This policy aims to protect personal data of the various stakeholders connected to our organization. This policy is aimed at providing individuals notice of the basic principles by which the company processes the personal data of individuals who visits, uses, deals with and/or transacts through the website and/or our mobile applications, and includes a guest user and browser (hereinafter 'you', 'user').
Purpose and Scope
The purpose of this policy is to describe how GGNation collects, uses, and shares information about you through our online interfaces (e.g., websites and mobile applications) including but not limited to https://ggnation.com (referred to herein as the "Website") and GGNation mobile application(s) (hereinafter collectively referred to as "Platforms") owned and controlled by us. This policy is also designed to provide information on how GGNation ensures data security, conducts data transfers and processes requests from data subjects.
This policy control applies to all systems, people and processes that constitute the organization's information systems, including board members, directors, employees and other third parties who have access to personal data available within GGNation.
Types of personal data collected by us
The personal data that we collect about you depends on the context of your interactions with us, the products, services and features that you use, your location, and the applicable laws.
Personal data is stored in personnel files or within the electronic records (on servers in India) of GGNation. The following types of personal data may be held by the Company, as appropriate, on relevant individuals:
Personal Identification Data
- First Name, Last name
Bank Account information
Numbers on credit card / debit card
Unified Payment Interface Data
Date of Birth
Electronic Identification Data
Login credentials (If you are registered user)
Visitors IP Data
Data and time of website visit
Pages visited and navigation on the website
Browser being used
County of accessing website
Language of the browser being used
Words searched for
Personal data stated in any form – for example: Name, address, phone number, country
Subject of Inquiry
Personal details (Name on the card, billing address)
Payment details (card numbers, card type)
Information about your interactions with customer service and maintenance interactions with us.
Your preferences in receiving marketing information from us
Your communication preferences
- Data inferred or assumed information relating to your behaviour and interests based on your online activity on our sites
Any financial data / sensitive payment data collected by us, will be processed by us to the extent permitted and in manner specified under applicable law. By submitting your credit or debit card account information through our Services, you expressly consent to the sharing of your information with our partners, third-party payment processors, and other third-party service providers (including but not limited to vendors who provide fraud detection services to us and other third parties).
Special Categories of Personal data
Special Category of personal data to includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade unions memberships, information about your health and genetic and biometric data.
We do not collect or process any special or sensitive personal data.
Should we specifically require "special" or "sensitive" personal data in connection with one or more of the uses described below, we will request your explicit consent to use the data in accordance with this policy and/or in the ways described at the point where you were asked to disclose the data.
If you voluntarily share with us or post/upload any "special" or "sensitive" personal data to this Website for any other reason, you consent that we may use such data in accordance with applicable law and this policy.
Sources of data collection
The data collected by the company is derived directly from the data provided by the user or by use of our sites.
<u>Data Collected from You</u>:
- Register yourself by creating a user account
- Register for various events or any other outreach initiatives made available by us or our Partner's
- Request a quote for the various products and services offered by us
- Place feedback, complete any customer surveys circulated or interact with our customer services online
- View our services or visit our website pages on the internet
- Browse our website
- Access or use GGNation Mobile Applications
<u>Data Collected from third parties</u>
We receive personal data such as access or login details, profile picture or any other text / image in relation to your personal data which may be available with such third parties.
We also receive information about your visits to this platform and to other websites using pixel tags.
Third parties from whom we receive your personal data include, our service providers, other networks connected to our service, our advertising partners, our marketing and advertising affiliates, our partners, analytics providers and such other third-party sources. Some of the third-party sources from where we collect personal data includes:
- TrueCaller SDK
Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.
Furthermore, we may allow third-party advertising companies (such as Facebook, Google, Twitter, Quora and Bing) to place cookies on our website. These cookies enable such companies to track your activity across various sites where they display Ads and record your activities, so they can show Ads that they consider relevant to you as you browse the Internet. These cookies store information about the content you are browsing, together with an identifier linked to your device or IP address.
