Privacy Policy

1. Introduction

Phenomenon Studio OÜ ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and use our services related to puzzle game reviews in Azerbaijan.

Company Information:

• Legal Name: Phenomenon Studio OÜ
• Registration Number: 14811067
• Address: Harju maakond, Tallinn, Kesklinna linnaosa, Kaupmehe tn 7-120, 10114
• Email: [email protected]

2. Information We Collect

2.1 Personal Information

We may collect personal information that you voluntarily provide to us when you:

• Fill out contact forms
• Subscribe to our newsletter
• Submit game review requests
• Interact with our customer service

This information may include:

• Name and contact information
• Email address
• Phone number
• Company/organization details
• Messages and communications

2.2 Automatically Collected Information

When you visit our website, we automatically collect certain information about your device and usage patterns, including:

• IP address and location data
• Browser type and version
• Operating system
• Pages visited and time spent
• Referral sources
• Device characteristics

3. How We Use Your Information

We use the collected information for the following purposes:

• To provide and maintain our services
• To respond to your inquiries and customer service requests
• To send you newsletters and marketing communications (with your consent)
• To improve our website and services
• To analyze website usage and trends
• To comply with legal obligations
• To protect our rights and prevent fraud

4. Legal Basis for Processing (GDPR)

Under the General Data Protection Regulation (GDPR), we process personal data based on the following legal grounds:

• Consent: When you provide explicit consent for specific processing activities
• Legitimate Interest: For website analytics and improvement of our services
• Contract Performance: To fulfill our obligations when providing services
• Legal Compliance: To comply with applicable laws and regulations

5. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your browsing experience. For detailed information about our use of cookies, please refer to our Cookies Policy.

Types of cookies we use:

• Essential Cookies: Necessary for website functionality
• Analytics Cookies: To understand website usage patterns
• Preference Cookies: To remember your settings and preferences

6. Information Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following circumstances:

• Service Providers: With trusted third-party vendors who assist in website operations
• Legal Requirements: When required by law or to protect our legal rights
• Business Transfers: In connection with mergers, acquisitions, or asset sales
• Consent: When you provide explicit consent for sharing

7. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of sensitive data
• Regular security assessments
• Access controls and authentication
• Secure data transmission protocols

8. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law. Specific retention periods:

• Contact Form Data: 3 years from last interaction
• Newsletter Subscriptions: Until unsubscribed
• Website Analytics: 26 months maximum
• Legal Correspondence: 7 years as required by law

9. Your Rights (GDPR)

Under GDPR, you have the following rights regarding your personal data:

• Right of Access: Request information about your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to certain processing activities
• Right to Withdraw Consent: Withdraw consent at any time

To exercise these rights, contact us at [email protected]

10. International Data Transfers

As we are based in Estonia (EU), your personal data is processed within the European Economic Area (EEA). If we transfer data outside the EEA, we ensure appropriate safeguards are in place, including:

• Adequacy decisions by the European Commission
• Standard Contractual Clauses (SCCs)
• Binding Corporate Rules

11. Children's Privacy

Our services are not directed to children under 16 years of age. We do not knowingly collect personal information from children under 16. If you become aware that a child has provided us with personal information, please contact us, and we will take steps to remove such information.

12. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review the privacy policies of any third-party sites you visit.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any significant changes by:

• Posting the updated policy on our website
• Updating the "Last updated" date
• Sending email notifications for material changes (where required)

14. Contact Information

If you have any questions about this Privacy Policy or our data practices, please contact us:

You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate if you believe we have not handled your personal data in accordance with applicable law.