Welcome to Game Anti-Cheating Tool!

This privacy policy explains the when, how and why when it comes to the processing of your personal information in connection with the Game Anti-Cheating Tool, also known as GameAC Tool for short (the “App” or the “Service”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

When you sign-up to participate in a tournament or event, you may be required to download and install the Game Anti-Cheating Tool. The Game Anti-Cheating Tool ensures that competitive game play in other apps remains fair for all players. Doing so safeguards the integrity of gameplay by proving that the individual competing does so on his or her own, without assistance from others. In addition to reviewing this privacy policy, please be sure to review the privacy policy for the game or tournament in which you will be competing.

If you do not agree to the processing of your personal information in the way this privacy policy describes, please do not provide your information when requested and stop using the App. By using the App you are acknowledging our rules regarding your personal information as described in this privacy policy.

This App has been developed by Sixjoy Hong Kong Limited (“we”, “us”, “our”).

For the purpose of data protection laws, the data controller of your personal information in relation to the App is Sixjoy Hong Kong Limited. The registered address of Sixjoy Hong Kong Limited is Room 907, Wing Tuck Commercial Centre, 177-183 Wing Lok Street , Hong Kong.

Our data protection officer can be contacted at dpo_gameac-tool@sixjoy.com.

Our representatives for data protection purposes in certain jurisdictions are as follows:

EU	Proxima Beta Europe B.V.	Gustav Mahlerplein 2, 1082 MA, Amsterdam, the Netherlands	dpo_gameac-tool@sixjoy.com
Korea	Kite Bird Korea Yuhan Hoesa	25F, 55, Sejong-daero, Jung-gu, Seoul (taepyeongro 2-ga)	dpo_gameac-tool@sixjoy.com
Turkey	Özdağıstanli Ekici Avukatlık Ortaklığı.	Varyap Meridian Grand Tower ABlok Al Zambak Sok No: 2 K: 32 D. 270 Ataşehir Istanbul Turkey	turkeydatarep_proximabeta@iptech-legal.com

Please reach out to us if you have any questions or concerns regarding the processing of your personal information: you can contact us anytime at dpo_gameac-tool@sixjoy.com.

The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How we use your personal information” below.

The following is a high level summary of the types of personal information we use:

2. Information you provide to us (either directly or through a third party).

You give us information about you when you use the App. We will ask you to provide a photo before, during (as a screen capture) and after the match to verify your identity to ensure that you are the right person to play in the tournament (the comparison of the photos will be processed and conducted via a machine and will not be verified manually). We will ask you to allow us to record your live audio during the tournament to ensure the same person is playing the game (we will review the audio manually and by machine, which will verify your voice signature throughout the tournament).

We receive your email address when you register for a tournament that requires the App to be used or if your email is required to facilitate your access to the App.

2. Information about you generated as part of the App (and its in-App services)

We automatically collect certain data from you so that we can provide you with the many functions and services that comprise the App. We generate a unique INO ID and password for you and send this to your registered email address. When you use the App, we automatically collect your device model, device ID and IP address, IDFV, to provide you with our service, ensure you are using the correct device and verify that you are who you say you are. We also collect and store your data each time you interact with us, for example, if you contact our support team, we collect information including device details, information on the network you use, information on your browser, your email address and any information that you provide in your communications.

Children

Children must not use the App for any purpose, except where their parent or guardian has provided consent (to the extent this option is available in your jurisdiction). By children, we mean users under the age of 18 years old; or in the case of a country where the minimum age for processing personal information differs, such different age. For users located in certain countries we have listed the relevant minimum age below.

Country in which the user is located	Minimum age of the user
Algeria	19
Argentina	18
Australia	18
Bangladesh	18
Brazil	18
Colombia	18
Cambodia	18
Canada	13
Egypt	18
European Economic Area/ Switzerland	16
Hong Kong	18
India	18
Indonesia	21
Japan	20
Kingdom of Saudi Arabia	15
Kuwait	21
Macau	18
Malaysia	18
Mexico	18
Morocco	18
Myanmar	18
New Zealand	16
Philippines	18
Qatar	18
Republic of Korea	14
Singapore	18
South Africa	18
Sri Lanka	18
Taiwan	20
Thailand	20
Tunisia	18
Turkey	18
United Arab Emirates	21
United Kingdom	13

We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at dpo_gameac-tool@sixjoy.com and we will delete such information.

How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why.

For users who live in the United Kingdom, the European Economic Area, Switzerland, Brazil, Turkey or Thailand (the “Relevant Jurisdictions”), it also identifies the legal basis under which we process your data.

