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Esports Platform Privacy Policy

Artem Uarabei
14.11.2019

Esports Platform Privacy Policy

1. General Provisions

  • 1.1 This Privacy Policy (hereinafter, "Policy") is the official document of "ClickStorm" (hereinafter, "Administration"), and sets the order of processing and protection of individuals' information (hereinafter "Users") who use eposrt platform accessible at https://click-storm.com (hereinafter "Platform").
  • 1.2 Privacy and security of your Personal information are crucial to Administration. Thus this Policy aims to ensure protection of information about Users, including personal data, against unauthorized access and disclosure.
  • 1.3 Relations, connected with collecting, storing, dissemination, and protecting information about Users, are covered by this Privacy Policy, other official documents of Administration and applicable laws.
  • 1.4 Being a public document the current revision of this Policy is available at https://click-storm.com/en/privacypolicy
  • 1.5 This Policy shall be regulated by User Agreement of the Platform available on the Platform at https://click-storm.com/en/privacypolicy (hereinafter "User Agreement of the Platform"). Terms that are not defined in this Policy have the same meanings as the ones in the User Agreement of the Platform, if not stipulated otherwise by the Policy. This Policy would prevail if any inconsistencies between it and other official documents of the Administration were to arise. Personal information is processed following the User Agreement of the Platform concluded between User and Administration.
  • 1.6 The User expresses agreement with the terms of use and consents on his own free will to process his/her data according to this Policy through putting a tick at the acknowledgment of agreement with the terms of this Policy provided in the interface of the Platform (Policy acceptance).
  • 1.7 In case of disagreement with the terms of the Policy, usage of the Platform should be immediately ceased.
  • 1.8 This Policy may be subject to amendments made by the Administration. When signing up after amendments, the User shall be suggested to accept the new version of the Policy. The usage of the Platform without acceptance of an updated version of the Policy is not allowed.

2. Terms of use of the Platform.

  • 2.1 Providing Platform access services, the Administration on its' own free will considers User to:
    • have rights allowing to use the Platform;
    • provide true information;
    • realize that the information mentioned in the 4th part of the Policy placed at the Platform by the User may be available to other Users as well as the Internet Users;
    • thus it may be copied and distributed by these Users;
    • know the conditions of this Policy, agree with them, and accept rights and responsibilities stated in the Policy.
  • 2.2 The Administration does not verify provided (collected) information of the Users unless otherwise provided to the cases when such verification is necessary as a fulfillment of obligations to the User and third parties in such an order provided in the Policy, User Agreement of the Platform and applicable laws.

3. Purposes and terms of information processing.

  • 3.1 The Administration processes information about Users, including personal data, to provide services towards Users. In particular:
  • 3.1.1 Organizing Tournaments using the Platform, summarizing the results, providing Participants with information about Tournaments that take place.
  • 3.1.2 Payment/ reward the Participants that took places in accordance with the Rules within taking part in Tournaments.
  • 3.1.3 Analyzing provided data with the potential to develop, improve and optimize the Platform, introduce new features;
  • 3.1.4 Advertisement mailing of those Users who gave their emails containing information about special offers, promotions, and others.
  • 3.1.5 Considering the fact that in accordance with the paragraph 5.3.3 of the Policy Administration may transfer Users' data to Partners (as stated below), and taking into account that Administration may cooperate with all-Russian and regional esports federations, the purpose of such transfers is to maintain databases of the Users who perform as players at esport discipline done by these Partners.
  • 3.2 Administration processes information about Users, including personal data, collected by Platform for a period of the User's using of the Platform, and during 3 (three) calendar years since the User's last authorization on the Platform.