- To recognize our website user and to enhance user experience when interacting with our website
What types of cookies do we use?
There are a few different types of cookies, however, our website uses:
- <u>Session Cookies:</u> Session Cookies are temporary and deleted from your machine when your web browser closes. We use session Cookies to help us track internet usage as described above.
- <u>Analytical/Performance Cookies:</u> Analytical cookies allow us to recognise and count the number of visitors and see how many visitors move around our website while they are using it. This helps us improve the way our website works, for example, by ensuring the users find what they are looking for.
- <u>Functionality Cookies:</u> Functionality Cookies recognise when you return to the website. This enables the company to create greater content for you and remember your likes and dislikes and other preferences.
- <u>Targeting Cookies:</u> Targeting Cookies records the visit to our website, the pages navigated to and the links clicked upon. It helps to formulate information relevant to the user's area of interests.
How to manage cookies?
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. Disabling some cookies form the website, may have a negative impact and may result in some non-availability of some features.
If you want to remove previously stored Cookies, you can manually delete the Cookies at any time. However, this will not prevent the Sites from placing further Cookies on your device unless and until you adjust your Internet browser settings.
These opt-out mechanisms rely on cookies to remember your choices. If you delete your cookies, use another computer or device, or change browsers, you will need to repeat this process. In addition, opting out of interest-based ads will not opt you out of all ads, but rather only those ads that are personalized to your interests.
We use Google Analytics and Segment Analytics to measure how visitors interact with content on our Site and to track events. We also use Facebook Custom Audiences to ask Facebook to show you ads that are customized based on your interaction with our websites or our Facebook applications and to measure how you interact with those ads. Additional information on how these services use such technologies can be found on Google's website, Segment website and Facebook's website.
If you do not wish to have data relating to your visits to our websites collected through Google Analytics, you may opt-out by installing the Google Analytics opt-out browser add-on. You may opt-out of Facebook Custom Audiences by visiting Facebook's opt-out page.
Aggregated Data means records that have been stripped of Personally Identifiable Information and has been manipulated or combined to provide generalised, anonymous information. Your identity and personal information are not available in Aggregated Data. We combine your personal data on an anonymous basis with other information to generate aggregated data for internal and commercial use and for sharing with affiliates, subsidiaries and business partners for planning and marketing purposes.
Data protection principles
Where third parties process data on behalf of GGNation, we ensure that the third party takes such measures in order to maintain the Company's commitment to protecting data.
We understand that it will be accountable for the processing, management and regulation, and storage and retention of all personal data held in the form of manual records and on computers.
All personal data obtained and held by the Company will:
- Be processed fairly, lawfully and in a transparent manner
- Be collected for specific, explicit, and legitimate purposes
- Be adequate, relevant and limited to what is necessary for the purposes of processing
- Be kept accurate and up to date. Every reasonable effort will be made to ensure that inaccurate data is rectified or erased without delay
- Not be kept for longer than is necessary for its given purpose
- Be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
- Comply with the relevant laws and procedures for international transferring of personal data applicable to us.
We may obtain your consent to collect and use certain types of personal data when we are required to do so by law.
Once consent is obtained from the individual to use his or her information for those purposes, GGNation has the individual's implied consent to collect or receive any supplementary information that is necessary to fulfil the same purposes. Express consent will also be obtained if, or when, a new use is identified.
Consent may also be implied where a user is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, and the client, customer, member does not opt-out.
Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), individuals can withhold or withdraw their consent for GGNation to use their personal information in certain ways. Individual's decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist you in making the decision.
If you refuse or withdraw your consent, or if you choose not to provide us with any required personal data, we may not be able to provide you the services that can be offered on our Platform.
