Skyforge Privacy Policy for Consoles

Skyforge Privacy Policy for Consoles

Version October 1, 2024

This Privacy Policy describes how Innova Co. S.à r.l. (“Innova” or “we”) processes the personal data we collect about you when you use our services and applies to the game Skyforge (hereinafter referred to as the "Game"), available for download, installation, or use through third-party digital distribution platforms, including but not limited to PlayStation Store; Nintendo eShop; Xbox Games Store (hereinafter referred to as the "Platform" or "Third-Party Platform").

Please read this Privacy Policy carefully, and note that our practices and the data we collect may differ depending on which Platform you use to access the Game and how you use our Services.

Please keep in mind that the privacy policy of the Platform from which you have downloaded the Game may set its own rules for users’ data processing when using the respective Platform. The Platform is independently responsible for such processes.

This Privacy Policy available at https://eu.4game.com/legal/skyforge/249/ (hereinafter referred to as the "Website") is presented in its most recent version. If we decide to amend this Privacy Policy, we will update this text and the date of its publication and make a respective notice available on the Website (as defined below). Still, we ask you to check the updates from time to time.

Please notice that all links to the websites in this Privacy Policy are effective as of the date hereof. We bear no responsibility in the event of their amendment after the date hereof.

Contents

SECTION 1. GENERAL INFORMATION 

SECTION 2. PERSONAL DATA CONTROLLER’S DETAILS 

SECTION 3. CHILDREN’S PRIVACY 

SECTION 4. HOW WE RECEIVE YOUR DATA 

• A. When we receive data from you
• B. When we receive data automatically
• C. When we receive data from third parties

SECTION 5. YOUR DATA WE COLLECT 

• A. Data we may receive from you personally
• B. Data we may receive from you automatically
• C. Data we may receive from other sources (inter alia, automatically)

SECTION 6. BASIS FOR OUR PROCESSING YOUR DATA 

SECTION 7. PURPOSES WE USE YOUR DATA FOR 

SECTION 8. HOW WE MAY SHARE YOUR DATA 

• A. Data storage partners
• B. Game developers and rights holders
• C. Anti-cheat and anti-fraud companies
• D. Innova’s Business partners
• E. Innova’s subsidiaries and affiliates
• F. Change of Control
• G. Additional cases, when we may share information

SECTION 9. HOW LONG WE STORE YOUR PERSONAL DATA 

• A. Correspondence
• B. Device-related data
• C. Game-related data

SECTION 10. PERSONAL DATA TRANSFERS

SECTION 11. AUTOMATED DECISION-MAKING 

SECTION 12. YOUR RIGHTS CONCERNING OUR PROCESSING OF YOUR PERSONAL DATA 

• A. Right of access
• B. Right to rectification
• C. Right to erasure (“right to be forgotten”)
• D. Right to object
• E. Right to data portability
• F. Right to complain to the supervisory authority

SECTION 1. GENERAL INFORMATION

This Privacy Policy describes what personal data we collect about you, how we use this information, and how you can contact us. In particular, we provide you with the following information:

• reasons for our processing your personal data;
• what is the purpose of our processing your personal data;
• your rights concerning our processing of your personal data;
• how long we store your personal data;
• whether we transfer your personal data to other recipients and categories thereof;
• whether we transfer (intend to transfer) your data to other countries;
• whether we carry out automated decision-making or profiling.

When we refer to the «Website» we mean the Website https://eu.4game.com/, and our other websites and services, that link to this Privacy Policy. 

Depending on the rules of the relevant Platform, the User acknowledges and accepts this Policy when uploading, downloading the Game through such Platform or in any other way, including by visiting the Website via the link https://eu.4game.com/legal/skyforge/249/.

We may occasionally update this Privacy Policy. When we do, we will revise the "last updated" date at the top of the policy. We will use reasonable efforts to notify you either by posting a notice available in the Game and/or on the Website. Still, we ask you to check the updates from time to time.

Please note that by clicking on the link https://eu.4game.com/legal/skyforge/249/ you are visiting the Website that uses cookie technology. Cookies are stored when you access the Website to make it work efficiently. The terms and conditions of collection and storage of cookies collected when you visit the Website are governed by the separate Privacy Policy at https://eu.4game.com/legal/4game/7/ and Cookies and tracking policy of the Website at https://eu.4game.com/legal/4game/152/ .

