Privacy Notice

Effective Date: June 22, 2023

The confidentiality of your data is our main priority. We strive to make the use of NEXTERS projects as convenient and safe as possible. We have developed this Privacy Notice (hereinafter referred to as the "Privacy Notice") in such a way as to make its content as clear as possible.

The Controller for the purposes of the GDPR and other applicable data protection or data privacy laws of the EU Member States, as well as other data protection requirements in respect of the Project, is:

NEXTERS Inc

3101, Cyprus, Limassol, 55 Griva Digeni

Email: privacy@gdev.inc

Data processing is carried out by us solely for the purposes defined by this Privacy Notice. Please note that you have the right to withdraw consent at any time, in the manner specified by this Privacy Notice.

Where applicable laws are stricter than the practices described in this Privacy Notice, NEXTERS has adopted specific privacy practices in those locations to satisfy those stricter requirements.

This Privacy Notice describes:

  • - What data we process;
  • - Whom we may share your data with;
  • - Purpose of data processing;
  • - How long do we store data;
  • - How we protect your data;
  • - How you can manage the data.

Please note, this Privacy Notice is available at www.gdev.inc and its related domains and subdomains (each the “Website” as applicable). NEXTERS has other privacy policies that address specific uses of NEXTERS. These policies are applicable at the following users:

  • - WEBSITE VISITOR;
  • - JOB APPLICANTS;
  • - EMPLOYEES OF PARTNERS

WEBSITE VISITOR

We do not collect or keep any personal data about visitors to our Website, except as expressly described in this Privacy Notice. If you contact us, we may keep a record of that correspondence.

Some of our services may contain Cookies and similar technologies, please see our Cookie Policy for details.

JOB APPLICANTS

Nexters Inc., and its subsidiaries, Nexters Global Limited, Nexters Studio Armenia LLC, NEXTERS STUDIO KAZAKHSTAN LTD, NHW LTD, Flow Research SLU, (collectively, “Nexters,” “we,” or “us”), respects the privacy of its job applicants and individuals interested in potential employment opportunities with Nexters (“you”), and we are committed to protecting their personal data. NEXTERS respects the privacy of its job applicants and individuals interested in potential employment opportunities with NEXTERS (“you”), and we are committed to protecting their personal data.

Personal data means any information relating to you that identifies you or could reasonably be used to identify you, and that is recorded in any form.

Your personal data may be retained and used to process your application for other open positions within NEXTERS, unless you object to such processing. In that case, data will be deleted. The processing of your personal data is based on Article 6(1)(b) of the GDPR. We need your personal data in order to conduct the recruitment process, and we will not be able to consider you for a job offer when you do not provide us with your personal data. Any processing of personal data from other sources is based on Article 6(f) of the GDPR. When we retain your personal data for other open positions, we do this based on Article 6(1)(f) of the GDPR and in order to give you the possibility to work with us in the future, even though we are currently unable to offer you a position.

We will delete your personal data as soon as it becomes clear that an offer of employment will not be made to you or is not accepted by you, unless we believe that you might be suitable for other future open positions and you have not objected to this, or unless we need to retain your personal data for the preparation, filing or defense of legal claims.

How We Obtain Your Personal Data

NEXTERS, as Data Controller, collects, processes and uses the personal data you submit through the following channels: Website, Job Boards, LinkedIn, recruitment agencies/search firms and Careers Fairs, for the purposes of processing your application as further described below.

We may collect information from publicly available sources, such as LinkedIn and Facebook, and from other social media platforms if necessary to perform the job you apply for and provided we are allowed to do so by national laws.

As further described below, we collect personal data from you in connection with your job application with NEXTERS and NEXTERS recruitment process, which includes the following:

  • - Name, address, telephone number, e-mail address, and other contact information;
  • - Work authorization status;
  • - CV, cover letter, previous work experience, and education information;
  • - Knowledge, skills, abilities, and preferences, including learning agility, aptitude, and working style and preferences;
  • - Professional and other work-related licenses, permits, and certifications held;
  • - Referral names and contact information for referrals;
  • - Information relating to character and employment references;
  • - Information related to your browsing and email actions, which may include Internet protocol (“IP”) addresses, browser type, referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics), operating system, date/time stamp, and/or clickstream data; and
  • - Any other information you elect to provide to us (e.g., employment preferences, willingness to relocate, current salary, desired salary, awards, or professional memberships).