Personal Information	Use	Legal Basis (only relevant if you are located in a Relevant Jurisdiction)
App
Information you provide to us (either directly or through a third party)
Manually uploaded photos	We use this information to verify your identity as the active player of the relevant game. This check is conducted via an automated process.	We collect this information with your consent.
Live audio during the match	We use this information to verify your identity. We do this by carrying out manual checks and checks by a machine (which will compare your voice signatures throughout the tournament) for the purpose of identifying whether you complying with the rules of the game including checking whether you are teaming up with anybody else.	We collect this information with your consent.
Screen Capture (video)	As part of the anti-cheating measures, you will be asked to activate screen recording. Your video recording is not processed by us – it is only processed on your device. However, screenshots of the video screen capture will be taken once per 3 minutes (see below).	Not Applicable (only processed on-device).
Screen Capture (photo)	As noted above, screenshots will be taken of the video screen capture once per 3 minutes. We use this information to detect cheating behaviours in the game-environment including whether you are running any anti-cheating device software when playing the game.	We collect this information with your consent.
Email address	We use this information to provide you with: · a link to download the App (if required by the relevant app store); and · a unique INO ID and password so that you can log into the App.	Necessary to perform our contract with you to provide this App.
Information generated as part of the App (and its in-App services)
IP Address	We use your IP Address to ensure that you are from the region under which you have registered.	Necessary to perform our contract with you to provide this App.
INO ID and password	We use your generated INO ID and password to verify your identity when you log in.	Necessary to perform our contract with you to provide this App.
Device information: device model, OS version, app version, network type, battery status, device identifier, network signal information, screen size, QIMEI.	We use this information to verify the device/software you use to play the game for anti-cheating purposes.	Necessary to perform our contract with you to provide the App.
Security information: device information, and network data.	We use this information: · for security and verification purposes, including to detect cheating behaviours; · identify and address bugs and assess App function for optimisation; and · solve App crashes and optimise compatibility of devices with the App.	It is in our legitimate interest to ensure the security of the App, manage registrations and improve the App.
Support data, if you contact our support team: device details, email address and any information that you provide in your communications.	We use this information to provide troubleshooting, such as addressing and remediating technical issues and bugs.	Necessary to perform our contract with you to provide and support the App.

How We Store and Share Your Personal Information

Our corporate group operates around the world. Pursuant to our contract with you to provide you with this App, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this privacy policy. Our servers for this App are located in Singapore. In addition, your information can be accessed from outside of where you live by our support, engineering and other teams around the world (including the PRC, India, Brazil and the European Union).

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates, and in particular, to the PRC, India, Brazil and the European Union.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

· Companies within our corporate group who process your personal information in order to operate this App including our technicians and Esports security team so that they can assess whether any users are not complying with the rules of the game. All related group companies may only use your personal information in accordance with this privacy policy.

· Third party service providers who help us deliver the service to you, including providers of cloud services that process information identified in this policy on their servers for the purpose of providing the App, a third party to help us manage our admin dashboard and we also share your information with the third party operating the Esports tournament that you are participating in so that they can check whether any users are cheating.

Regulators, judicial authorities and law enforcement agencies, and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities, such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:

comply with a legal obligation, process or request;
enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
detect, prevent or otherwise address security, fraud or technical issues; or
protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law or similar obligations (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted to our services; therefore we do not assume any responsibility for any transmission of your information which you do at your own risk.

Data Retention

We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information	Retention Policy
All data	2 months from the date of upload or collection (as applicable).

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

Your Rights

Some jurisdictions’ laws grant specific rights to users of this App, which are set out in this section.

This section entitled “Your Rights” applies to users that are located in the Relevant Jurisdictions. If you are located in a territory outside a Relevant Jurisdiction, please refer to the Supplemental Jurisdiction-Specific Terms for an overview of your rights and how these can be exercised.

The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Brazil, Canada, Argentina, India and Russia.

You have certain rights in relation to the personal information we hold about you, depending on where you are located. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at dpo_gameac-tool@sixjoy.com.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. If you want to access the information we are holding about you, please contact us at dpo_gameac-tool@sixjoy.com.

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you, as described above in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer it to another party, with certain exceptions. We will provide further information to you about this if you make such a request.

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction

You have the right to correct any of your personal information we hold that is inaccurate. If you believe we hold any personal information about you and that information is inaccurate, please contact us at dpo_gameac-tool@sixjoy.com.

Erasure

You can delete your account, or remove certain personal information, by contacting us at dpo_gameac-tool@sixjoy.com.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on this App and there are grounds for erasure, we will use reasonable steps to try to tell others who are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at dpo_gameac-tool@sixjoy.com.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at dpo_gameac-tool@sixjoy.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend App access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these App-related announcements, which are not promotional in nature.

Contact & Complaints

Questions, comments and requests regarding this policy are welcomed and should be addressed to: to dpo_gameac-tool@sixjoy.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at dpo_gameac-tool@sixjoy.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.

