Last Modified: April 01 ,2019
1. WHO WE ARE
We are Smilegate Entertainment, Inc., a company located at 5F, Solidspace Bldg. 220, Pangyoyeok-ro, Bundang-gu, Seongnam-si, Gyeonggi-do, Korea ("SGE", "us", "we" or "our").
We are the organiser of various eSports tournaments (including but not limited to the Crossfire Stars tournament) (the “eSports Tournaments”), events and associated services such as Creators event.
2. HOW TO CONTACT US
This Privacy Policy explains how we collect, use and protect your personal data in connection with our eSports Tournaments. Respecting and protecting your privacy and your personal data is very important to us.
If you have any questions about this Privacy Policy or our use of your personal data, if you need to report a problem, or if you would like to exercise one of your rights under this Privacy Policy you can contact us using the following contact details:
- Title : Data Protection Officer
- Email : cfs@smilegate.com
For the purposes of applicable EU data protection legislation, we also have a representative located within the European Union. The contact details of our EU representative are set out below:
- Name : KEUSSLER Consulting GbR
- Address : v. Keussler Consulting GbR, partnership, Schepp Allee 47, 64295 Darmstadt, Germany
- Email: privacy_EU@smilegate.com
Please read this Privacy Policy carefully to understand our practices regarding your personal data and how we will treat it.
By visiting our website (www.crossfirestars.com) (the “Websites”), and participating in our eSports Tournaments, you acknowledge the terms of this Privacy Policy and the use and disclosure of your personal data as set out in this policy.
3. HOW WE COLLECT YOUR PERSONAL DATA
We collect personal data about you in the following ways in connection with the eSports Tournaments, events and associated services, including but not limited to Creators event.
Information we collect about you indirectly
We generally collect information about you (including personal data) indirectly through our partner companies (called publishers) who service the eSports games for us in the country where you live. When you qualify or choose to participate in our eSports Tournaments, these publisher companies will provide us with certain personal data about you.
The information we receive is likely to include the following:
• Nickname; In-Game Name; First Name; Last Name; Gender; Nationality; Date of Birth; Passport Number; Passport Expiration Date; Cell phone Number; Email; SNS URL; Skype ID; WeChat ID; Languages Spoken; Years playing Pro; Position; Favoured Weapon; Favoured Character; Awards; T-shirt Size; Dietary Requirements; Photo ID
Information we collect from you directly
During your participation in our eSports Tournaments, we will collect certain personal data about you. For example, information relating to your gameplay, in-game activity and progression through the eSports Tournament.
If you are fortunate enough to win, we will also ask you for your bank account and payment details so that we can arrange for your prize money to be transferred to you.
If you apply for Creators (Official CFS partners who participate in creating interactive video contents related to the eSports Tournaments) we will collect personal data for you as follows:
• Name; Nickname; Date of Birth; Nationality; Country of Residence; Region; Language; Email Address; Technical Skills; Use of tools; Occupation; Video file; Portfolio
During your participation as Creators, we will collect certain personal data such as cell phone number, bank account, passport number and passport expiration date for providing benefits according to your activity as Creators.
Information we collect about you automatically
We may collect the following information from you automatically when you visit our Websites:
• Technical information such as the internet protocol (known as IP) address used to connect your computer to the internet, your log-in information, time of access, date of access, time zone setting, web page(s) visited, software crash reports, type and version of browser used, browser plug-in types and versions used, and operating system and platform to ensure the security of your account and to verify that the person operating your account is you;
• Your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Websites (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call out customer service team; and
• Information about your computer or device allowing us to analyse trends, administer our Websites, track your web navigation, and gather broad demographic information for aggregated use.
Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with certain data, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our relationship. We will inform you if your failure to provide any requested personal information is going to result in these consequences.
4. COOKIES
Cookies are small pieces of data (text files) that are sent by the website server to the user's browser or app and saved on the user's computer and other devices. Our Websites may use cookies to collect the information described above.
You have a right to choose whether cookies are installed on your device or not. You may choose to refuse all cookies, confirm each time a cookie is saved, or permit all cookies by going to [Tools]>[Internet Option]>[Security]>[Custom Setting], or by using the Settings or Options function on mobile devices. However, if you refuse all cookies, you may not be able to access certain services or functionality of our Websites.
Google Analytics
The Websites use Google Analytics, a web analytics service provided by Google, Inc. ("Google").
Google Analytics uses "cookies", which are text files placed on your computer, to help us analyse how users use the Websites. These cookies do not collect any personally identifiable information and are only used for the statistical collection of data such as visits and page hits. Google Analytics’ cookies store IP addresses but we cannot link those addresses to any individual or path through the Websites. Google uses the cookies to read information and evaluate visitors’ use of the Websites in the form of statistical reports that we can access. The information generated by the cookie about your use of the Websites (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Websites, compiling reports on website activity and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.
