Art Platform Standoff 2 |Privacy Policy

Last updated: 06.05.2025

What is this document about?

1. The purpose of this Policy is to provide users of the Art Platform Standoff 2 service (hereinafter referred to as the «Service») with information on how Axlebolt LTD processes your personal data (hereinafter referred to as the «Policy»). This Policy explains why and how we use your information when you use the Service.
2. By using the Service, including registration, uploading or viewing content, participating in Creative Contests, voting, interacting with other users, or accessing any other functionality of the Service, You or your legal representative (hereinafter referred to as the «User») agree to these Policy and accept the Policy in full.
3. By using the Service, you also agree to the Terms of Use and the Creative Contest Entries and Rules.

Who we are

4. We, Axlebolt Limited, are the controller of your personal data, i.e. we independently determine the purposes and means of processing your personal data. Axlebolt Limited (Axlebolt Ltd) was established and operates in accordance with the laws of the Republic of Cyprus, registration number HE 409660, registered at: Christodoulou Chatzipavlou, 221, Helios Court, office/apartment 401, 3036, Limassol, Cyprus («Axlebolt», «we», and derivatives).

Changes to the Terms of the Policy

5. The Policy, placed at https://art.standoff2.com/docs/privacy_policy_en.html, is published on this page in the most up-to-date version. We may unilaterally make changes to the Policy in order to comply with, among other things, the latest changes in applicable legislation. All changes will take effect immediately after publication. We will make every effort to ensure that the User is notified of the Policy update, but we ask you to check this page regularly for updates to the current version of the Policy.

Definitions

6. Some of the definitions used in this Policy have the following meanings:

1. Contact Information is information that the User can share with Axlebolt to obtain reference information and contact the support team, marketing offers, and notifications, as well as to comply with legislation. In order to fulfill our obligations, provided by Terms of Use, said information may include, at the discretion of User, an email address, telephone number, social networks accounts.
2. Personal data is information or data of any kind that allows an individual to be identified, including Contact Information and Anonymized Analytical Data.

1. Information on activities – depersonalised information about the User's activities on the Service, used for analytical and advertising purposes.
2. Information on device – technical information about your device, including information about the browser and types of browser plug-ins, operating system and operating system version, network information, device type and producer, language set for the device, IP address and other technical information.
3. Game – a mobile game application under the general title STANDOFF2, available for devices running the iOS and Android operating systems. Please note that processes of Personal data processing in the Game are not covered by this Policy and are described separately in the Game Policy https://standoff2.com/ru/privacy-policy.html
4. Creative Contest - an event organized within the Service, in which Users can submit their Creative Content under specified conditions, with winners determined based on criteria set by Axlebolt in accordance with Terms of Use.
5. Cookies - text files generated by the by the website hosting the Service and stored on User’s computers without any changes or processing, as well as other similar technologies. We process technical (necessary for the functioning of the Service) Cookies based on our legitimate interest in servicing it. We also process session (necessary for convenient use of the Service) and analytical Cookies (necessary to improve the quality of our services). Cookies can also be used to ensure the security of the data collected and the Service as a whole.
6. Anonymized analytical data is analytical anonymized information about the User's actions on the Service, the collection and processing of which is aimed at improving the quality of our services. Anonymized analytical data may be obtained, among other things, through Cookies.
7. Applicable legislation refers to legal provisions on the protection of Personal data and confidentiality of which you are a subject according to your location or other legal criteria.
8. Cross-border transfer refers to the transfer of data to a foreign state's territory to an individual or legal entity for the purposes of data processing, including for storage purposes.
9. Finance information - the User's bank details, including the bank account details, the name and TIN of the payment recipient, the correspondent account, the BIC and the name of the bank, the bank card number, if applicable, which the User provides in the event of winning the Creative Contest.

