Gamercraft Privacy Policy

For more information contact Gamercraft at team@gamercraft.com

Effective as of: April 23, 2020

We are Gamercraft. We create and organize tournaments for amateur and semi-professional gamers. Our platform is designed to deliver the best online competitive and learning gaming experiences. To do that, we need information about you. Protecting your privacy is really important to us. We only use your information where we have a legal basis to do so. This Privacy Policy will help you understand what information we collect, how we use it and what choices you have when you play any of our games, use our websites, buy merchandise from us, or take part in live events and promotions (the "Services").

You should also read our Terms of Service which set out the contract between you and Gamercraft.

1. Who decides how your information is used?

Gamercraft, Inc. is the data controller responsible for making decisions about how we use your personal information if you are based in the United States and both outside and inside of the European Economic Area (EEA).

If you have any questions or comments on this policy, you can:
• Email us at privacy@gamercraft.com
• Contact our Data Protection Officer at dpo@gamercraft.com

2. The information we collect about you and how we use it

This Privacy Policy covers our use of any information that can or could be used to identify you or your household ("Personal Data"). It does not cover information which cannot be used to identify you ("Anonymous Data").

We need to collect and use certain Personal Data to provide the Services to you and fulfil the promises we make to you in the Terms of Service:

• When you sign up for our Services you give us Personal Data voluntarily by providing it to us, for example when you sign up for an account. We collect and use that information in order to authenticate you when you register an account and use the Services, to make sure you are eligible and able to receive the Services, and so that you receive the correct version of the Services. That information includes the in-game username you choose to use on our Services, and internal account IDs that we assign to your account.
• You must have an account with a supported external single sign-on service to use our Services. As such, the Personal Data we collect also depends on which external accounts you choose to use, their privacy policy, and what your privacy settings with those services allow us to see when you use their services to access Gamercraft Services.
• If you choose to link your Google account to the Services, we will collect your Google email address and an authentication token provided by Google.
• If you choose to link your Discord account to the Services, we will collect your email address, username, and an authentication token provide by Discord. Some external providers may notify you that they make additional information, such as your public profile, available to us when you use their single sign-on services. We do not collect that information from them.
• We also collect and use your in-tournament actions and achievements, as well as certain information about your mobile device (including device identifiers, device OS, model, configuration, settings and information about third party applications or software installed on your device), to operate the Services for you.
• We further use the information above in order to provide technical and customer support to you.
• You also give us Personal Data when you make a purchase through us, subscribe to our publications, register for a live event, enter a tournament, competition, promotion, sweepstakes or survey or communicate with us. Depending on which of these Services you use, that may include your name, mailing address, phone number, country of residency, date of birth (as needed to verify eligibility), and email address. We use that information to fulfil those Services to you and to provide related customer support to you.
• We also collect your in-game names and the region of your gaming account depending on the games we support.

In addition, we have and rely on a legitimate interest in using your Personal Data as follows:

• Using your IP address, browser type, operating system, the web page you were visiting before accessing our Services, the pages of our Services which you browsed or the features you used, and the time spent on those pages or features, the links on our Services that you click on, device and advertising identifiers, as well as actions you take during gameplay, your in-game user settings and preferences and your in-app purchases to understand who is using our Services and how.
• Using your contact information, namely your email address in order to communicate with you to provide technical and customer support.
• Using your internal account ID in order to attribute to your account any user content (such as local points of interest) that you elect to submit to Gamercraft through the Services.
• Using your email address and device information in order to share updates and news about the Services with you either within the games or by email. You can unsubscribe from these at any time in your device settings or in-app settings.
• To provide social features within our web and mobile applications so you can interact and play with other players, including storing your communications with those players, find your friends and be found by them, and share your tournament and competitive experiences and achievements with your friends.
• To offer new or additional features for our Services.
• To organize and run live events based on or featuring our tournaments. Note that when you participate in live events your in-game actions and achievements, in-game username and your avatar, team, and other components of your in-game profile will be visible to other event participants and to the public (for example on leaderboards displayed at the event and online).
• Using your in-game actions and achievements, as well as certain information about your mobile device (including device identifiers, device OS, model, configuration, settings and information about third party applications or software installed on your device), to carry out anti-fraud and anti-cheating measures against behaviors prohibited under our Terms of Service, to ensure that we provide a fair gaming experience to all players.
• To make legal or regulatory disclosures and to establish, exercise, or defend legal claims.

We will only use your Personal Data to do the following if we have your consent:.

• If you elect to add information about Gamercraft tournaments and live events to your mobile calendar, we will, with your permission, access your device’s calendar and write in these events. We do not access or collect any other information from your calendar. You can change your mind and disable access to your calendar at any time in your device settings.
• Send you push notifications reminding you of your upcoming tournaments, matches, instant challenges, and any other of the Services.
• Send you marketing materials by email or via in-app notifications. You can unsubscribe from these at any time in your device settings or in-app settings.

