Confidentiality Policy
Confidentiality Policy
We respect the privacy of your personal data and ask you to familiarize yourself with this Confidentiality Policy (hereinafter the “Policy”). This will help you learn what information and for what purposes we process in connection with your use of www.coding-farm.net and the Game and how you can change, delete or otherwise influence the processing of your personal data.

The Policy has been developed and the processing of personal data is carried out in accordance with Regulation (EC) 2016/679 of the European Parliament and of the Council of the European Union (hereinafter GDPR), the recommendations of the Working Group on Data Protection under Article 29 of the GDPR and the European Data Protection Board, Children's Online Privacy Protection Rule. Your personal data will be processed in accordance with the laws applicable to you within the scope described in this Policy.
Please read and make sure you understand this Policy. If you do not agree with this Policy, please discontinue further use of the site.

Who processes personal data
GBL Academy Limited Liability Partnership
  • Address: Republic of Kazakhstan, Taras Shevchenko Str., 4/1
  • Telephone: +77056697813
  • Authorized email address: cio@gbl.academy
The indicated person processes your personal data and is hereinafter referred to as “GBL”, “we”.

The terms we use

Personal data
means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Conset
means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

Data controller
means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

Data processor
means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

Data processing
means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Third party
means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

Personal data breach
means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;

Recipient
means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

Supervisory authority
mean one or more independent public authorities provided by each Member State which is responsible for monitoring the application of the GDPR in order to protect the fundamental rights and freedoms of natural persons in relation to processing and to facilitate the free flow of personal data within the European Union;

Supervisory authority concerned
means a supervisory authority which is concerned by the processing of personal data because:
  • the controller or processor is established on the territory of the Member State of that supervisory authority;
  • data subjects residing in the Member State of that supervisory authority are substantially affected or likely to be substantially affected by the processing; or
  • a complaint has been lodged with that supervisory authority;

Restriction of processing
means the marking of stored personal data in order to limit their processing in the future
Terms not defined in this section shall be interpreted in accordance with the terms of the User Agreement posted on the internet

What data we process and for what purposes
In the table below we tell you which data we process and for what purposes:

Purpose of personal data processing

Amount of personal data processed
Registration on the website and in the game
  • email address
  • telephone number
  • age
  • gender
  • grade level
  • all the data that appear in the accounts of the following services: Facebook, Google, Apple, Clever (if registering through a social network or other electronic service)

Identification on the Site and in the Game
  • full name
  • email address
  • telephone number
Establishing and maintaining communication between you and GBL
  • full name
  • telephone number
  • email address
Maintaining the user's progress (development) on the Site and in the Game
  • email address
  • generated user device identifier
Collecting statistics, improving the user experience and upgrading the Site and the Game
  • gender
  • age
  • generated user device identifier
  • user geolocation data (country, region, city)
  • user device data (operating system, device model, screen resolution)
  • the number of times the application is run
  • the user's actions in the app.
  • Cookies





GBL does not process any special or biometric personal data of Users.


We collect some information automatically whenever you interact with the Site and the Game. GBL automatically collects and processes the following information
  • Your IP address;
  • unique device identifier;
  • browser characteristics, device characteristics;
  • type of operating system;
  • language preferences;
  • actions taken on the Site and in the Game;
  • the pages requested and the dates and times of visits to the website.
Cookies are usually used for this purpose.

In addition to your explicit consent to the processing of personal data that you give when you register on the Site and in the Game, the following situations are the legal grounds for processing:
  • processing is necessary for the execution and conclusion of a contract between you and GBL;
  • processing is necessary to comply with a legal obligation GBL;
  • processing is necessary to protect your vital interests or those of another individual;
  • processing is necessary for the purpose of securing a legal interest of GBL or a third party, unless such interests override your interests or fundamental rights and freedoms.


GBL always respects your rights and will take them into account when processing personal data using the above-mentioned legal grounds. You can send us your objections to this processing at any time. However, you are cautioned that the sending of the objection may influence GBL's ability to provide access to the Site and the Game for your benefit.


If you use the Site or the Game, we are obliged to process your personal data for the following purposes:
  • Registration in the Game and on the Site;
  • Identification in the Game and on the Site;
  • Saving the User's progress (development) in the Game;
  • Gather statistics, improve the user experience and upgrade the Game and the Site.

If you refuse to process personal data for these purposes, GBL will not be technically able to provide you with access to the Game and the Site.

Processing your personal data for the legal interest of GBL or a third party means that we may process your personal data in the following situations:
  • complying with legal obligations to prevent fraud, control the theft of your data and otherwise protect our customers and our business;
  • complying with applicable law, assisting law enforcement, supervisory and judicial authorities;
  • carrying out research, including focus groups, which aim to improve our company's performance and level of service.


