(a) What Personal Information about you we may collect?
(b) How we may use your Personal Information?
(c) Who we may share your Personal Information with?
(d) How we protect your Personal Information?
(e) Contacting us & your rights to prevent marketing and to access and update your Personal Information
(f) Our Cookies Policy
What Personal Information about you we may collect ?
We will collect and process all or some of the following Personal Information about you:
(a) Information you provide to us ► Personal Information that you provide to us, such as during any registration process, signing up or logging in process to access or use of our websites or otherwise interact with us, including your name, email address, and other contact details;
(b) Your transactions ► details of transactions you carry out through our websites or through other channels and of the fulfilment of the services we provide;
(c) Websites and communication usage ► details of your visits to our websites and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access, information on the amount of time you use our services/products and the pages you visit. We collect this information in order to develop our products and services and to understand what your usage patterns and preferences are so that our services are relevant to you and we will improve for you;
(d) Promotions ► we may request Personal Information to administer your participation in any contests, sweepstakes or other promotions that we organise;
(e) Device Information ► such as information about your software applications, IP address, geolocation, operating system, browser, security status and other device information in order to protect against fraud and manage risk as well as improving your experience with our website ;
(f) Marketing preference information ► details of your marketing preferences (e.g. communication preferences), “likes” and information relevant to selecting appropriate services and products to offer you;
(g) Activities on Social Networking Sites (SNS) ► if you choose to take part (eg, by “liking” Sandbox Global’s profile on any social network including Twitter/Facebook/Linkedin, posting a message, or answering a poll), we may then have access to the information you disclose which may include Personal Information, depending on your SNS privacy settings;
(h) Website and communication usage ► details of your visits to the websites and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs, other communication data, and any resources that you access;
(i) Survey information ► we may also ask you to complete surveys that we use for research purposes. In such circumstances we shall collect the information provided in the completed survey.
How we may use your Personal Information
(a) The purposes for which we use the Personal Information that we collect via our website will comply with our obligations under the GDPR. We will identify the “legal grounds” on which we rely to process the Personal Information. There are 6 “legal grounds” set out in the GDPR which permit companies to process personal data only.
Consent: where you have given your consent to the processing of your Personal InformationProcessing: where it is necessary for the performance of a contract with you as a partyLegal obligation: where Processing of your Personal Information is necessary for us to comply with our legal obligations.Protection of legitimate interests: where Processing of your Personal Information is necessary to protect the legitimate interest of your Personal Information.Public Interest: where Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the public officer/controllerAny Exception: where Processing is necessary for the purposes of the legitimate interests pursued by a controller, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data, in particular where you are a child. This shall not apply to processing carried out by public authorities in the performance of their tasks
(b) If you have consented to our use of your Personal Information for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. In cases where we are using your Personal Information because we or a third party have a legitimate interest to do so, you have the right to object to that use which may include no longer using the services that we provide.
(i) To manage and provide services and products you have requested ► to administer our services, including to carry out our obligations arising from any contracts entered into between you and us, or to notify you about changes to our services and products.
Use justifications: consent, legitimate interests, contract performance (to enable us to perform our obligations and provide our services to you or to notify you about changes to our service)
(ii) To correspond with you regarding services and products that may be of interest to you ► to provide you with offers/promotions/updates when you have chosen to receive them. We may also use your Personal Information to market our own and our selected business partners’ products and services to you by way of in-app alerts, post, email, phone, SMS or online or social media advertisement. Where required by law, we will ask for your consent at the time we collect your Personal information for any of these types of marketing. We will provide an option on the appropriate platform to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you.
Use justifications: legitimate interests (to keep you updated with latest news in relation to our services and products); consent
(iii) To understand our users/customers and to develop and tailor our services and products ► we may analyse your Personal Information so to better understand your usage patterns, preferences and marketing requirements, as well as to develop our services/products;
Use justifications: legitimate interests (to ensure the quality of our services to you and to allow us to improve our services);
(iv) If applicable, to sponsor you and/or your esports team ► to carry out our obligations arising from any sponsorship agreements entered between you and us, to notify you about changes to the terms of our sponsorship, or to advertise the fact that you and/or your esports team are sponsored by us.
Use justifications: contract performance; consent
Use justifications: contract performance, legal obligations, legal claims, legitimate interests (to ensure that the quality and legality of our services)
(vi) To inform you of any changes ► to notify you about any changes to our services and products;
Use justifications: legitimate interests (to notify you about any changes to our service/products)
(vii) To re-organise our business ► in the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a reorganisation, we may need to transfer some or all of your Personal Information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer your Personal Information to that re-organised entity or third party after the sale or reorganisation for them or in the process for them to use for the same purposes as set out in this policy
Use justifications: legitimate interests (in order to allow us to change our business)
(viii) To ensure website content is relevant ► to ensure that content from our websites is always relevant and presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers;
Use justifications: legitimate interests (to allow us to provide you with the content and services on the websites)
(viv) In connection with legal or regulatory obligations ► We may process your Personal Information to comply with our regulatory requirements or dialogue with regulators as applicable which may include disclosing your Personal Information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.