For further information regarding the way in which Google Analytics uses cookies please see "How Google uses data when you use our partners' sites or apps", (located at www.google.com/policies/privacy/partners/). You can also stop being tracked by Google Analytics across all websites by going to Google's site at: http://tools.google.com/dlpage/gaoptout.
5. WHY WE COLLECT YOUR PERSONAL DATA
We collect, use and disclose your personal data for a number of reasons, including:
To organise and provide the eSports Tournaments and associated services
• for the purposes of providing and organising eSports Tournaments, including all associated logistics such as:
- (A) broadcasting and production
- (B) event travel and logistics, including accommodation and nutrition
- (C) tournament administration
- (D) event ticketing
• to post tournament information on our Websites for general users in “player information” format
• to post event photographs/videos via online streaming/broadcasting and on our Websites
• for settling fees, provide contents, purchase and fee payments, delivery of goods (prizes from events, etc.)
• to manage Creators, including but not limited to selection of such Creators, providing support for content production cost related to the eSports events and providing travel and accommodation support to offline eSports events.
To manage our users
• for customers services purposes
• to prevent unlawful and unauthorized use by rogue users, to check if they want to join, to deal with civil complaints including resolving dissatisfaction and customer advice, to preserve records for any disputes mediation and to give notifications
Business optimization and service development
• to conduct troubleshooting, research, analysis and product and service development to provide our players with the best gameplay experiences when participating in our eSports Tournaments.
Legal proceedings and requirements
• to investigate or address claims or disputes relating to your participation in the eSports Tournaments or as otherwise allowed or required by applicable law
For marketing and promotion purposes
• for specialization or development of new services (products), to deliver promotional information such as events and to provide services based on demographic information, statistics related to access frequency and the members' use of the service
6. WHO DO WE SHARE YOUR DATA WITH?
We may share your personal data with the following categories of recipients:
Related Entities
• Your personal data will be used by us and may be disclosed to our group companies (for example Smilegate Holdings, Inc.).
Publishers
• As described above, we have relationships with a number of publisher companies that service our games in different jurisdictions. These companies share your data with us.
Service providers
• In order to provide the eSports Tournaments, we work with service providers (e.g. broadcasters, event organizers and travel agencies) who may, in the course of providing their services, receive and process personal data on our instruction and on the basis of a contractual data processing agreement.
Other players and/or the general public
• We post tournament information on our Websites for general users in “player information” format. This information may be viewable by your friends, people in games, or the public in general.
Regulatory bodies/industry bodies
• We may disclose your personal data to a regulatory authority, government agency or law enforcement body with jurisdiction over our activities.
Replacement providers
• In the event that we sell or buy any business assets, we may disclose your personal data to the prospective seller or buyer of such business or assets. If SGE or substantially all of its assets are acquired by a third party, personal data held by us about our clients will be one of the transferred assets.
Indicator and tracking analysis tools
• We share your personal data with certain entities which provide us with indicator and tracking analysis tools in the Websites. In particular, we use Google Analytics and therefore share your personal data with Google. For details of how Google uses your data, please visit www.google.com/policies/privacy/partners.
• Please see the "Cookies" section, below for further information on the cookies which are used as part of the indicator and tracking analysis tools in the Websites.
At your option
• In certain circumstances, you have the option of sharing information with others yourself as part of the Events (e.g. if you give out personal data in a publically accessible participant or forum profile). However, we do not transfer such data to other third parties.
• For example, within the Events and the Websites, you may be provided with the option to link through to other websites or gaming communities. These other domains, apps and websites are subject to their own privacy practices and we encourage you to read the privacy policies of each and every website and application with which you interact. You visit these other websites or applications at your own risk.
• You should be aware that personal data that you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your data and by using such services, you assume the risk that the personal data you provide may be viewed and used by third parties for any number of purposes.
• Otherwise, your data will only be passed on in special exceptional cases, where we are obligated or entitled to do so by statute or upon binding order from a public authority.
7. WHAT ARE MY RIGHTS?
You have various rights in relation to the data which we hold about you. To get in touch with us about any of your rights under applicable data protection laws, please use the contact details set out above. We will seek to deal with your request without undue delay, and in any event within any time limits provided for in applicable data protection law (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.
In addition, for users located in the EU only, the European General Data Protection Regulation (the "GDPR") gives you the following rights in relation to your personal data:
Right to object
This right enables you to object to us processing your personal data where we do so for one of the following reasons:
• because it is in our legitimate interests to do so (for further information please see the section on our legal bases for processing below);
• to enable us to perform a task in the public interest or exercise official authority;
• to send you direct marketing materials; or
• for scientific, historical, research, or statistical purposes.
