GDPR Privacy Notice to EU Residents

Effective Date: September 8, 2021

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this GDPR Privacy Notice, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Company will be the controller of your Personal Data processed in connection with the Services.

Where applicable, this GDPR Privacy Notice is intended to supplement, and not replace, the Company’s Privacy Policy at https://www.game.tv/privacy.html (the “Privacy Policy”). If there are any conflicts between this GDPR Privacy Notice and the Company’s Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this notice or whether any of the following applies to you, please contact us at [email protected].

What Personal Data Do We Collect From You?

We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

Information we collect directly from you:

We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:

• Email address
• User content, for example, comments, posts, or decks you submit publicly, photographs you upload (which can include Personal Data if you include Personal Data in such content)
• Nick name and avatar

In the event you are selected as a winner of a tournament we run on the Services, we receive the following Personal Data directly from you when you provide us with such Personal Data:

• First and last name
• Mailing address
• Telephone number
• Your photograph

Information we receive from third party sources:

Some third parties such as our affiliate ad networks, business partners, and service providers provide us with Personal Data about you, such as the following:

• Account information for third party services: If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services (e.g., Discord, Line, Google, Facebook Connect, or Twiter), or if you share content from our Services through a third party social media service, the third party service may send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service.

Information we automatically collect when you use our Services:

Some Personal Data is automatically collected when you use our Services, such as the following:

• IP address
• Unique device identifiers or synthetic anonymous IDs
• Web browser information
• Application activity such as app upload, app download, app installation, app uninstallation, app start, app play duration, app stop, app crashes, app network activity and app resource consumption
• Transaction information (e.g. transaction amount, date and time such transaction occurred, Purchase transaction history)
• Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.) -- For more information, please review our Cookie Policy (here).
• Location information (country-level only)
• Log data (e.g. access times, hardware and software information)
• Device event information such as crashes, system activity and hardware settings
• System configuration information; metadata concerning your Android apps
• Other interactions with the Services and third party advertisements

How Do We Use Your Personal Data?

We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:

• Create and manage user profiles
• Communicate with you about the Services
• Contact you about Service announcements, updates or offers
• Provide support and assistance for the Services
• Personalize website content and communications based on your preferences
• Analyze how you use the Services and personalize, provide, and improve our services
• Meet contract or legal obligations
• Respond to user inquiries
• Fulfill user requests
• Comply with our legal or contractual obligations
• Resolve disputes
• Protect against or deter fraudulent, illegal or harmful actions
• Enforce our Terms of Service
• Provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, as well as we, can provide you with an optimal online experience

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

• Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service or other agreement with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
  • Your sign-up contract information, such as your email
  • Your account data, such as your nickname, and avatar
  • Your contact information you provided to us on the purchase orders, insertion orders, or other documents, such as name, address, email address, and telephone
• Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
  • End user analytics data, such as synthetic anonymous ID
  • Customer support data, such as Mac address, IP address, location data (country-level only), and email address
  • Game or application related data, such as name of app/game, package name, version, time at which application was installed / uninstalled, search string, application click information
  • Cost-Per-Install revenue, In-App-Purchase spend, conversion information
  • Tournament data, such as tournaments played, created and registered
  • Tournament winner data, such as first name, last name, mailing address, telephone, and photograph
  • Internal contractor records, such as first and last name, mailing address, email, telephone, date of birth, location, and banking information

  Examples of these legitimate interests include:

  • Operation and improvement of our business, products and services
  • Data analytics and personalization of web and services content
  • Marketing of our products and services
  • Provision of customer support
  • Detection and protection from fraud or security threats
  • Compliance with legal obligations
  • Completion of corporate transactions
  • Internal Administration
• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

How and With Whom Do We Share Your Data?

We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:

• Payment processors
• Fraud prevention service providers
• Ad networks
• Analytics service providers
• Staff augmentation and contract personnel
• Hosting service providers
• Co-location service providers
• Telecommunications service providers

We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:

• Third party business partners who you access through the Services
• Shipping and logistics companies
• Other parties authorized by you

We also share information with third parties when you have given us consent to do so (as indicated at the point such information is collected).
We also share Personal Data when we believe it is necessary to:

• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
• Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
• Maintain the security of our products and services

Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.