NEXTERS may collect this information in a variety of ways, including from application forms, CVs, identity documents, third parties (such as for references or background checks, or from recruiters), or through interviews or other forms of assessment.

If we ask you to provide any other personal data not described above, then the personal data we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect it.

How We Use Your Personal Data

NEXTERS uses your personal data for the purposes of carrying out its job application and recruitment process. Such uses include:

  • - Assessing your skills, qualifications, and interests against our career opportunities and determining your suitability for employment;
  • - Deciding whether to offer you a job;
  • - Verifying your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job;
  • - Communications with you about the recruitment process and/or your job application(s), including, in appropriate cases, informing you of other potential career opportunities at NEXTERS;
  • - Recommending potential career opportunities based on your skills, qualifications, and interests;
  • - Creating and/or submitting reports as required under any applicable laws or regulations;
  • - Making improvements to NEXTERS’ job application and/or recruitment process, including improving diversity, equity, and inclusion in our recruitment practices;
  • - Fulfilling the purpose for which you provide it;
  • - Complying with applicable laws, regulations, legal processes, or enforceable governmental requests; and/or
  • - If you are offered and accept employment with NEXTERS, the personal data collected during the job application and recruitment process may become part of your employment record.

If we need to process your personal data for an incompatible purpose not discussed in this Privacy Notice, we will provide notice to you and, if required by law, seek your consent. We may process your personal data without your knowledge or consent only where required by applicable law. NEXTERS does not subject you to automated decision-making.

EMPLOYEES OF PARTNERS

During interactions, preliminary discussions, etc. We may collect personal data about employees, directors, authorized signatories, or other individuals associated with Nexters corporate customers, business partners, and vendors. For the purpose of this Privacy Notice it is assumed that the Partner acts as a data controller and NEXTERS as a data processor or in the respective role under applicable Data Protection Laws.

In these activities, we may receive (either from you directly or from a Partner acting as data controller) the following types of data:

  • - name;
  • - job title;
  • - work address;
  • - corporate email address;
  • - telephone number;
  • - any other information you elect to provide to us.

PROVISION OF DATA TO THIRD PARTIES

NEXTERS is an international game development company with operations around the world. When you use the NEXTERS Services, your personal information may be processed anywhere we or our partners do business, including the United States, provided that adequate technical and organizational measures are in place to ensure the security of your personal information.

To provide the Services, we may provide the Data to suppliers or agents working on our behalf. We do not sell your personal data to third parties. We may disclose the Data to third parties that provide a service to us, ensuring that they are contractually obligated to keep your personal data confidential and will comply with the GDPR and other relevant data protection laws.

We may share your information with the following types of third parties:

  • a) technical and customer support providers who assist us in the provision of the Services,
  • b) third party software providers, including ‘software as a service’ solution providers, where the provider hosts the relevant personal data on behalf of Nexters;
  • c) analytical services that help us develop and improve the Project;
  • d) providers that help us generate and collate reviews in relation to our offers and Services;
  • e) advertising and promotional agencies and those organizations or online platforms selected by us to carry out marketing campaigns on our behalf and to advertise their own products or services that may be of interest to you; and/or
  • f) professional advisers such as solicitors, accountants, tax advisors, auditors, and insurance brokers;
  • g) service providers that assist us in providing our services.

We may share your personal data with our affiliates and partners in the EU / EEA and outside the EU / EEA. If the transfer of data outside the EU / EEA is not regulated by an EU Commission sufficiency decision, we base on the legal guarantees set out in Article 46 et al. Seqq. GDPR. This mainly includes EU Commission-approved Standard Contractual Clauses, which we have strengthened with additional security measures such as additional individual risk assessment, additional contractual guarantees, and technical guarantees, including additional encryption or pseudonymization, to enable international transfers with NEXTERS affiliates and partners outside the EU/EEA.

Learn more about the EU Commission's approved Standard Contractual Clauses.

We may share personal data with external providers or service providers or providers whom we engage to perform services or functions on our behalf and in accordance with our instructions.