Changes

If we make any changes to this privacy policy we will post the updated policy here. Please check this page frequently to see if there are any updates or changes to this privacy policy.

Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this privacy policy, the English version shall prevail.

SUPPLEMENTAL TERMS – JURISDICTION SPECIFIC

Some jurisdictions laws contain additional terms for users of this App, which are set out in this section.

If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our privacy policy above.

Algeria

By using this App, you give us your consent for the collection, storage, treatment and use of your personal information, and transfer of your personal information to a third party (local cloud providers to back up your data or our affiliates around the world to help us deliver the App) located in Algeria or PRC, India, Brazil and the European Union (as described in the Privacy Policy) where it is manually and electronically treated.

Argentina

Your rights

If you are dissatisfied with our response to your request for access to, correction, or erasure of your personal information or your privacy complaint in respect of your personal information, you may contact the Agency for Access to Public Information at: Av. Pte. Gral. Julio A. Roca 710, Piso 2°, Ciudad de Buenos Aires (Telephone: +5411 3988-3968 or email: datospersonales@aaip.gob.ar).

Data transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, by providing us your personal information and by using the App, you consent to the transfer of your personal information to a jurisdiction where privacy laws may not offer the same level of protection as the laws that may apply in Argentina.

Australia

Overseas Recipients

We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at dpo_gameac-tool@sixjoy.com .

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us atdpo_gameac-tool@sixjoy.com.

Children

If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the App.

Transacting Anonymously

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the App. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the App, including social media integration and purchases.

Your Rights

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone: +61 1300 363 992 or email: enquiries@oaic.gov.au).

Data Transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

Bangladesh

Agreement

By accepting this Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data, including disclosing to third parties, to the extent provided by this Privacy Policy. By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to PRC, India, Brazil and the European Union.

Age Restriction

In order to use the App, you represent that you are at least 18 years old and, therefore, legally capable of entering into binding contracts.

Brazil

Language

This Privacy Policy is provided in Portuguese for users located in Brazil. In case of dispute, the Portuguese version of this Privacy Policy shall prevail.

Consent Revocation

Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact dpo_gameac-tool@sixjoy.com. This may affect our provision of the App to you.

Parental and Guardian Consent

If you are under the age of 18, you should not use the App for any purpose without first obtaining parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf). We do not knowingly collect personal information from any children under the age of 18 without such consent. Please contact our Data Protection Officer if you believe we have any personal information from any children under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such personal information.

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

Canada

Service providers

If a user located in the province of Alberta, Canada, wishes to obtain written information about our policies and practices with respect to service providers, they may contact us at dpo_gameac-tool@sixjoy.com. Our privacy experts who monitor this email address are also able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers.

Colombia

How We Use Your Personal Information

From the entry into force of this Privacy Policy, at the time of the collection of your personal data, we will request your prior authorization, by informing you about the specific purposes of the processing of your personal data for which such consent is obtained under the Privacy Policy.

Your authorization may be expressed (i) by writing, (ii) orally or (iii) through unequivocal conduct that allow us to reasonably conclude that your authorization was granted, such as the act of accepting the Privacy Policy. We may keep evidence of said authorizations, while respecting the principles of confidentiality and privacy of information.

Your Rights

As a data subject you have certain rights, including (i) to access, update and rectify your personal data; (ii) to request a copy of the consent you have given us; (iii) to be informed about how we have processed your personal data; (iv) to file claims before your country’s data protection authority; (v) to revoke the consent you have given us to process your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons; (vi) to ask for the suppression of your personal data (right to erasure); and (vii) to freely access your information.

You can contact us if you want to exercise any of these rights through our contact information in the section ‘Contact & Complaints’ of this Privacy Policy.

Egypt

This Privacy Policy is provided in Arabic for users located in Egypt. In case of dispute, the Arabic version of this Privacy Policy shall prevail.

By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. If you do not consent to this Privacy Policy, you must not use the App.

You are acknowledging your consent to the processing, storage, and cross-border transfer of your personal data. The cross border transfer may be to any country in which we have databases or affiliates, in particular the PRC, Brazil, India and the European Union.

As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.

Hong Kong

As a Hong Kong data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations).

You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to reject to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

India

Age Restrictions

Children under the age of 18 are not allowed to execute online contracts with us or sign up for our services. Parental consent is required for children under the age of 18 years who wish to use our services. Where the users are children, their parents understand and acknowledge that our collection, storage and processing of personal information shared with us shall be used for the lawful purposes set out in this privacy policy and is considered necessary for the purposes of account verification, security and to support and improve the Service.

Your Rights (For India)

You have the right to access, correct and update your information. To do so, you may contact our grievance officer at dpo_gameac-tool@sixjoy.com.

Indonesia

Consent

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.

Parental and Guardian Consent

If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on and use the App.