4. User's information list.

  • 4.1 Users' data. Users' data includes:
    • 4.1.1 Necessarily provided information for signing in the Platform:
      nickname;
      email address or User's VK account address
    • 4.1.2 Necessarily provided information to take part in tournaments, where such provision is required:
      Steam account name
    • 4.1.3 Optionally provided information by filling in profile, additional data, used to keep in touch with the participants and judges of Tournaments and with the Administration of the Platform in Platform supportive community in VK.com: https://vk.com/im?media=&sel=-42389024 or to communicate with the Administration of the Platform via other means of communication;
      Country/ city;
      Phone number;
      Nicknames from various games;
      VK.com, Facebook, Twitter, YouTube account names;
      Steam account name;
      Messaging system login
    • 4.1.4 Additionally provided data by those Users that became winners/ prize-winners of Tournaments, upon request of Administration to reward and to perform obligations towards Users arising out of User Agreement of the Platform.
      series and number of identity document
      Individual Taxpayer Number
      Insurance Number of Individual Ledger Account
      bank details of the User
  • 4.2 Other information about Users, processed by Administration
  • Website's Administration may also process other information about Users, including:
    • 4.2.1 additional data, received while accessing to the Platform including technical devices, technological interaction with the Platform (including host IP address, operating system type, browser type, geographical location, Internet service provider) and subsequent actions of User on the Platform;
    • 4.2.2 information automatically received in access to the Platform using bookmarks (cookies);
    • 4.2.3 information received as a consequence of User's actions on the Platform (in particular, but not exclusive, information about joining a Team/ information about building a team/ information about taking part in Tournaments and results of participating/ leaving the Team/ information about organization of Tournament);
    • 4.2.4 Tournaments' accounts in games in which User takes part
  • 4.3 Certain information, mentioned by User in his Game Account, including personal data, may be available for other Users. Such information includes but not exclusive: attached accounts in game projects, country, age, list of Teams, and Tournaments in which User has taken part.

5. Ways and principles of processing information about Users.

  • 5.1 Personal data processing is based on principles of:
    • validity and fairness;
    • restriction of the processing of personal data by fulfilling specific and legitimate purposes;
    • accordance of amount and nature of collected information, compliance of the ways of processing personal data with the goals;
    • impossibility of integration of databases that were established for different purposes, containing personal information.
  • 5.2 Terms and purposes of personal data processing
    Administration processes personal information of Users in purposes of execution of contract between Administration and User in accordance with the User Agreement of the Platform. According to article 6 of Federal law from 27.07.2006 №152-FL, "On personal data," User's consent is not required. According to paragraph 2.2 of article 22 of the law mentioned above, Administration is allowed to process personal data without proper notice to the authorized body protecting the rights to personal data.
  • 5.3 Ways of processing personal data.
    • 5.3.1 Collecting, storage, systematization of personal data. Collecting, storage, systematization of personal data is done by Administration when signing-up, participating in certain Tournaments, and sequent voluntary adding information on the Platform. Personal data established by paragraph 4.1.1 of this Policy is provided by User and is a minimum when signing-up.
      Personal data established by paragraph 4.1.2 of this Policy is provided by User when taking part in specific Tournaments where provision of such data is a necessity. Personal data set in section 4.1.3 of this Policy is provided by User voluntarily. Personal data set in paragraph 4.1.4 of this Policy is provided by User voluntarily to get prize rewards, in case of winning a Tournament.
    • 5.3.2 Storage and use of personal data. Personal data is stored on the electronic devices and is processed by automatical systems; it may be processed by non-automatical systems as well when needed or to fulfill legal requirements.
    • 5.3.3 Transfering of personal data. Personal data of Users is not transferred to third parties unless otherwise provided in this Policy. The User consents that Administration is allowed to transfer personal data to third parties - partners of Administration (hereinafter "Partners"), provided that User agrees to have his data processed by such Partners. In this case, Users understand and agree that Partners are independent of Administration and do not interact on behalf of Administration or vice versa. Users should read the documents that define data processing by such Partners on their own.
      Providing Users' data upon request of the government department (local government) is done in the order provided by applicable law.
      In purposes of fulfilling the User Agreement of the Platform, concluded between User and Administration and providing User with access to functionality of the Platform, Administration develops, works on, introduces provided services and products and optimizes their quality, improves available functionality of the Platform and services. To fulfill the mentioned purposes, the User agrees that in compliance with law Administration may collect, store, accumulate, systemize, extract, compare, fill (clarify) data. Administration may also transfer to its affiliates results of automated processing of data with the use of various types of information assessment such as integral or text following given ones in request for processing by Administration or entities listed in this paragraph.
  • 5.3.4 Destruction of personal information. User's personal information is destructed in cases of:
    • erasure of personal data by User from his Game Account and making a request according to section 9 of this Policy;
    • erasure of personal data provided by User after 3 (three) years since last authorization on the Platform by Administration;
    • erasure of personal information by Administration via asking technical support VK.com https://vk.com/im?media=&sel=-42389024 to delete data provided and displayed by User or in other cases under User Agreement of the Platform or this Policy.
  • 5.3.5 Using personal information for marketing mailing.
    Administration of the Platform is allowed to use personal data of User to suggest special offers, products, and services that may be interesting for User. By providing an email address, User agrees to receive marketing emails, thus makes it a legal basis for processing personal information. Users may opt-out of marketing mailing at any time by clicking "unsubscribe" below the message send by Administration.