If these providers are established within the EU, we ensure that they are contractually bound to comply with EU data protection regulations. We also guarantee in our contracts with these organizations that they only process personal data in accordance with our instructions and provide consistent services and protect the integrity and confidentiality of your personal data entrusted to them. We may also disclose personal information to our advisers, consultants, law enforcement and other government agencies (such as tax and social security authorities), police, prosecutors, and courts. All these recipients are themselves responsible for complying with EU data protection regulations.

Some of the suppliers we work with are located outside the European Economic Area. If the EU Commission has not recognized them as providing adequate protection of personal data, we rely on the legal guarantees described above.

The companies specified in the list may access and process your data in accordance with their own privacy policies, being an equivalent Data Controller. We encourage you to review their privacy policies to learn more about how they process data.

We may disclose your personal data as permitted by law to investigate, prevent, or act regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Policies and (or) Terms of Use or other agreements, or as required by law.

Please feel free to contact us for additional information on third country data transfers as well as our safeguards and supplementary security measures.

DATA SECURITY AND PROTECTION

NEXTERS respects the confidentiality of your data and strives to ensure the highest level of protection. Despite the measures we are taking to protect your information, any measures that we apply will not have any effect if you neglect the data security.

The project implemented reliable means of protection to ensure the security of your data. We do everything possible for your safety when using the Project and are constantly improving our information protection methods. As some means of protecting information from unauthorized access, alteration, disclosure or destruction, we use the following methods:

  • - data encryption during storage and transmission;
  • - we carry out two-stage user authentication when requesting an action with the Data;
  • - we improve the techniques and methods of collecting, storing and processing the Data;
  • - access to the Data, in encrypted and impersonal form, have only authorized employees, consultants or interested groups of people who need access to this information to perform their duties;
  • - all persons having access to the Data are briefed on working with data, their knowledge and skills are systematically being checked.

In spite of all measures taken by us, your careful attitude to the Account and access to it has a great importance in the safety of your Data. To prevent unauthorized access to your Data and Account, we strongly recommend you not to share access to the account to any third parties and to comply with the rules of the project and use of the Services. In case of your violation of the Terms of Use of the Services, we will not be able to guarantee the security of your Data.

DATA MANAGEMENT

You have all the technical capabilities to determine how the Data shall be used. We are constantly improving the data management methods available to you.

For exercising your rights, you can:

  • - at any time withdraw your consent for Data Processing;
  • - access to your Data received by us. You are entitled to access the Data about you received by us which means you have the right to request the provision of information about Data storage, access to Data, as well as copies of the stored Data;
  • - require limitation of Data processing for the time required to verify the reliability of the information provided;
  • - change the Data. You may discretionary determine the Data, which shall be associated with your Account.
  • - object to the processing of your Data. If you believe that we have no legitimate reason for processing your Data, please contact us using email: privacy@gdev.inc. If we fail to satisfy your claim, you have the right to file a complaint with the local supervisory authority.
  • - delete Data related to the Account.

FULL NAME AND CONTACT DETAILS OF THE AUTHORIZED DATA PROTECTION MANAGER FROM NEXTERS INC:

Personal Data Specialist

3101, Cyprus, Limassol, 55 Griva Digeni

Email: privacy@gdev.inc

If your consent expires or is withdrawn or canceled, we will delete the data processed on the basis of your consent, unless there is any other basis for processing them in order to achieve other data processing objectives outlined in this Privacy Notice. Note that as a result of deleting your data associated with the Project, you will no longer have access to the Services.

LOCAL LEGISLATION

We provide you with access to international Services and strive to comply with applicable local laws. Please note that our Services are provided "as is" and you should get to know with applicable laws. By continuing your use of the Project, you are warrant that your use of the Project is not contrary to the applicable law and Terms of Service.

Please note we do not sell users’ Personal Data in California. Data transfer is carried out in order to provide the Services legally.

FINAL PROVISIONS

We reserve the right to modify this Privacy Notice at any time, so please review it on a periodic basis.

This Privacy Notice is made in English language. In case of any inconsistency or discrepancies between a non-English translation of this Privacy Notice and the English version, the English version shall prevail.

FAITHFULLY YOURS,

NEXTERS INC.