Privacy Policy

Privacy Policy

Imperia Online JSC respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Throughout this Privacy Policy the following terms have the following meanings:

“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

“Performance of Contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

“Comply with a legal obligation” means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

“THIRD PARTIES” & “Internal Third Parties”mean other companies in the Stillfront Group acting as joint controllers or processors and provide IT and system administration services and undertake leadership reporting.

“External Third Parties” mean:
- Service providers acting as processors who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
- Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

1. Important Information and Who We Are

  • Purpose of This Privacy Policy

    This privacy policy aims to give you information on how Imperia Online JSC collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service, or take part in a competition.

    This website is not intended for children, and we do not knowingly collect data relating to children.

    It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

  • Controller

    Imperia Online JSC is the controller and responsible for your personal data (collectively referred to as "Company", "we", "us", or "our" in this privacy policy).

    We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below

  • Contact Details

    Our full details are:

    Full name of legal entity: Imperia Online JSC
    Name or title of DPO: Data Protection Officer
    Email address:
    Postal address: 69 Bulgaria Blvd., floor 16, Sofia, Bulgaria

    You have the right to make a complaint at any time to the supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

  • Changes to the Privacy Policy and Your Duty to Inform Us of Changes

    This version was last updated on 01.02.2024. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:

  • “Identity Data” includes first name, last name, username or similar identifier, and title.
  • “Contact Data” includes billing address, delivery address, email address, and telephone numbers.
  • “Financial Data” includes bank account and payment card details.
  • “Transaction Data” includes details about payments to and from you and other details of products and services you have purchased from us.
  • “Technical Data” includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • “Profile Data” includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
  • “Usage Data” includes information about how you use our website, products, and services.
  • “Marketing and Communications Data” includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does “not” directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

For more information on how we use cookies or other information accessed and stored on your device see our Cookie Policy.

3. How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

  • “Direct interactions.” You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
    • apply for our products or services
    • create an account on our website
    • subscribe to our service or publications
    • request marketing to be sent to you
    • enter a competition, promotion, or survey
    • give us feedback or contact us

“Automated technologies or interactions.” As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

“Third parties or publicly available sources.” We may receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from the following parties:
    • analytics providers
    • advertising networks
    • search information providers
  • Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services.
  • Identity and Contact Data from data brokers or aggregators.
  • Identity and Contact Data from publicly available sources.

4. How We Use Your Personal Data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

4.1 Purposes for Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note: The table has been omitted for brevity, but it should detail specific uses of personal data, such as for providing services, marketing, fraud prevention, and improvement of services, along with the corresponding legal basis for each use.

5. Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • Specific third parties listed in the table in paragraph 4 above.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

We share your personal data within the Stillfront Group which involves transferring your data outside the European Economic Area (EEA).

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, you can ask us to delete your data: see your legal rights below for further information.

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your rights

  • Your Entitlements

    Participation and providing your data to us is entirely voluntary. Nonetheless, without this information, we might not be able to offer the Services, or certain functions within those Services might be limited. Using our Services implies we will collect information tied to you, in line with this Privacy Policy and based on the specific Services you engage with and your preferences within those Services. You have various options to manage or restrict how much data is processed. For instance, you may decide against linking your accounts from other platforms with our Services, adjust your device settings to manage or restrict your Advertising ID usage, or block certain or all cookies via your internet browser settings.

    In respect to the handling of your Personal Data, under certain conditions, you have the privilege to enforce the following rights:

  • Access

    You can inquire if we are processing Personal Data about you, gain access to that data, and gather further details such as the purposes of such processing. You are entitled to a copy of the Personal Data being processed. If the request is submitted through electronic means, the information will be provided in a common electronic format unless you indicate a different preference.

  • Correction

    You are allowed at any point to rectify any incorrect Personal Data as well as complete any incomplete Personal Data, taking into account the goals of the processing.

  • Deletion

    You can demand the removal of your Personal Data under specific circumstances, like when it is no longer necessary for what it was originally collected for. We afford you the capability to either delete or adjust your personal data independently within the game. By navigating to your user account settings while logged in, you can remove your personal data.

  • Processing Limitation

    You can request that we minimize the processing of your Personal Data to simply storing it, under certain circumstances, like if you dispute the legality of the processing but do not wish for your data to be removed.

  • Consent Withdrawal

    You reserve the right to withdraw your consent concerning your Personal Data's processing at any point, provided the processing relies on your consent. The withdrawal does not retroactively impact the consent-based processing that occurred prior to the withdrawal.

  • Portability of Data

    You can request a portable, machine-readable format of your Personal Data and have it transferred to a different Controller, where feasible. This applies to Personal Data that is processed with your consent or for the fulfillment of a contract with you, and only to data that you have provided us.

  • Authority Complaints

    You possess the right to file complaints about our processing of your Personal Data with the relevant data protection oversight authority.

10. Objection Right

According to Article 21 of GDPR, you may object to the processing of your personal data, for reasons associated with your unique situation, whenever the processing is based on Article 6(1)(e) or (f) of GDPR; this is applicable to profiling based on those provisions as well. We will halt processing your personal data unless there are demonstrable, compelling, and legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defense of legal claims. If personal data is processed for direct marketing reasons, you may at any point object to the processing of your personal data for such purposes; this extends to profiling insofar as it is connected to such direct marketing. Upon objection to processing for direct marketing purposes, your personal data will cease to be processed for these purposes. You also have the choice, notably in the digital services context, to express your objection through automated means utilizing technical specifications, regardless of Directive 2002/58/EC.

11. Updates to this Privacy Policy

From time to time, we might revise this Privacy Policy to reflect alterations in how we conduct our business or the regulatory requirements applicable to us. Any updates will be posted in this section. Additionally, we will communicate any significant changes to you through other suitable methods, depending on how substantial the changes are.