What Data, for What Purposes, on What Grounds, and How Long We Process It

7. We process the following information related to Users:

• Contact information (if the User registers on the Service to use it or contacts Axlebolt support);
• Financial information (if the User has received a cash prize and applied for the payment);
• Information on device (if the User uses the Service);
• Cookies: technical, session and analytical (if the User uses the Service);
• Login and password, game ID (unique player number in the Game) for access to the Service and the Creative Contest;
• Avatar (any image at the discretion of the User, if the User expresses a desire to use an avatar. We do not check the avatar's compliance with your real photo and do not limit the use of any image if such an image does not violate the rights of third parties).

8. We try to minimize the collection of Personal data and do not collect additional information about you.
9. In order to process User data, we obtain consent in accordance with the Policy. The User has the opportunity to revoke consent at any time or request the deletion of any information we have collected, but in this case we will be forced to restrict access to some functions of the Service, including access to your personal account.

Minors’ Personal data processing

10. Due to the nature of our services, we may inadvertently collect Personal data from minors under the age of 18. If you are a minor, please make sure that your parent (legal representative) has read and understood the provisions of this Policy. This Policy is accepted and confirmed by the minor's legal representative on behalf of the minor. If you are a minor and are unable to inform your legal representative of the provisions of this Policy, or if you (your legal representative) do not agree with the terms of this Policy, immediately cease further use of the Service.

11. If a legal representative allows a minor to use the Service, we assume that said legal representative has read and understood this Policy, as well as accepted the Policy on behalf of the minor.
12. We further assure you that we do not deliberately collect Personal data from Users under 18 years of age, since the Service is intended for a wide audience and is focused on a wide range of legally capable individuals.

Where Did We Get Your Data From?

• From you (from communication, including from completed forms)
• From Cookies and other similar technologies installed by our Service in your browser.

Who Can We Share Your Data With?

13. We do not transfer your Personal data to third parties without your express consent, unless the transfer of such data is required by law in accordance with applicable legislation.
14. We may provide and use anonymized analytical data so that we can learn more about our visitors and about the effectiveness of the actions we take to attract interest in our Service and related services, as well as the quality of our business projects.
15. Taking into account the above, the following categories of Personal data may be transferred to the following third parties:

16. Additionally, if you win the Creative Contest, we will transfer your financial information to the banking organization to make the payment, as well as to the tax authorities, if such an obligation is required by applicable law.
17. We can also disclose information that you provide us to respond to subpoenas, requests, notices, court orders, requests from public authorities in any proceedings, as well as to exercise our rights.
18. We can also disclose your information to defend ourselves against legal claims if we think that information should be disclosed for the purposes of protection of our rights, your safety or safety of other persons, investigation of fraud, or in response to any request from public authorities.
19. We can transfer your information to investigate, prevent, or take actions with respect to illegal actions, alleged fraud, and situations associated with potential threats to the physical security of any person, or as otherwise required by law.

Automated Solutions

20. We do not use automated decision-making, and we do not use your data to automatically assess aspects of your personality (automated profiling, etc.).

Cross-Border Transfer and Data Storage Location

For residents of the Russian Federation:

21. We guarantee that the Personal data we collect from Users located in the Russian Federation is stored and updated on servers located in Russia in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data".
22. Axlebolt may transfer Personal data outside the Russian Federation for the fulfillment of its obligations strictly upon receipt of direct consent for the transfer to certain persons and in compliance with the requirements for notifying the relevant government body.
23. Cross-border transfer of Personal data is limited by law in relation to countries that cannot ensure the same level of data protection as Russian law, except in cases where such transfer is carried out for the performance of an agreement with the data subject or with his written consent.
24. We also want to assure you that your data is safe, and our partners adhere to high standards of data protection, as do we. We undertake to transfer your Personal data abroad using only all necessary security mechanisms to protect your data, including data encryption.

For residents of the European Economic Area (EEA):

25. Personal data of Users located in the EEA is processed in accordance with the GDPR (General Data Protection Regulation) and stored in Germany.