This Privacy Policy covers only our activities with respect to your personal data and does not apply to activities of third parties, whom we do not own, control, and/or to whom we do not issue mandatory instructions. Therefore, if you wish to disclose your personal data to such third parties, including, in connection with the use of the Platforms, please make sure, you have read and understood their policies on personal data processing and that you agree with such. Here we also would like to specifically mention, that we bear no responsibility for privacy practices of the Platforms and third-party websites, that are linked to or from our Website. 

If you do not understand, how we process your personal data or wish to make inquiries in accordance with the General Data Protection Regulation (available via the link: https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1566480551844&uri=CELEX:32016R0679, hereinafter, the “GDPR”), please contact us using the details in Section 2 below.

SECTION 2. PERSONAL DATA CONTROLLER’S DETAILS

Innova Co. SARL (hereinafter, “Innova”, “we”, “us”) is in the terms of the GDPR the controller of the personal data we process unless we precisely state otherwise.

To contact us on any matters related to this Privacy Policy, or other privacy issues, please use any of the below means at your convenience:

• e-mail: privacy@inn.eu
• via post: Innova Co. SARL

16 RUE ERASME, L-1468 Luxembourg

Should you have any inquiries, related to the Game, please contact our support team here: eu.support@4game.com 

SECTION 3. CHILDREN’S PRIVACY

The Game is not intended for children under the age of 13 and when advertising our services, we do not target children. Use of the Game by children requires prior parental control and permission. We do not knowingly obtain the personal information of children under 13 years. 

If you are under the age of 13, please do not use the Game and the Website, do not download the Game, do not provide any of your information to us, and/or post any of your information on the Game and the Website. If we learn, that we have unintentionally received personal data of a child under the age of 13, we will delete that data. 

Should you believe, that we collected the personal data of children through the Game or the Website or that the child posted his data in the Game without relevant parental consent, please contact us, so that we can promptly delete irrelevant data and take all the necessary steps. However, please note that in certain cases such requests may not result in the complete deletion of such data (e.g. if another user of the Game or the Website has reposted such content on third-party resources).

SECTION 4. HOW WE RECEIVE YOUR DATA

Please note, that Section 4 tells you, how we obtain your data. In Section 5 below you will find further detail on the particular information we collect about you. 

A. When we receive data from you

We receive most of the personal data we process directly from you when you:

• file a request, inquiry, and/or complaint with us; contact our support team or approach us otherwise;
• wish to participate and/or participate in the online/offline event and/or promotion we can organize;
• subscribe to our e-newsletters (if applicable).
• download, upload, access the Game, or use our Services;
• visit the Website, use our forums and/or chats. Please note that when visiting our Website and using our forum, data is collected and processed in accordance with the separate Privacy Policy of the site at https://eu.4game.com/legal/4game/7/ ;
• publish any content on our forums and/or official groups within the social networks (facebook.com, Twitter) and other online resources (i.e., Twitch, Discord, or YouTube channels, etc.)

Your privacy and security of your data are very important for us, this is why we address your attention to the fact that some of our features, through which you provide your data, are automated and/or provide free text fields, and, therefore, we may not determine, whether you provided us with incorrect or sensitive data. Therefore, we kindly ask you to be careful, when you submit your data and not to share with us any sensitive personal data. If you feel a need to correct or delete your data, please do not hesitate to contact us in accordance with Section 2 and Section 12 hereof.

We want to warn you, that when you use forums and/or chats, the information you share therein, may become public or, sometimes used by other persons in a way, you might not be aware of (e.g., he may resend your message to someone else or when you are messaging to someone, who is streaming the gameplay right at that moment). Thus, please pay particular attention to the information you share with others. We also ask you not to share your personal data or the data which may personally identify you, as well as such data on third parties, including, via the Website.

Moreover, the Website may contain links to third-party resources, which Innova does not operate. Although we do our best to provide links only to safe resources, that respect your privacy, we bear no responsibility for an approach to content, security, and privacy within such third-party resources. Therefore, please familiarize yourself with the privacy policies and terms of use available therein.

B. When we receive data automatically

We collect certain information automatically, in particular when you when you download/install the Game on your Device.

