall no longer be defined as personal data. This processing is not prohibited by the law and do not require any specific consent.

To comply with the law, requests of the government agencies, court or police (if applicable). 

The processing is necessary for compliance with a legal obligation to which the Company is subject.

To respond to your inquiry or message.

Your Consent.

To maintain the record of processing activities.

The processing is necessary for compliance with a legal obligation to which the Company is subject.

To send you our weekly mailing list.

Your Consent.

4. Protection of children.

The Website is not intended for users under the age of 18 years or under the age required to participate in gambling in the jurisdiction of the particular user (“legal age”).

The Website does not collect and process the data of users under the legal age. If it is determined, that any Website user is under the legal age, we will immediately remove all the data was collected from the child. If you are a parent or a guardian and find out, that your child or your ward uses the Website in any manner, do not hesitate to contact us in order to solve this issue.

The Company bears no responsibility for any use of the Website by children or persons under the age of 18. By using the Website, each user or visitor certify and warrants, that he or she has reached the legal age of his or her jurisdiction.

5. To whom can we disclose your data?

Your data, collected under this Policy, can be disclosed to the following Parties:

5.1  The employees, affiliates and sub-contractors of the Company. We can do this in order to provide you with the Website in its full functionality. These disclosures shall be based on the proper data transfer agreements. It means that those parties shall process your data only in accordance with this Privacy Policy.

5.2  Service providers, software providers, host providers. Some functions of the Website, or the infrastructure of the Company may not belong to the Company. That is why, when you visit the Website, your data may be transferred to those third parties.

5.3  Analytics

We use Analytics in order to better understand our users’ needs and to optimize users’ experience on the Website.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google services. Google Analytics Opt-out Browser Add-on provides visitors and users with the ability to prevent their data from being collected and used by Google Analytics. To install Google Analytics Opt-out Browser Add-on, please, follow this link: https://tools.google.com/dlpage/gaoptout?hl=en-GB.

Hotjar

Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, etc.) and this enables us to maintain, and improve our Website. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices (in particular a device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our Website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please follow Hotjar’s privacy policy (https://www.hotjar.com/legal/policies/privacy).

5.4  To the governmental authorities, such as regulatory bodies, police, courts upon their lawful request.

6. How long do we store your data?

We shall store your Automatically collected data and Message data as long as we need these data to provide you with the Website or to solve your issue. In some cases, we may store your data for an additional period of time, if required by the law.

As was specified above, we may use your data after the anonymization procedure. We want to assure you, that those data a) shall contain no information, which can be defined as “personal data”; and b) shall contain no information, by using of which you can be identified.

7. Your rights

As the data subject, you have the number of rights, which you can realize by contacting our Support Team via email:

These rights are:

The right to access. You have the right to obtain from the Company confirmation as to whether or not personal data concerning you are being processed, and, if the Company indeed processes your personal data, to receive a copy of the personal data undergoing processing.

The right to correction. You can always ask the Company for correction of inaccurate personal data about you.

The right to erasure. You can always ask the Company to remove all the personal data we collect from you. We will remove all previously collected personal data if we no longer need these for the purposes those data were collected.

The right to object to processing. You have the right to object, on grounds relating to your particular situation, to processing of your personal data, if the grounds of this processing were necessary for the purposes of the legitimate interests pursued by Company. Additionally, you have the right to object to processing of your personal data for direct marketing purposes (if applicable).

The right to restriction of the processing. You have the right to obtain from the Company restriction of the processing, in case if one of the following applies: a) you contested to the accuracy of the personal data; b) the processing is unlawful and you oppose the erasure of the personal data and requests the restriction of their use instead; c) the Company no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims; d) you have objected to processing on the basis of your right to object pending to verification whether your legitimate grounds override those of the Company.

The right to withdraw consent. If you previously consented to the processing of your data, you have the right to withdraw this consent at any time. It means that we shall stop processing of the personal data, for the processing of which the consent was required, starting from the date of the withdrawal. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

The right to data portability. You have the right to receive from the company the data, which were collected from you, in a structured, machine-readable format and have the right to transmit those data to another controller (simply, to another company).

Please note, that these rights are applicable with some restrictions:

8. Complaints Information.

You can always contact our Support Team for any issue concerning your privacy, including complaints. Nevertheless, if you deem, that your rights under the data protection legislation have been infringed, you can lodge a complaint with The office of The Commissioner for personal data protection of the Republic of Cyprus. The Website of the Commissioner: www.dataprotection.gov.cy.

9. How do we protect your data?

We protect your data by using the legal methodology and technical methodology:

10. Cookies.

Our website uses cookies. A cookie is a small file of letters and numbers that we put on your electronic device. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For more information on Cookies, please, follow Cookie Policy.

11. Transfer of the data outside the European Union (For EEA residents).

Please note, that some parts of our business group are located outside the European Economic Area. It follows that legislation on the data protection may be not so strict as the legislation, which is in force in the European Union, and some of your data will be transferred to these jurisdictions. Also, we want to notify you, that we apply all measures to oblige all parts of all our business group, as well as all our non-EU business partners to process your data in accordance with The General Data Protection Regulation (EU) 2016/679 (simply, “GDPR”). If you consent to this Policy, you hereby consent to these transfers. You can withdraw this consent at any time, but in this case the functions of the Website will not be available for you.

12. Third-party Websites.

Please note, that our Website may contain the links to the Websites, operated by the third parties. For example, banners of third-party brands or hyperlinks to third-party websites etc. Please note, that you follow those banners or links at your own risk. The Company bears no liability for the content on those Websites and bears no responsivity on anything, what can happen as a result of your visit to those third-party Websites. We highly recommend you to visit “Privacy Policy” or “Privacy Notice” or another privacy document on the third-party Website before submitting any information to the latter.

13. Changes to this Policy.

We may change this Privacy Policy from time to time. If we do, we will let you know by revising the date of this Policy. We encourage you to review the Privacy Policy whenever you access our Website. By continuing to use our Website after Privacy Policy changes go into effect, you agree to be bound by the revised policy.

Contact us

If you have any question or suggestions regarding our website - feel free to contact us anytime!

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