Purpose of Collecting Personal Data
We collect your personal data for the following purposes:
To fulfil or meet the reason you provided the information;
We use your information for managing and processing purposes, including, but not limited to, tracking usage, progress and other details in relation to the gaming event you are part of. GGNation may use certain information collected from you in order to verify your identity or to monitor your performance during your usage of our services to confirm that you are abiding by the applicable rules or requirements as may be applicable;
To send you updates about the Programs, other GGNation events, platform maintenance or new services provided by GGNation, among other things, through itself or through third parties, via email, SMS, phone call or any other medium;
Provide Chat Room services;
To enhance the quality of our content and service offerings;
Providing information to relevant external authorities for tax, social security and other purposes as legally required;
Conducting surveys to assess your satisfaction, including but not limited to its processes or policies;
Setting up and maintaining accounts and subscriptions with third parties that provide information and research services or communication services;
Making decisions about your continued engagement or membership;
Dealing with legal or regulatory disputes or investigations involving you, our work, or other partners, employees, workers and contractors, including accidents at work, potential and actual negligence claims and professional discipline matters;
To monitor use of our information and communication systems to ensure compliance with our IT and document management policies;
To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution;
Business management and planning, including accounting, auditing and insuring;
Planning or reviewing options in relation to the operation or management;
Keeping registers required by law or regulation;
Communicating with you, for example to respond to inquiries;
Enhancing the safety and security of the services and preventing fraud, or protecting our or our customers', or your rights or property;
Enforcing applicable terms and conditions and other applicable policies;
Recognize your devices and associate the information with your profile including
- using data collected or received from service providers, advertisers, and other third parties, such as your device information, to match mobile advertising and cookie identifiers;
- matching your devices if you log into the same online service on multiple devices or web browsers or if your devices share similar attributes that support an inference that they are used by the same user or household;
- using this information to match your interests across devices, as well as for analytics, ad serving or reporting, or to improve the services;
- Identifying you or your device or associated information with you, your device, or your profile whenever you visit the GGNation Service, even if you do so when logged out or without intentionally identifying yourself.
Advertising and Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or if you provided us with your details and expressly consented to receiving that marketing.
We may use your Identity, Contact, Electronic, and User generated Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.
We also enter into agreements with third parties to serve Ads on our behalf across the internet, social networking sites and blogs. These third parties may collect personal data about your visits to our platform and your interactions with our products and use this information to target advertisements for goods and services.
Where electronic direct marketing communications are being sent, you have the option to opt-out in each communication sent, and this choice will be recognised and adhered to by us.
Disclosure of personal data
GGNation is a global company and may share the personal information collected or provide such access to other companies within the GGNation group.
Examples of third parties with whom GGNation may share personal data includes:
With government bodies, including tax and social security authorities, to comply with applicable laws (including employment and tax laws), to obtain licenses or approvals, and upon request during an audit or assessment;
With suppliers, subcontractors and service providers, to maintain an efficient and commercially viable business, including technology, telecom, internet providers;
With professional advisers, consultants, and employment and recruitment agencies, to conduct background verification and reference checks, administer benefits and payroll, deal with disciplinary and grievance issues and maintain emergency contact details;
With our legal advisors and external auditors for legal advice and to conduct business audits;
With service providers for business continuity management and contingency planning in the event of business disruptions.
With certain companies in order to establish a membership to participate in digital wallets, payment services or rewards programme
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Our Policy on Children's Data
As a general policy, our company does not engage in the collection, processing, storage, use, dissemination, and transfer of personal data of children below 13 years unless consent has been obtained from their parents or legal guardians.
GGNation will ensure that appropriate technical and organizational measures are in place, supported by privacy impact and risk assessments, to ensure a high level of security for personal data, and secure environment for information held both manually and electronically.
GGNation implements appropriate security measures designed to prevent unlawful or unauthorized processing of personal information and accidental loss of or damage to personal information such as Access Control, Password protection and encryption, log management etc.
GGNation maintains written security management policies and procedures designed to prevent, detect, contain, and correct violations of measures taken to protect the confidentiality, integrity, availability, or security of your Personal Information. These policies and procedures assign specific data security responsibilities and accountabilities to specific individuals, include a risk management program that includes periodic risk assessment and provide an adequate framework of controls that safeguard your personal information.