C. When we receive data from third parties

In certain cases, we can obtain information about you indirectly, including from third parties. This might happen if any of the below scenarios is in place:

• we received a complaint from another user of the Game, which refers to you;
• because you download or access the Game through the Platforms, they may provide us with information to facilitate your access to and use of the Game. This typically includes information like your User/Online ID, and information, which helps us facilitate your gameplay and track your progress in the Game.
• we receive respective information from public authorities, regulators, and/or law enforcement bodies (e.g., in the event we receive an inquiry from them, that concerns you, etc.);
• we may receive certain data on you in order to provide you with in-game items or other types of benefits if you participate in loyalty programs from our partners.

Please note that if you contact us by email or other means, we cannot foresee, whether you will use such contact to disclose the personal data of some third party. Should you choose to do so, please be advised that you will be treated as an independent data controller in respect to such third-party personal data. Therefore, you should be subject to respective responsibilities and obligations, stipulated by applicable laws, including, inter alia, your obligation to indemnify us against any requests, complaints, and claims, including those for compensation of damage, caused to a third party, whose data you disclosed to us. Moreover, because we do not receive such personal data directly from the ones, to whom it is attributed (but we receive such data indirectly from you), it is you, who shall obtain consent from such affected third parties prior to any disclosure of their information to us. In case you have no explicit consent from third parties for disclosure of their information, please make sure, you are fully compliant with other grounds for such use of the personal data, as required under the applicable laws.

SECTION 5. YOUR DATA WE COLLECT

We collect the data about you, as listed below. Please note, that we do not process special categories of personal data (“sensitive data”). Innova does not collect sensitive data in relation to your racial and ethnical origin, biometric data, health data, your political, religious or philosophical beliefs, trade union membership, genetic, health or sex life or sexual orientation, as well as other personal data that is sensitive to fundamental rights and freedoms.

A. Data we may receive from you 

• your nickname, email (if applicable), date of birth, avatar, reviews, comments, and details on your preferences and interests (depending on the Platform through which you download and use the Game);
• your data, which we receive from you in order to process your inquiries/requests/claims and/or to provide you with support services (such data may vary and may include, for example, your name and surname, contact data, email, gameplay data, the reason why you approach us, devices you use for accessing the Game, your account data, data on your in-game characters and progress, etc.);
• your data, that you provide in order to participate in our online and/or offline events, workshops, meetings, conferences, and/or promotions or loyalty programs (including, inter alia, your name and contact data, your image, information you provide to confirm you are eligible to participate, winner’s data, which is needed to get the prize, data on your use of the promotions or loyalty program, data on your preferences and interests, etc.);
• data on your use of the Game (e.g., account settings, preferences, etc.);
• feedback you give us, as well as user-generated content, created by you, when using the Game.

B. Data we may receive from you automatically

• game identifier such as User/Online ID;
• information about your connection to the Game (IP address of your Device, parameters of your network channel, Internet connection, Internet service provider, traceroute information between your device and servers of Innova, crash/errors data, date and time of your use of the Game, information about your activities in the Game, such as data on clicks, scrolling, browsing times and other standard server log information, etc.);
• information about your use of the Game (your game's preferences, progress in the Game, playtime, as well as information about device settings, your in-game character activities, logs and data on in-game transactions, log files (information on the actions made by the character in our game generated by the software, fixed in symbolic non-personal form), contents of in-game chats (correspondence), etc.).

C. Data we may receive from other sources (inter alia, automatically)

• data on you, which may be contained in the complaint of another user, inquiries of public authorities, regulators, and/or law enforcement bodies.

Please note that when you make in-game purchases in the Game, we do not collect or have access to your payment information. Innova does not collect and process any payment information, we do not collect or process financial transaction number, the amount of the transaction number, card number and issuer, your billing address, payment system user ID, payment date and time, and other data that the payment system/agent may require you to provide in order to process your payment.

This information is collected and stored by the Platform and/or the operator of the Platform's payment system from which you access the Game.