Right to withdraw consent
Where we have obtained your consent to process your personal data for certain activities (for example, for marketing), you may withdraw this consent at any time and we will cease to use your data for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose, in which case we will inform you of this condition.
Data Subject Access Requests
You may ask us for a copy of the information we hold about you at any time, and request us to modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this unless permitted by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
Right to erasure
You have the right to request that we "erase" your personal data in certain circumstances. Normally, this right exists where:
• The data are no longer necessary;
• You have withdrawn your consent to us using your data, and there is no other valid reason for us to continue;
• The data has been processed unlawfully;
• It is necessary for the data to be erased in order for us to comply with our obligations under law; or
• You object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
We would only be entitled to refuse to comply with your request for erasure in limited circumstances and we will always tell you our reason for doing so. When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.
Right to restrict processing
You have the right to request that we restrict our processing of your personal data in certain circumstances, for example if you dispute the accuracy of the personal data that we hold about you or you object to our processing of your personal data for our legitimate interests. If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
Right to rectification
You have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. You may also request details of the third parties that we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
Right of data portability
If you wish, you have the right to transfer your personal data between service providers. In effect, this means that you are able to transfer the details we hold on you to another third party. To allow you to do so, we will provide you with your data in a commonly used machine-readable format so that you can transfer the data. Alternatively, we may directly transfer the data for you.
Right to complain
You also have the right to complain to your applicable data protection authority. Contact details for data protection authorities in the EU are available at: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
In addition, for users located in China only, you will have the following rights in relation to your personal data:
Data Subject Access Requests
You may ask us for a copy of the information, we hold about you at any time, including the personal data, the type or source of such information, the purposes for processing, the identity or type of third parties that have obtained such information. We will provide access to the information we hold about you free of charge, unless we are permitted by law to charge a fee. If you request further copies of this information from us, we may charge you a reasonable administrative fee. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
Right to rectification
You have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort.
Right to erasure
You have the right to request that we "erase" your personal data in certain circumstances. Normally, this right exists where:
• We have violated the applicable laws and regulations or our agreement with you in collecting and using your personal data;
• We have violated the applicable laws and regulations or our agreement with you in sharing or transferring your personal data with or to third parties, in which case we will notify the third parties to erase your personal data; or
• We have violated the applicable laws and regulations or our agreement with you in publicly disclosing your personal data, in which case we will cease the public disclosure and notify the recipient to erase the personal data.
Right to withdraw consent
Where we have obtained your consent to process your personal data for certain activities (for example, for marketing), including collecting, sharing, transferring or publicly disclosing your personal information, you may withdraw this consent at any time and we will cease to use your data for that purpose.
Right of data portability
If you wish, you have the right to transfer to another third party the basic information and identity information we hold on you.
To allow you to do so, we will provide you with your data in a commonly used machine-readable format so that you can transfer the data. Alternatively, we may directly transfer the data for you to the extent permitted by then commonly-employed technology.
8. SECURITY
We have in place appropriate technical and organizational security measures to protect your personal data, including:
• In order to protect the unauthorized disclosure of users' personal data from hacking or any external break-ins, we currently use equipment that blocks any external break-ins, which protects the data from any hacking, attacks, or unauthorized access, and we also use encryption, etc., so that personal data may be transferred safely. In particular, the server containing users' personal data managed separately so that is not directly linked to the external internet line.
• In preparation for any unexpected emergencies, we have a policy to back-up the system and data.
We are taking protective measures to try and minimize damages caused by computer viruses by using vaccines that are regularly updated.
Only the minimum number of people have right of access to the users' personal data.
We train our staff who handle personal data on new security technology and personal data protection obligations. Further, through an internal designated personal data protection unit, etc., we try and correct any errors immediately upon detection by checking the company's personal data processing procedure implementation and the relevant personnel's compliance with the personal data protection policies.
In addition, we have physical security measures in place including limiting access, CCTV installation, setting security levels and limiting physical access based on security levels etc.
9. WHERE WE KEEP YOUR PERSONAL DATA
In general, your data will be stored in the Republic of Korea. However, it may be transferred to other jurisdictions. For example, your personal data will be transferred to any country in which our eSports Tournaments are taking place.
In the event that we transfer your personal data to another country and where the country or territory in question does not maintain adequate data protection standards, we will take all reasonable steps to ensure that any such transfers is undertaken in accordance with applicable data protection and privacy laws and that your data is treated securely and in accordance with this Privacy Policy. However, please note that where personal data is stored in another country, it may be accessible to law enforcement agencies in accordance with domestic laws.