For residents of other countries:

26. Your Personal data is stored in Germany. If you are located in a territory where your consent is required to transfer your personal information to another jurisdiction, then by using the Service, you give us your explicit and unambiguous consent to such transfer or storage and/or processing of information in other specified jurisdictions.

Data Security

27. We make it a priority to ensure safety of your Personal data. We follow generally accepted standards to protect your information both at the time of transfer and after it is received. However, no method of communication through the internet is absolutely safe, nor may the method of electronic storage be treated as absolutely safe.
28. Though no safety system is completely safe, we take safety measures together with our partners to protect against unauthorized access or disclosure of information collected by us. When it comes to Axlebolt, it includes preventing disclosure of your data unless required and ensuring transfer of all information collected by Axlebolt via protected connections, as well as protection and coding by using the appropriate software so as to ensure unauthorized access protection. Our employees and third parties that get access to your data undertake to maintain the confidentiality of your information.

Your Rights

29. We adhere to the principle of processing Personal data in accordance with the strictest legislation. That is, if we have any doubts about the applicable legislation or if there is no applicable legislation in the country where you are located in, we will apply the strictest possible regulation and take all possible measures to protect your rights. Below we have provided a list of rights for residents of certain countries and regions.

For residents of the European Economic Area (EEA):

30. if you are a resident of the EEA, you have rights under applicable data protection laws, including GDPR. These include, but are not limited to:

• The right of access. You have the right to request and receive a copy of your data at our disposal;
• The right to correction or removal. You have the right to request correction or deletion of your data at our disposal;
• The right to limitation of treatment. You have the right to restrict the processing of your data at our disposal;
• The right to data portability. You have the right to transfer your data (to another controller) at our disposal.
• In certain circumstances, you may also have the right to object to the processing of your data. To send such a request, please use the contact information provided in the Contact Us section. We will review any such request and take action in accordance with applicable data protection laws.
• If we rely on your consent to process your Personal data, you have the right to withdraw your consent at any time. However, please note that this will not affect the legality of your data processing until such consent is revoked.

For residents of the Russian Federation:

31. if you are a Personal data subject from the Russian Federation, then you have the right to ensure the protection of your rights and freedoms when processing Personal data, the protection of your rights to privacy, and the protection of your personal and family secrets. In particular, you have the right to:

• require us, as an operator, to clarify your Personal data, block, or destroy it if your Personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, as well as to take legal measures to protect your rights;
• receive information related to the processing of your Personal data, including: confirmation of the processing of your Personal data by the operator; the legal grounds and purposes of processing your Personal data; the purposes and methods used by the operator for processing your Personal data; the name and location of the operator, and information about persons (except for the operator's employees) who have access to your Personal data or to whom Personal data may be disclosed on the basis of an agreement with the operator or on the basis of Federal Law; processed Personal data related to the relevant Personal data subject, the source of their receipt; the terms of processing of your Personal data, including the terms of their storage; information about the performed or proposed cross-border data transfer; title or full name and address of the person processing your Personal data on behalf of the operator, if processing is entrusted or will be entrusted to such a person; other information;
• protect your rights and legal interests, including compensation for damages and (or) compensation for moral damage in court.

For residents of Brazil:

32. if Brazilian legislation applies to the processing of your Personal data, you have the right to ask Axlebolt for the following:

• confirmation of data processing;
• access to processed data;
• correction of incomplete, inaccurate, or outdated data;
• anonymization, blocking, or deletion of unnecessary, redundant data or data processed in violation of the provisions of the Brazilian Data Protection Act (LGPD);
• the opportunity to transfer data to another service or product provider through a direct request in accordance with the requirements of the National Data Protection Authority (ANPD) taking into account the requirements of commercial and industrial secrets;
• deletion of Personal data processed with your consent;
• information about public and private organizations with which Axlebolt has shared data;
• information about the possibility of withholding consent and the consequences thereof.

33. You can also withdraw your consent to Personal data processing, object to processing carried out on the basis of one of the opt-out situations if there is a violation of the provisions of the LGPD.