6. Rights and Obligations of Users

  • 6.1 Users are allowed to:
    • 6.1.1 change and correct personal information in Game Account on the Platform provided it is relevant and real. This right is restricted by User Agreement of the Platform, which does not allow changing of specific information after signing-up in Tournament;
    • 6.1.2 erase personal data from Game Account on the Platform. This right is restricted by Users Agreement of the Platform, which does not allow changing of specific information after signing-up in Tournament;
    • 6.1.3 request clarification of personal data, blocking of it, or erasure if it is incomplete, outdated, invalid, illegally received, or is not necessary to put in and if it is impossible to execute paragraphs 6.1.1 and 6.1.2 of these Rules. This right is restricted by Users Agreement of the Platform, which does not allow changing of specific information after signing-up in Tournament;
    • 6.1.4 request Administration for information about processing personal data;
    • 6.1.5 fulfill other rights under the applicable law of the Russian Federation.
  • 6.2 User is obliged:
    • 6.2.2 not to transfer personal data of other Users, not to establish databases using these data, which became known while using the Platform without any authority or statement in law;
    • 6.2.3 not to copy data of other Users which became known while using the Platform;
    • 6.2.4 provide Administration with requested information if it is provided in this Policy.

7. Measures to protect information about Users

  • 7.1 Administration takes technical and organizational measures to protect Personal Information against unauthorized access, destruction, alteration, blocking, copying, distribution, and other wrongdoings.
  • 7.2 For authorized Platform access, email address, or VK.com password are used. The User is responsible for the safety of the data. The User is not allowed to transmit his password to the third parties and shall provide its security.
  • 7.3 To fulfill the applicable law of the Russian Federation Administration uses databases located in territory of the Russian Federation while processing personal data.

8. Limitation of the Policy

This Policy does not apply to the actions and resources of the third parties, as well as processing of Users' data by Partners following paragraph 5.3.3 of this Policy.
Administration is not responsible for the actions of the third parties that gained access to personal information while using the Platform, as well as for consequences of use of information which is available for anyone because of the Platform's nature.

9. Users' appeal

  • 9.1 Users may request Administration about the use of their data, following paragraph 6.1.4 of this Policy, in written form: Russia, 125167, Moscow, Leningradsky Ave. d. 37, floor 12, placement 54, room 1, or using electronic document, signed by qualified electronic signature
    following the laws of the Russian Federation, by contacting technical support on [email protected]
  • 9.2 User's request shall contain the following information:
    number of identity document of the User or his representative;
    date of issuance and information about issuing authority of this document;
    Platform nickname;
    Signature of the User or his representative.
  • 9.3 The Administration undertakes to investigate the User's request and respond in 30 calendar days since the application has been received.
  • 9.4 All the received correspondence from Users (in written or electronic form) refers to limited access information and is not revealed without the written consent of the User. Personal data and other information about User may not be used without exclusive agreement otherwise for the response on the subject of request or in cases provided by applicable law.

10. Click-Storm Action Chess - based on https://www.kfchess.com/.