Privacy Policy
This policy explains how Vivalmi SP collects and processes personal data in connection with the Phylax iG website, console and Service.
Last updated: 13 June 2026
1. Data controller
The controller for personal data processed through Phylax iG is Vivalmi SP. For any privacy matter you can contact us at ivan.novak@vivalmi.com.
2. Data we process
- Account & contact data — name, business email, company and role, provided when you request access or sign in.
- Access-request data — the information you submit in the request-access form, plus source and browser user-agent metadata.
- Usage & technical data — log data, IP address, device/browser information and audit events generated when using the console.
- Integration data — webhook event metadata exchanged with a Customer’s PAM. Phylax iG is designed to avoid processing player personal data and does not hold player funds.
3. Why we process data and legal bases
We process personal data to:
- provide, secure and operate the Service — performance of a contract and our legitimate interests;
- evaluate and respond to access requests — legitimate interests / pre-contractual steps;
- maintain audit logs, prevent abuse and ensure security — legitimate interests and legal obligation;
- communicate with you about the Service — legitimate interests or consent where required.
4. Sharing and processors
We share personal data only with trusted service providers acting as processors under appropriate agreements — for example cloud hosting, database, authentication and email-delivery providers — strictly to operate the Service. We do not sell personal data. Where data is transferred outside the EEA, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses.
5. Retention
We retain personal data only for as long as necessary for the purposes described above, to comply with legal obligations, resolve disputes and enforce agreements. Audit logs are retained for a period consistent with security and compliance needs, after which they are deleted or anonymised.
6. Your rights
Subject to applicable law, you have the right to access, rectify, erase, restrict or object to processing of your personal data, to data portability, and to withdraw consent where processing is based on consent. You also have the right to lodge a complaint with your local supervisory authority (in Slovenia, the Information Commissioner / Informacijski pooblaščenec). To exercise any right, contact us at ivan.novak@vivalmi.com.
7. Security
We implement appropriate technical and organisational measures to protect personal data, including HMAC-signed event delivery, access controls, encryption in transit and audit logging. No method of transmission or storage is completely secure, but we work to protect your data and respond promptly to any incident.
8. Cookies
The website and console use only the cookies and local storage strictly necessary to provide core functionality such as authentication and session management. We do not use third-party advertising cookies.
9. Changes
We may update this policy from time to time. The “Last updated” date reflects the latest revision. Material changes will be communicated where appropriate.