For data subjects in the Republic of Turkey:

34. The Personal Data Protection Law No. 6698 ("KVKK") contains the rights of data subjects accessing services from the Republic of Turkey. You have the right to contact the data controller in order to:

• find out if your Personal data is being processed;
• request information about whether your Personal data has been processed;
• find out the purpose of processing your Personal data and whether this Personal data is being used in accordance with said purpose;
• find out the third parties to whom your Personal data is being transferred within the country or abroad;
• request correction of incomplete or inaccurate data, if any;
• request the deletion of your Personal data in accordance with the conditions specified in Article 7 of the KVKK;
• request reports on transactions carried out in certain cases from third parties to whom your Personal data has been transferred;
• claim compensation for damages resulting from the illegal processing of your Personal data.

For residents of California:

35. The California Consumer Privacy Act ("CCPA") grants California residents the following rights:
36. The right of access/information. You have the right to request that we provide you with the following information:

• the categories and specific elements of Personal data that we have collected about you over the past 12 months;
• the categories of sources from which we collect Personal data;
• the business or commercial purposes for the collection, use, exchange, or sale of Personal data;
• the categories of Personal data that we have disclosed about you for commercial purposes and the categories of recipients to whom they have been disclosed;
• the categories of Personal data that we have sold or transferred, and the categories of third parties to whom each type of Personal data has been sold or transferred.

37. The right to removal. You have the right to request that we delete your Personal data under certain circumstances, with some exceptions.

1. The right to correction. You have the right to require us to correct the Personal data we hold about you if you believe it to be inaccurate. We may request the relevant documentation in connection with your request. After receiving and validating a request to correct inaccurate Personal data, we will make all commercially reasonable efforts to correct said Personal data. 
2. The right of refusal.  We do not sell your Personal data. However, in any case, you have the right to opt out of the sale and exchange of your Personal data.   
3. If you wish to opt out of said sale and exchange, other than by using Cookies or other online tracking technologies, you can contact us using the methods listed below in the Contact Us section.
4. The right to non-discrimination. You have the right not to be discriminated against for exercising the rights set out in the CCPA.

Contact Us

5. If you wish to exercise the above rights or contact us for any other reason, please contact us at [email protected]. You can also email us at: Christodoulou Chatzipavlou, 221, Helios Court, office/apartment 401, 3036, Limassol, Cyprus.
6. Please note that in order to fulfill the request, we may require additional information to identify the person who is contacting us. If the provision of said information may violate the rights and legitimate interests of third parties, we may refuse to provide this information.
7. To exercise the rights mentioned above, your request must contain the following information:

• your email address
• information confirming that you are associated with us, or information otherwise confirming that we are processing your Personal data
• your signature, or your representative's signature

45. You can always contact our data protection officer at [email protected].

Contacting Data Protection Authorities

46. For residents of the European Economic Area (EEA): if you reside in the European Economic Area and believe that we are illegally processing your Personal data, you have the right to file a complaint with the local data protection supervisory authority. You can find the contact information here: https://commission.europa.eu/about-european-commission/contact_en.
47. For residents of the Russian Federation: if you believe that your rights are being violated, you can contact the Federal Service for Supervision of Communications, Information Technology, and Mass Media—Roskomnadzor. You can find the contact information via the following link: https://rkn.gov.ru/contacts.
48. For residents of Brazil: if you believe that our interaction with your Personal data violates applicable law, you can submit a request to the Brazilian Data Protection Authority (ANPD).
49. For residents of California (US): if you are a CCPA subject, you have the right to file a complaint with the California Data Protection Agency via their email address: [email protected].
50. For residents of the Republic of Turkey: if you believe that your rights are being violated, you can contact the Personal Data Protection Authority. You can find our contact information here: https://www.kvkk.gov.tr/Icerik/6655/Contact-Us.

Thank you for choosing our services!

Best regards,

The Axlebolt team