In addition, as part of its organizational security measures, at GGNation:
- We ensure that all files or written information of a confidential nature are stored in a secure manner and are only accessed by people who have a need and a right to access them
- We ensure that all files or written information of a confidential nature are not left where they can be read by unauthorised people
- We check regularly on the accuracy of data being entered into computers
- We always use the passwords provided to access the computer system cautiously and such access should not be circulated, unless absolutely necessary
- Personal data should not be kept or transported on laptops, USB sticks, or similar devices, unless authorised by [insert details]. Where personal data is recorded on any such device it should be protected by:
- We ensuring that data is recorded on such devices only where absolutely necessary
- We using an encrypted system — a folder should be created to store the files that need extra protection and all files created or moved to this folder should be automatically encrypted
- We ensure that laptops or USB drives are not left lying around where they can be stolen.
- Failure to follow the Company's rules on data security may be dealt with via the Company's disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on the severity of the failure.
We also take steps to ensure that our service providers, contractors and other third parties maintain similar levelsof data protection measures when processing your personal data. While we strive to secure your personal data, please note that 100% security of personal data cannot be guaranteed and that GGNation shall not be liable for any misuse or loss of personal data carried out by third party service provider(s).
International data transfers
Our website is primarily operated and managed on servers located and operated within India. However, in some cases, your personal data may also be stored in third party data servers located in other countries when GGNation engages these third parties for business purposes and further processing of your data.
GGNation engages sub-contractors, service providers and other third parties for facilitating our products, service offerings and to offer support services to you, and your personal data may be transferred to servers of such sub-contractors, service providers and other third parties. Depending upon the location of our service providers, your information, including personal data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.
Further, your personal data may be transferred and may be shared, disclosed and transferred between various GGNation group companies where such transfers are required for legitimate business reasons.
Where required under applicable law we will seek your express consent for such transfers. In all other cases, by consenting to this policy, you also provide consent to GGNation to transfer your personal data to GGNation affiliated companies, service providers or any third-party entity in locations around the world. We take steps to ensure that a degree of data protection which is similar to this policy is afforded to such personal data transferred.
Where GGNation transfers your personal information internationally, we will comply with applicable legal requirements
Further as the Company takes steps to ensure that transfers of personal data to any public authority cannot be massive, disproportionate and indiscriminate in a manner that would go beyond what is necessary in a democratic society. In the event of conflicts between these and public authority requirements, the company will find a practical solution that fulfils the purpose of this Policy.
We are committed to take all steps reasonably necessary to ensure that your data is treated securely and in accordance with our data privacy and security standards.
Conflicts of Law
This Policy is intended to comply with the laws and regulations in the place of establishment and of the countries in which the company operates. In the event of any conflict between this Policy and applicable laws and regulations, the latter shall prevail.
Retention of personal data
We keep your personal data for no longer than necessary for the purposes for which the personal data is collected and processed. The length of time we retain personal data for, depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.
Where a data breach is likely to result in a risk to the rights and freedoms of individuals, it will be reported to the relevant supervisory authority as soon as it becomes possible for the company, after the Company becomes aware of it and may be reported in more than one instalment.
Individuals will be informed directly in the event that the breach is likely to result in a high risk to the rights and freedoms of that individual.
If the breach is sufficient to warrant notification to the public, the Company will do so without undue delay.
External Links on our Website
GGNation reserves the right to change these terms from time to time at its sole discretion and without notice to you. In the case of any violation of these terms, GGNation reserves the right to seek any and all remedies available by law and in equity for such violations.
Updates to this Policy
You can contact us at:
Name: GoodGame Esports Ventures Private Limited
Address: F-302, P No-96, Krishna Colony, Jaipur, Rajasthan, India - 302039
Contact Details: email@example.com