We also rely on your consent where we use cookies or similar technologies. Please see our Cookie Policy for more information about how we use them. Insofar as cookies collect Personal Data, we will process it only based on your explicit consent, in anonymized form, or under a pseudonym.

While you may disable the usage of cookies through your browser settings, Gamercraft currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to the lack of industry standard on how to interpret that signal.

3. Who we share information with

We will not share any Personal Data that we have collected from or regarding you except as described below:

Information Shared with Our Service Providers. We engage external service providers to work with us to administer and provide the Services. As part of that they will process your Personal Data on our behalf. These external service providers have access to your Personal Data only for the purpose of performing services on our behalf, in compliance with this Privacy Policy, and we make sure each one is contractually obliged not to disclose or use your Personal Data for any other purpose. The service providers we use help us to:


• run, operate and maintain our tournaments through third party platform and software tools;
• perform content moderation and crash analytics;
• run email and mobile messaging campaigns;
• perform tournament, gaming, and marketing analytics;
• administer tournaments, competitions, sweepstakes and promotions, including registering players, managing check-in and attendance, verifying eligibility and prize fulfilment;
• provide technical and customer support; and
• process payments for battle passes, entry fees, and any other of our offerings.

Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) as a Third Party Service in accordance with their own privacy policy. Such external service provider does not share your financial information, like credit card number, with Gamercraft, but it may share limited information with us related to your purchase, like your zip or postal code.

Information Shared with Other Players. When you use the Services, and in particular when you play our games, use social features within those games, or take part in live events, we will share certain Personal Data with other players. This Personal Data includes your in-game profile (such as your username, your avatar, and your team), your in-tournament actions and achievements. For more details please read the Game-Specific Disclosures at the end of this Privacy Policy. Additionally, certain games link to third-party sharing features on your device that you can use to disclose Personal Data to others outside the web or mobile applications; Gamercraft does not control and is not responsible for the practices of these third-party sharing features.

Information Shared with Third Parties. We share Anonymous Data with third parties for industry and market analysis. We may share Personal Data with our third-party publishing partners for their direct marketing purposes only if we have your express permission. We do not share Personal Data with any other third parties for their direct marketing purposes.

Information Disclosed for Our Protection and the Protection of Others.We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We only share information about you to government or law enforcement officials or private parties when we reasonably believe necessary or appropriate: (a) to respond to claims, legal process (including subpoenas and warrants); (b) to protect our property, rights, and safety and the property, rights, and safety of a third party or the public in general; and (c) to investigate and stop any activity that we consider illegal, unethical, or legally actionable.

Information Disclosed in Connection with Business Transactions.Information that we collect from our users, including Personal Data, is a business asset. If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, will be disclosed or transferred to a third party acquirer in connection with the transaction.

4. How your Personal Data is transferred

Gamercraft stores data in AWS (Amazon Web Services) instances. Your Personal Data will likely be transferred and stored in a country outside of your home country, including in the USA, for the purposes outlined in this Privacy Policy. The data protection laws in these countries may not be the same as in your home country.

If we transfer your Personal Data from the EEA to other countries, including the USA, we ensure that a similar degree of protection is provided to your Personal Data as within the EEA by ensuring that at least one of the following safeguards is implemented:
• The country that your Personal Data is transferred to is a country that the European Commission has deemed to provide an adequate level of protection for Personal Data as the EEA.
• Where we engage with service providers in the USA, they are part of the EU-US Privacy Shield, which requires them to provide the same protection of your Personal Data as it has in the EEA.

5. How we keep your Personal Data safe

We have appropriate security measures in place to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, improperly altered or disclosed. We also limit access to your Personal Data to employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. How long we will keep your Personal Data

We keep your Personal Data for as long as we need to provide the Services to you and fulfil the purposes set out in this Privacy Policy. This is also the case for anyone that we share your information with and who carry out services on our behalf.

When we no longer need to use your Personal Data and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or anonymize it so that it can no longer be associated with you. When removing Personal Data, we will take commercially reasonable and technically feasible measures to make said Personal Data irrecoverable or irreproducible.

7. Your rights and choices

You have certain rights in relation to your Personal Data. In order to exercise these rights, please contact us at our support page or Discord Channel.

You can:
• Request access to the Personal Data we hold on you by emailing privacy@gamercraft.com.
• Delete or correct your Personal Data. The easiest way to update your account information is via your in-app settings.
• Object to us processing your Personal Data. Some of the Personal Data we hold is necessary for us to provide the Services to you and fulfill the promises we make to you in the Terms of Service.
• Ask us to stop using your Personal Data, including for marketing and promotional purposes (but be aware that sometimes we need to use your Personal Data in order for you to use the Services).
• Have your Personal Data transferred to another organization (where it is technically feasible).
• Complain to a regulator. We'd appreciate the chance to deal with your concerns directly so we'd prefer you to contact us first. However, if you're based in the EEA and believe that we have not complied with data protection laws, you can complain to our regulator or with your local supervisory authority.