Use justifications: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities)
Who we may share your Personal Information with (and transfers outside of the EEA)?
(b) Sharing outside the Sandbox Global group: Personal Information may be provided to third parties, including anti-fraud organisations, legal, regulatory or law enforcement authorities in cases of suspected criminal activity or contravention of law, for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements of governments, regulatory authorities or other self-regulatory organizations, or to comply with a court order or for the protection of our assets (for example, collection of overdue accounts).
(c) Sharing within the Sandbox Global group: We may share your Personal Information within the Sandbox Global group, including locations outside of the EEA where we do business, for marketing purposes, for legal and regulatory purposes, to manage credit risk and other business risks, to perform analytics, to ensure we have correct or up to date information about you (such as your current address or date of birth) and to better manage your relationship with us.
(d) Business sale or reorganisation: In the event that we buy new businesses or sell some of our businesses, the Personal Information associated with any accounts, products or services of the business being purchased or sold will be reviewed as part of the due diligence process and subsequently transferred as a business asset to the new business owner. As said, we may also transfer Personal Information as part of a corporate reorganisation or other change in corporate control.
(e) Sub-contractors and agents: We may use our companies in the Group, affiliates or other companies to provide services on our behalf such as data processing, account administration, fraud prevention and detection, analytics and marketing. Such companies will be given only the necessary Personal Information needed to perform those services and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes not authorised. We have contracts in place subjecting these companies to the same standards of confidentiality by which we are governed.
Where we transfer Personal Information from inside the European Economic Area (the EEA) to outside the EEA, we may be required to take specific additional measures to safeguard the relevant Personal Information. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export Personal Information to these jurisdictions. In countries which have not had these approvals (see the full list here http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm), we will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements.
How we protect your Personal Information?
(a) We use physical, electronic and procedural safeguards to protect against unauthorized use, access, modification, destruction, disclosure, loss or theft of your Personal Information in our custody or control.
(b) We have contracts and controls in place with third party service providers stipulating that any information we provide to them shall be safeguarded and used only for the purpose of providing the service we have requested from the third-party service providers.
(c) We cannot and in no position to guarantee that the data transmission over the Internet or website is secure from intrusion, hacking or data leaks. However, we always maintain commercially reasonable physical, electronic and procedural safeguards to protect your Personal Information in accordance with the data protection legislative requirements.
(d) Our retention periods for personal data are based on business needs and legal requirements. We retain your Personal Information for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When Personal Information is no longer needed, we either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the data.
(e) All Personal Information you provide to us is stored on either our or our subcontractors’ secure servers and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.
Contacting us & your rights to prevent marketing and to access and update your Personal Information
(a) Most of our processing is permitted by “legal grounds” other than consent (see section 8 (a) above). However, in relation to Direct Marketing, where we are required to do so, we will obtain your consent before using your Personal Information for this purpose. If you prefer not to receive our Direct Marketing communications and/or not have your Personal Information shared among the members of the Sandbox Global group for the purpose of marketing, you can choose to have your name deleted from our Direct Marketing and/or shared information lists.
Direct Marketing means our communication with you such as mail, telemarketing or email, using your contact information, to inform you about services and products that we think may be of interest and value to you. This does not include communications regarding services or products that you currently have, including improved ways to use the products, or additional features of the products as well as transactional information.
(b) We will exercise reasonable endeavours to ensure that your Personal Information is accurate. To assist us with this, you must notify us of any changes to your Personal Information that you have provided to us by contacting us as set out in the “Contacting Us” section below.
(c) If you have any questions in relation to our use of your Personal Information, you should first contact us as per the “Contacting Us” section below. In specific situations and under certain conditions, you may have the right to require us to:
(i) provide you with a copy of the information that you have provided to us;
(ii) provide you with further details on the use we make of your information;
(iii) update any inaccuracies in the Personal Information we hold;
(iv) delete any Personal Information we no longer have a lawful ground to use;
(v) where processing is based on consent, to withdraw your consent so that we will not process the Personal Information anymore
(vi) object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
(vii) restrict how we use your Personal Information whilst a complaint is being investigated.
(d) Your exercise of your rights herein is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of the rights herein, we will check your entitlement and respond in most cases within a month.
(e) Please let us know if you have any questions in relation to our privacy practices, the privacy of your Personal Information or you want to change your privacy preferences.
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