GBL may process the following personal data for this purpose:
  • background (full name; age; gender, nationality);
  • technical data (IP address; technical Cookies; actions taken on the website; operating system; date and time of the visit to the website);
  • contact details (email address; telephone number).



In some cases, we use the following tools to collect and process the above-mentioned personal data:
  • Google Analytics and Google AdWords (Google LLC.). 1600 Amphitheatre Parkway Mountain View, CA 94043, United States of America
  • Facebook pixel (Facebook Inc.). 1601 Willow Road Menlo Park, CA 94025, United States of America
  • Intercom (Intercom R&D Unlimited Company), Ireland, 2nd Floor, Stephen Court, 18-21 Saint Stephen's Green, Dublin 2
  • TikTok Pixel TikTok Inc.: 10100 Venice Blvd., Culver City, CA 90232 , USA
  • Dev2Dev (Dev2Dev LLC). Antakalnio g. 17, LT-10312 Vilnius, the Republic of Lithuania
  • AppsFlyer (AppsFlyer Ltd). 100 1st Street, Floor 25 San Francisco, CA 94105, United States

We do not collect personal data in advance or store it for potential future purposes unless required or permitted by applicable law.

How we process cookies
The Site, its subdomains and the Game use cookies. We process anonymous data in order to improve the user experience and upgrade the Site and the Game.

Cookies are small text files that are stored on the User's device after viewing the fragments of the website.


The use of cookies enables us to monitor the availability of the Game and Site, analyze data and understand how to develop our products. We process the following types of cookies:

  • technical cookies: they are necessary for the correct operation of the Site and the Game. Such cookies enable the detection of hardware and software on the User's device; the detection of operational errors; and the testing of new features to improve performance. The processing of technical cookies does not require consent;
  • analytical cookies: they allow counting the number of users; determining what actions users take (pages visited, time and number of pages viewed). Analytical data is collected through partners, including Google Analytics;
  • advertising cookies: they help to analyze from which sources a user has clicked and to personalize advertising messages. The processing of your personal data in this way is only possible with your separate consent.




The length of time that cookies are stored depends on the specific type, but in any case no longer than necessary to achieve the purpose of processing personal data. When you visit the GBL website, GBL asks User for their consent to the use of cookies. To stop processing cookies, the User can change the settings of the browsers used on all devices (computer, mobile devices) or withdraw their consent to the processing of cookies at any time.


If you refuse to use cookies, certain features of the Website and the Game may not be available, which will influence your ability to use them.



How do you consent to the processing of personal data
You agree to the terms of the Policy and give GBL your consent to process your personal data for the above purposes if you:

  • register online at www.coding-farm.net or in the Game by filling in the registration form and ticking the box to agree to the processing of personal data. Consent is deemed given when registration is completed by pressing the “Register”, “Continue” or similar button;
  • log on to the Site or the Game using social media or other electronic services available for authentication on the Site or in the Game. Consent is deemed to have been given at the moment of clicking on the button displaying the social network or electronic service selected for authorization and entering the service's authentication details;
  • you enter or change information in the “Personal Information” or similar section on the Site or in the Game. You decide how much personal information you want to see in the Personal Information section.
  • tick the box to agree to receive newsletters and promotional material when you register on the Site by filling in the registration form. Consent is deemed given at the time of application by pressing the “Register”, “Continue” or similar button.


By agreeing to the terms of the Policy and amending its settings, you give us your informed and knowing consent to process your personal data on the terms set out in the Policy and applicable law. In doing so, we proceed from the following:

  • You have provided completely accurate information. GBL does not verify its authenticity. All the risks of providing inaccurate or insufficient information lie with you;
  • You have the right to give appropriate consent or act with the consent of your legal representative in accordance with applicable law.

You can withdraw your consent to the processing of personal data at any time. To do this, you will need to make a request to support@gbl.academy. Withdrawing your consent to the processing of personal data may affect our ability to provide you with access to our products. We will notify you of this impossibility and arrange for further action.


Personal data of other people that you provide to GBL
There may be a situation when you register on the Site or in the Game not for yourself. Then you are most likely providing us with another person's personal data.
In this case you are solely responsible for ensuring that the person or persons whose personal data you have provided is aware of, understands and agrees that GBL is processing their data in accordance with the Policy.
Personal data processing and security

We may do the following with your personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer, depersonalization, blocking, deletion, destruction.

GBL undertakes to process only such personal data as is directly relevant to the purpose of its processing and collection and to the extent necessary to fulfill the relevant purpose. We will not process it using the methods and for the purposes incompatible with the purpose of collection. We take reasonable steps to ensure that personal data is accurate, complete, up-to-date and processed in accordance with the defined purposes for which it was collected.

We store your personal data on electronic media.
GBL follows proper security procedures and takes all necessary measures to prevent unauthorized access to and misuse of personal data. Nevertheless, we ask you to understand that technically the Site and the Game function “as is”, and that no security system is perfect. If we become aware of a security breach, we may either publish a notice or try to notify you by email and take reasonable steps to rectify the breach.