The law provides exceptions to these rights in certain circumstances. Where you cannot exercise one of these rights due to such an exception, we will explain to you why.

We offer you choices regarding the collection, use, and sharing of your Personal Data and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.

After you contact us, you may receive an email in order to verify your request. We aim to provide the information or complete the outcome you request within 30 days.

8. Children

Unless stated otherwise for a particular Service, children are not allowed to use the Services, and we do not collect Personal Data from them. We define “children” as follows:

• Residents of the EEA: anyone under 16 years old, or the age needed to consent to the processing of personal data in your country of residence.
• Residents of the Republic of Korea, anyone under 14 years old.
• Residents of other regions: anyone under 13 years old

For Services that permit Child participation, parents or legal guardians ("Parents") must provide verified consent. Parents can provide and verify their consent through the Gamercraft Parent Portal, or through another authorized third-party provider made available through the Service. Where Parental consent is required, Gamercraft recommends that Parents monitor the Child’s online activity and use of the Service.

The Gamercraft Parent Portal is operated on Gamercraft’s behalf by Kids Web Services (KWS), a product of SuperAwesome Trading Ltd of 40 Long Acre, London WC2E 9LG, United Kingdom, www.superawesome.tv. You may contact SuperAwesome directly at privacy@superawesome.tv or +44 203 668 6677 for any questions related to their handling of user information, especially parent information. KWS is certified by the kidSAFE Seal Program, an FTC-Approved COPPA Safe Harbor Program. SuperAwesome is also a valid licensee, and participating member, of the Entertainment Software Rating Board’s Privacy Certified Program (“ESRB Privacy Certified”).

Verifiable parental consent is required for the collection, use, or disclosure of a child's Personal Data. Gamercraft will not collect, use, or disclose any Personal Data from a child if their parent or guardian does not provide such consent. We may ask a Child to provide a Parent’s email address in order to request this consent, and the Parent’s email address will be deleted if consent is not provided within a reasonable time.

Parents who wish to consent to their Child accessing our Services must first create a Gamercraft Kids account so they can manage the privacy settings of their Child’s account. Parents will then be required to verify their identity through the Gamercraft Kids Parent Portal operated by SuperAwesome. In order to perform that verification, SuperAwesome requires certain personal information about parents. Any such information is collected by SuperAwesome as a Third Party Service in accordance with their own Privacy Policy, which can be found at https://parents.superawesome.tv/en/privacy.

Once verified, a parent can consent to their child accessing the Service. For user account creation, Gamercraft will collect the in-game username the Child chooses to use on our Services, internal account IDs that we assign to the Child’s account, and, with the parent’s permission, the Child’s personal email address. We need that information to authenticate the Child’s account, to make sure the Child is eligible and able to receive the Services, and so that the Child receives the correct version of the Services. As the Child accesses and uses the Service, Gamercraft will also collect and use the Child’s device location and other Personal Data listed in this Privacy Policy for the purpose of operating and providing the Service to the Child, as described in this Privacy Policy. If we need to collect additional information for other purposes we will first seek your permission.

Parents have the right to review their Child’s Personal Data; to have their Child’s Personal Data deleted; and to refuse further collection, use, and/or disclosure of their Child’s Personal Data by notifying us. As a parent, you understand that Gamercraft has a legitimate interest in providing your Child’s Personal Data collected via the Services to external providers for the sole purpose of administering or providing the Services, as described in Paragraph 3 of this Privacy Policy.

If we learn that we have collected Personal Data of a Child, and we do not have parental consent, we will take steps to delete such information from our files as soon as possible.

If you have questions about our privacy practices for Children, please contact us at privacy@gamercraft.com or Gamercraft, Inc., 22 Boston Wharf Road 7th Floor, Boston, MA 02210

9. Changes to this Privacy Policy

Any Personal Data that we collect is covered by the Privacy Policy in effect at the time such information is collected. We may make changes to this Privacy Policy from time to time. You will be given reasonable notice of any material change.

10. Third Parties

In using our Services you may access links to websites and services that are owned or operated by third parties (each, a “Third Party Service”). Any information that you provide on or to a Third Party Service or that is collected by a Third Party Service is provided directly to the owner or operator of the Third Party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy, or security practices and policies of any Third Party Service. To protect your information we recommend that you carefully review the privacy policies of all Third Party Service that you access.

11. Disclosures Specific to California Residents

California law requires that we make certain disclosures about your data. We do not sell your Personal Data. The information listed in Section 2 falls under the following California Consumer Privacy Act (CCPA) categories: identifiers, commercial information, Internet or other electronic network activity information, geolocation data, and visual information.