SECTION 6. BASIS FOR OUR PROCESSING YOUR DATA 

We process your data pursuant to the GDPR and other applicable legislation, where the basis for our processing is as follows:

SECTION 7. PURPOSES WE USE YOUR DATA FOR

In particular, we process your data as referred to above (individually and/or combined with other data we receive in accordance with this Privacy Policy) for the following purposes:

• to provide you the Game and Services, e.g., so that you can download and run the Game, the Game Client, and use the Game otherwise (e.g., to provide game access to you, to save progress in the Game, etc.);
• to contact you in relation to your use of the Game, including, inter alia, amendments in our policies and legal documents, or when we send you notifications related to your account security;
• to identify you and provide you with necessary support (e.g., when we need to communicate with you on your support tickets, on security issues, etc.);
• to handle your claims, requests, inquiries and/or complaints, and communicate with you otherwise;
• to ensure your participation in the online or offline events and promotions we organize, including, inter alia, to arrange your receipt of prizes, your travel, etc.;
• to provide you with in-game offers, that you may be interested in;
• to run our business, to improve the Game, to fix bugs, develop new tools, and products, to provide you with new features within the Game;
• to investigate, handle, and prevent improper use of the Game, violations of terms of use of the Game, fraud, cheating, and in-game violations, for example, data on the organization of game process and information about in-game character activities, game data and commands, the log files, content of in-game chats (correspondence) may be used by Innova for decisions to ban a game account or a character;
• to organize the game process and enhance the security, confidentiality, and safety of your game account (if applicable), e.g. against unauthorized access and disclosure, including resulting from hacking and hacker attacks and/or fraudulent access, to restore access the Game, restore lost in-games items, etc.;
• your IP address and other online identifies are used to determine your approximate geographic location, to prevent illegal use of the Game, should we have reasonable concerns, that there is a risk to the security of Innova’s servers (e.g., blocking of concurrent IP addresses);
• to comply with legal obligations that Innova is subject to (e.g. our obligations to keep certain information under tax laws, etc.);
• for the purposes of the legitimate and legal interests of Innova or a third party (e.g. the interests of our other users), except where such interests are overridden by your prevailing legitimate interests and rights;
• we may use your data to create user segment data and create aggregated and anonymous statistics on user’s use of the Game, which we may share with third parties pursuant hereto;
• to combine together personal data that we may obtain from different sources, as mentioned above, inter alia, to create a single or several databases.

We may also use your data for other purposes, not mentioned herein, only based on your prior consent.

SECTION 8. HOW WE MAY SHARE YOUR DATA

Please note, Innova does not sell, including rent, release, disclose, disseminate, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means, the personal information of the Users that we collect to any third party for monetary or other valuable consideration.

However, in order to perform our obligations, we may share your data with the following categories of third parties:

A. Data storage partners: 

User data is stored using third-party data storage services, using the services of data centers in Luxembourg (Tier 4 data center in Luxembourg), Netherlands, and in the United States and on servers provided by our cloud service providers. 

Please note that we store data from UK, EU, EEA, or Switzerland users using data center services in Luxembourg, Netherlands.

If you reside in the UK, EU, EEA, or Switzerland, we rely on Standard Contractual Clauses and/or other approved legal mechanisms to transfer personal information from the UK, EU, EEA, or Switzerland to countries located outside of these locations (as applicable).

B. Game developers and rights holders: 

we may share non-personally identifiable information publicly and with our partners — like developers or rights holders. This information includes as a minimum your use of the Game. It may also include your progress in the Game, achievements you have completed, your multiplayer game matchmaking information, in-game items, and other information needed to analyze, improve, and fix game-related issues. We pseudonymize data to reach the only goal of enhancing the Game;

C. Anti-cheat and anti-fraud companies: 

we may decide to share the information required for our detection, investigation, and prevention of cheating, fraud and other prohibited acts in the games with anti-cheat, and anti-fraud companies only for the purposes mentioned herein;

D. Innova’s Business partners: 

We may provide your data to business partners with whom we jointly offer Services, including the companies that provide the Platform through which you access the Game;

E. Innova’s subsidiaries and affiliates: 

as a global company, we collect information that may be processed in our offices worldwide. Your information may also be processed outside of the European Economic Area, e.g. in the Russian Federation, or any other country in which we, our affiliates, or subsidiaries maintain presence. Personal data collected is treated confidentially and is used only by Innova or Innova’s affiliate where Innova falls within the category of the controller of personal data and its affiliate – the processor of a part of the personal data. When your personal data is shared with Innova’s affiliates and subsidiaries, Innova guarantees an adequate level of personal data protection, including but not limited to concluding standard data protection clauses adopted by the European Commission with Innova’s affiliates and subsidiaries, as well as such third parties;