10. HOW LONG WILL WE KEEP YOUR PERSONAL DATA?
We will not keep your personal data for longer than is necessary for the purposes for which we have collected it, unless we believe that the law or other regulation requires us to keep it (for example, because of a request by a tax authority or in connection with any anticipated litigation) or if we require it to enforce our agreements.
Where there is a need to store data because of relevant legislation, for the period stipulated in the legislation, the personal data may be:
• stored for 5 years if records related to contracts or subscription cancellations
• stored for 5 years if records related to supply of goods and payments
• stored for 3 years if records related to customer complaint or dispute resolution
• stored for 6 months if records related to marks or advertisements
• stored for 3 months if records related to Websites visits
When it is no longer necessary to retain your personal data, we will delete the personal data that we hold about you from our systems. While we will endeavour to permanently erase your personal data once it reaches the end of its retention period, some of your personal data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists in the electronic ether, our employees will not have any access to it or use it again.
11. LEGAL BASES FOR USING YOUR PERSONAL DATA
For users from the EU only, applicable privacy laws in the EU require us to inform you of the different legal bases that we rely on to legitimize our processing of your personal data. We have set these out below.
Where using your data is in our legitimate interests
We are allowed to use your personal data where it is in our interests to do so, and those interests aren't outweighed by any potential prejudice to you.
We believe that our use of your personal data is within a number of our legitimate interests, including but not limited to:
• To provide and manage the eSports Tournaments and associated services;
• To manage our users;
• To provide customer support to our users;
• For business optimization and service development;
• To manage our Websites;
• For marketing and promotion services;
• To ensure that our systems run smoothly; and
• To protect against improper use or unauthorized use of our services.
We don't think that any of the activities set out in this privacy policy will prejudice you in any way. However, you do have the right to object to us processing your personal data on this basis.
Where you give us your consent to use your personal data
We are allowed to use your personal data where you have specifically consented. In order for your consent to be valid:
• It has to be given freely, without us putting you under any type of pressure;
• You have to know what you are consenting to – so we'll make sure we give you enough information;
• You should only be asked to consent to one thing at a time – we therefore avoid "bundling" consents together so that you don't know exactly what you're agreeing to; and
• You need to take positive and affirmative action in giving us your consent – for example, we could provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.
We currently seek your consent for marketing and advertisement purposes, as well as consent to process your dietary requirements (where applicable).
Before giving your consent you should make sure that you read any accompanying information provided by us so that you understand exactly what you are consenting to.
You have the right to withdraw your consent at any time, and details can be found in the "Right to withdraw consent" paragraph in the section on your rights above.
Where using your personal data is necessary for us to carry out our obligations under our contract with you
We are allowed to use your personal data when it is necessary to do so for the performance of a contract that we have with you. For example, if you have won a competition, we need to process your bank account information in order to be able to pay you your prize money.
Where processing is necessary for us to carry out our legal obligations
As well as our obligations to you under any contract, we also have other legal obligations that we need to comply with and we are allowed to use your personal data when we need to in order to comply with those other legal obligations.
12. LINKING TO THIRD PARTY WEBSITES
Within the Websites, you may be provided with the option to link through to other websites or services. These other domains, apps and websites are subject to their own privacy practices and we encourage you to read the privacy policies of each and every website and application with which you interact. You visit these other websites or applications at your own risk
13. YOUR CALIFORNIA PRIVACY RIGHTS AND "DO NOT TRACK”
If you are located in California, you have certain additional rights
California Civil Code section 1798.83 permits users who are California residents to request certain information identifying any third party to whom SGE may have disclosed, within the past year, personal data pertaining to such user and such user's family for that third party's direct marketing purposes, as well as a description of the personal data disclosed. To request such information, you may contact us using the contact details set out above. Any written inquiry must include "California Privacy Rights Request" in the first line of the description. Please note that we are only required to respond to one request per user each year.
In addition, California residents under the age of 18 who are registered users of any of online sites, services or applications where this Privacy Policy is posted may under California law request and obtain removal of content or information they have publicly posted. To make such a request, you may contact us using the contact details set out above. Your request should include a detailed description of the specific content or information to be removed. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
California law permits our users who are California residents to be informed as to how we respond to web browser "Do Not Track" settings. We do not respond to "Do Not Track" settings at this time, whether that signal is received on a computer or on a mobile device.
14. CHANGES TO THIS PRIVACY POLICY
We will review this Privacy Policy periodically, and reserve the right to modify and update it at any time. You acknowledge that we may make changes to this Privacy Policy and it is your responsibility to check back to this page from time to time to review the Privacy Policy. Changes to this Privacy Policy will come into effect immediately upon such changes being notified to you or uploaded to our Websites.