We have appropriate corporate systems and procedures in place to protect and safeguard the personal data you provide to us. Only employees with special rights are authorized to access personal data in the course of their duties.

The retention period is due to our duty to ensure that you are able to use our services, the need to resolve disputes that may arise in the use of our products and for other purposes that enable us to carry out our statutory activities, including the detection and prevention of fraudulent or other illegal activities, and the requirements of applicable law.

We will in any case stop processing your personal data if any of the following events occur:
  • You have withdrawn your consent to the processing of personal data or asked us to destroy it;
  • the retention period for personal data has expired;
  • the purposes of processing personal data have been achieved or are no longer necessary. In this case personal data is processed until your profile on the Website and the Game is deleted and for a period of 3 years from that date (the maximum period stipulated by the limitation period of the agreement).


Children's privacy
We are committed to protecting the privacy of children who use our Site and the Game.
GBL assumes that you are a legally capable person capable of giving consent to the personal data processing in accordance with applicable law and we do not collect personal data directly from a child under the age of 13. However, whilst children may use the Site and the Game, we presume that children act with the approval and consent of their legal representatives.


If we find out that we have collected personal data directly from a child under the age of 13 without the consent of its legal representative, we will take measures to delete such personal data as soon as possible.

Transmission of data to third parties
The main purpose of GBL processing of personal data is to ensure that we fulfill our obligations to you. Sometimes this requires the involvement of third parties. The amount of data transmitted is determined by the terms and conditions of the contracts we have entered into with such third parties.
But there are other purposes for which your data (name, surname, patronymic; telephone number; e-mail address) may be passed on to third parties:
  • increasing the speed with which we send you information and promotional messages (provided you have consented to the sending of such messages);
  • keeping you informed of new educational and development opportunities.
If at some point you realize that our messages have become irrelevant or not interesting to you, you can easily refuse to receive them by sending a corresponding request to the following email address
We carefully select third party partners to whom we may entrust your personal data (only to the extent permitted by this Policy).

In our contracts with third-party partners, we therefore specify the obligations of partners to respect your interests in the personal data processing. Thus, third-party partners guarantee:

  • the confidentiality of personal data when processed and used;
  • compliance with the following measures to ensure the security of personal data during its processing: use of information security measures; detection and recording of unauthorized access to personal data and taking measures to restore personal data; restriction of access to personal data; recording and accounting of actions with personal data; control and evaluation of the effectiveness of applied measures to ensure security of personal data; processing of data in the scope and in the manner appropriate to the purpose of its collection;
  • that third parties do not have the right to pass on and distribute your personal data to others.



We collect your data directly and do not transfer your data across borders.
User requests
GBL is always open to any requests you may have.
If you have a question, query or request regarding your personal data, the easiest way is to email us at support@gbl.academy.

In order for us to recognize you immediately, the email shall be sent from the email address you provided when you registered on the Site or in the Game.
You can send us requests to delete your personal data. Please note that we may need to retain certain information for the purposes of enforcing GBL legal interests. For example, to fulfill our legal obligations to law enforcement and other public authorities.


Furthermore, you are entitled to object to the processing and to ask us to stop processing your personal data and/or to stop sending you advertising messages.

You are entitled to ask us to restrict the way we process personal data in certain circumstances. In particular, this reason includes changes and updates to your information. GBL undertakes to limit the processing of your personal data in this case.
You can request your personal data from us in a structured, machine-readable and widely used format. In particular, you can request to transfer such information to another data processing operator without impediment.
We will promptly review your request to access, amend or delete your personal data and will respond within ten (10) working days of receipt of the request, in any event.

If we receive a report from you about unauthorized processing of personal data, we will block such information at the time we receive the report and until all the circumstances of the processing have been clarified.
We will unsubscribe you on the day we receive your request.

Upon receipt of your withdrawal of consent to the processing of personal data, we will stop processing and will destroy the personal data being processed within the legally prescribed period, and in any event no later than ten (10) working days from the date of receipt of the request.
If for any reason you do not agree with any of our decisions regarding the processing of your personal data, you have the right to appeal to any competent national privacy authority in accordance with the law applicable to you.
Changing the Policy
GBL is entitled to amend this Policy at any time. As a rule, all these changes are related to bringing the Policy in line with changes in legislation or functional features of the service and are aimed at ensuring even greater protection of the rights of personal data subjects.

We undertake not to make any material changes to or impose any additional encumbrances or restrictions on your rights set out in this Policy without notification to you.
GBL will notify you when there are changes to the Policy and ask you to read the new version. Notification of the change can be displayed on the site (e.g. through a pop-up window or banner) or can be sent by email. By continuing to use our service, you agree to the updated Policy.