F. Change of control: 

we may share your data as part of our company’s sale, merger, or change in control, or in preparation for any of these events. Any entity which buys us, or part of our business will have the right to continue using your data, but only in the manner set out in this Privacy Policy;

I. Additional cases, when we may share information:

• information about the user’s in-game activities, logs, and data on in-game transactions, as used for game violations detections  in order to prevent or punish cheating and unfair game, may be disclosed to such user unless disclosure will compromise the mechanism through which we detect, investigate and prevent such violations;
• without the user’s consent the data may be disclosed in cases, required by law, for example, upon the request of the competent authorities, public entities or bodies, our auditors, banks, and other competent parties, acting based on the European Union or respective Member State law;
• when we defend and/or enforce our rights (including those of our affiliates) or in the event of litigation between Innova and the user or in case Innova receives a request from the competent authority. Data on the organization of the game process, information about the user’s in-game character activities, logs and data on in-game transactions, game data, and commands, log files (information on the actions made by the character in the game, generated by the software, fixed in symbolic non-personal form), as well as the content of in-game chats (correspondence) can be combined with the personal information user provides and further disclosed to the court or competent authority;
• should you participate in our events and/or win prizes, in order to arrange your travel and/or prize delivery we may share your necessary contact data with our travel and logistics partners (or instruct you to do so yourself);
• we may use third-party services to send you emails (if applicable).

SECTION 9. HOW LONG WE STORE YOUR PERSONAL DATA

Innova stores data and information during the time periods specified below or until receiving your request to erase personal data if there is no legitimate reason to keep it longer. Upon expiry of the terms for storing your personal data, we will delete it, unless we need to keep certain data due to requirements of applicable laws or during the period this data is necessary for establishment, exercise, or defense of legal claims. 

Please note that data, that you shared with others (for example, in the in-game chats, etc.) may remain visible even after your account is deleted, as we cannot control data, that other users copy when using the Game. 

A. Correspondence: 

Innova keeps records of correspondence with the User, including support tickets along with other communications, for the validity period of agreements between you and Innova for use of the Game and 1 year after the termination of such agreements, unless there is a legitimate reason for a longer processing.

B. Device-related data: 

We store the following data if gathered, no more than for 1 year from the moment agreements between the User and Innova for use of the Game are terminated:

• data on the user’s IP address and other online identifiers of his devices and applications;
• the date and time of the user’s visit, information about the user’s activities on the game services;
• other standard server log information.

C. Game-related data: 

Innova stores the following data for the 1 year from the moment it is collected: data for organization of the game process, information about your in-game character activities, logs, and data on in-game actions, game data and commands, log files (information on the actions made by the character in the Game generated by the software, fixed in symbolic non-personal form), the content of in-game chats (correspondence). If the data indicates that a violation has occurred, we will further store the data for the establishment, exercise, or defense of legal claims during the applicable statute of limitations or until a legal case related to it has been resolved. 

However, it shall be noted, that if access to the Game has been banned, such data is stored for 3 years after we reveal the violation unless there is legitimate ground for a longer processing. In case of a dispute with the user, log files, chats are stored during the period of the dispute. In the event of litigation between Innova and the user or in case Innova receives a request from the competent authority, such data can be combined with the personal information the user provides and stored during the period of resolution of the dispute.

SECTION 10. PERSONAL DATA TRANSFERS

Your personal data are stored and processed otherwise using the services of data centers in Luxembourg (Tier 4 data center in Luxembourg), the Netherlands, and in the United States. Your information may also be processed outside of the European Economic Area, namely, in the Russian Federation by our affiliate or in the United States by the Game’s rights holder in accordance with our Privacy Policy. 

Should your personal data be shared with Innova’s affiliates and subsidiaries or rights holder, Innova guarantees an adequate level of personal data protection, including but not limited to entering into Standard Contractual Clauses approved by the European Commission with Innova’s affiliates, subsidiaries, and the Game’s rights holder.  

Innova applies necessary safeguards to ensure the protection of the rights of personal data subjects. In particular, any and all information sent to us is encrypted (scrambled) via the Secure Socket Layer (SSL) technology. We also implement technical and organizational measures to protect users’ data:

• within Innova, we limit access to personal data (i.e., only the personnel, whose access to your data is necessary to run our business, is allowed to access it);
• specific measures for data minimization to incorporate clear retention periods for personal data;
• using anonymization or pseudonymization techniques, and other electronic, physical, and procedural safeguards, as applicable in the industry;
• ways to allow the data subject to express his or her point of view and contest the decision; and,
• a mechanism for human intervention in data processing.

SECTION 11. AUTOMATED DECISION-MAKING

Please be kindly advised, that as per Article 22 of GDPR, we do not make decisions based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

SECTION 12. YOUR RIGHTS CONCERNING OUR PROCESSING OF YOUR PERSONAL DATA
 

Please be advised, that in order to exercise your rights, stipulated in this paragraph, you can approach Innova using the below contact details: 

Innova Co. SARL

16 RUE ERASME, L-1468 Luxembourg

e-mail: privacy@inn.eu

You have the following options with respect to the data, that we process:

• Access your data: you are entitled to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided;
• Opt-out of Innova processing your information: you are entitled to withdraw the consent, you gave us to process your data;
• Delete your personal data: you can file a request with us to delete all or certain parts of information about you, that we process;
• Correct and amend your data: please feel free to contact us, should you discover, that your data is inaccurate or incomplete;
• Object, limit or prohibit our use of your data: you can approach us with a request to fully or partially stop using your data or limit such use.

Please find below further details on your rights:

A. Right of access

You have the right to obtain (i), information about your personal data that we hold, including the purposes of the processing, the categories of personal data concerned, the recipients of the personal data, storage periods, and (ii) a copy of the personal data undergoing processing.

B. Right to rectification 

In the case of processing personal data, we shall endeavor to ensure by implementing measures to keep it accurate and up-to-date for the purposes for which it was collected. In case your personal data is inaccurate or incomplete, you can change the information you provided by contacting Innova via the details indicated in Section 12. 

C. Right to erasure (“right to be forgotten”) 

You have the right to request a deletion of your personal data. Deletion of your data will lead to loss of access to the Game, you will also lose game-related information, including, data about your progress in the Game.

The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

Please be advised that you have the right to obtain from us the erasure of your personal data without undue delay, where one of the following grounds applies (unless processing is necessary pursuant to Article 17(3) of GDPR, when the below provisions shall not apply to the extent that processing is necessary):

• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• you withdraw consent on which the processing is based according to point (a) of Article 6(1) and where there is no other legal ground for the processing;
• you object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of the GDPR;
• the personal data have been unlawfully processed;
• the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which Innova as the controller is subject;
• the personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of GDPR.

In some cases, considering the complexity and number of the requests, the period for personal data erasure may be extended, but not for more than two additional months.

D. Right to object 

When our processing of your personal data is based on legitimate interests according to Article 6(1)(f) of the GDPR, you have the right to object to this processing in accordance with Article 21 of the GDPR. If you object we will no longer process your personal data unless there are compelling and prevailing legitimate grounds for the processing as described in Article 21 of the GDPR; in particular if the data is necessary for the establishment, exercise or defense of legal claims. 

E. Right to data portability 

You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller without hindrance from us. In exercising your right to data portability pursuant hereto, you are entitled to have the personal data transmitted directly from us to another controller, where technically feasible. Please be aware that the exercise of the right to data portability shall be without prejudice to the right to erasure (right to be forgotten). Moreover, your right to data portability shall not apply to processing necessary for the performance of a task carried out in the public interest, as well as such right shall not adversely affect the rights and freedoms of others.

F. Right to lodge a complaint with the supervisory authority

Should you have any complaints about our compliance with this Privacy Policy and/or applicable legislation, please do not hesitate to contact us. We will carry out all the necessary checks and will do our best to resolve the dispute timely and in accordance with relevant regulations.

Pursuant to Article 77 of GDPR, without prejudice to any other administrative or judicial remedy, you shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes GDPR.

Please be kindly advised that according to the laws of Luxembourg (the country where Innova as the controller is incorporated), effective as of the date of this Privacy Policy publication, it is the National Data Protection Commission (Commission Nationale pour le Protection des Données, the “CNPD”), which acts as the data protection supervisory authority. Please use the following contact details, should you desire to approach the CNPD:

Commission nationale pour la protection des données

15, Boulevard du Jazz

L-4370 Belvaux

Tel.: (+352) 26 10 60-1

website: https://cnpd.public.lu/en.html (details for lodging complaints can be found, inter alia, via this link: https://cnpd.public.lu/en/support/protection-des-donnees.html#reclamations).