Data Subject Rights

You have the right to access your personal information stored in our App from time to time in accordance with applicable data privacy laws and regulations in Indonesia.

Data Breach

In the event we fail to maintain the confidentiality of your personal information in the App, we will notify you through the contact information provided by you or via the App, to the extent required by local laws and regulations.

Data Retention

We will retain your personal information in line with legal requirements.

Notification to Amendment of this Privacy Policy

If you fail to explicitly express your objection to any amended version of this Privacy Policy within fourteen (14) days of the date the relevant amended version of this Privacy Policy is made available, you will be considered as having accepted the changes and agreed to the new Privacy Policy.

Data Accuracy and Third Party Consent

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Japan

If you are under the age of 20, you must obtain your parent’s or legal guardian’s consent to register an account on and use the App.

By clicking “accept”, you consent to the transfer of your personal information to third parties, which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Singapore, the PRC, India, Brazil and the European Union.

You may request us to notify purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us at dpo_gameac-tool@sixjoy.com.

Kingdom of Saudi Arabia

You consent to the collection, use, disclosure, export and storage of your personal information as described in this Privacy Policy.

Kuwait

You represent that you are at least 21 years old, or 18 years old and have obtained parental/guardian consent and, therefore, legally capable of contracting under the applicable laws and regulations in Kuwait.

By accepting this Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data and to disclose this data to third parties whether inside or outside of Kuwait, in line with the provisions of this Privacy Policy.

Macau SAR

You have the right not to provide your personal information. However, as a result, we may not be able to provide the App to you. As a Macau SAR data subject you have legal rights in relation to your personal information (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to request a copy of the data we process about you, to make a data correction request, and have the right to oppose the use of your personal information for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.

Malaysia

Language of this Privacy Policy

In the event of any discrepancy or inconsistency between the English version and Malay version, the English version shall prevail.

Parental and Guardian Consent

If you are under the age of 18, please do not use the App without parental/ guardian’s consent.

In the event you are agreeing to this Privacy Policy in order for a minor to access and use the App, you hereby consent to the provision of personal information of the minor to be processed in accordance with this Privacy Policy and you personally accept and agree to be bound by the terms in this Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor's compliance with this Privacy Policy.

Rights of Data Subjects

Right of access: You have the right to request access to and obtain a copy of information of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for access of your personal information in the amounts as permitted under law.

When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However this may affect our provision of the App to you.

Mexico

Language

This Privacy Policy is provided in Spanish for users located in Mexico. In case of dispute, the Spanish version of this Privacy Policy shall prevail.

Age Restrictions

You won’t be able to use the App unless you are 18 years old or you have obtained parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf).

Types of Personal Information We Use

For clarification purposes, in section 1 "The types of personal information we use” and section 2 “How we use your personal information” you can find full details about the personal data we use. Therefore, we are providing you with complete information about the personal data we use, in terms of the Federal Law on Protection of Personal Data held by Private Parties and other applicable regulations.

Purposes of Processing

Some of the purposes of processing stated above are for voluntary purposes, including to show you personalised recommendations and advertising. You may object the processing of your personal data for voluntary purposes as stated in the section “Your Rights” below.

Please, be informed that we may also use your personal data to comply with legal obligations or requests from competent authorities, assert or defend our rights before the competent authorities / courts, respond to requests you send us in relation to your personal data and to carry out the transfer of personal data detailed in section 3 “How we store and share your personal information”.

Data Transfer Consent

In general, we do not require your consent to carry out the transfers detailed in section 3 “How we store and share your personal information”. However, we require your consent to transfer your personal data to a third party that acquires all or substantially all of us or our business.

By using the App and providing us with your personal data, you agree to the data transfers detailed above that require your consent. You may exercise your rights in connection with your personal data as stated in the section “Your Rights” below.

Your Rights

The sub-sections entitled “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only “, which includes the limitation to the use and disclosure of your personal data included in Section “Your Rights” above also apply to users that are located in Mexico.

You also have the right to revoke the consent that you have provided us to process your personal data.

To exercise any of your rights, contact our Data Protection Officer at dpo_gameac-tool@sixjoy.com.

To know more about your rights, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact our Data Protection Officer at dpo_gameac-tool@sixjoy.com.

Morocco

The protection of your privacy is an important principle for us. We collect information for purposes strictly necessary for the proper use of the App.

By accepting these conditions of use, you explicitly accept that your personal data may be subject to processing by the App.

Kindly note:

· the purposes of the processing for which the data is intended are set out in the table in the section “How we use your personal information”.

· recipients or categories of recipients are set out in the second paragraph of the section “How We Store and Share Your Personal Information”.

· whether the answer to the questions is compulsory or optional, as well as the possible consequences of a lack of answer: please refer to the section “How we use your personal information” and the section “Your Rights” (sub-paragraph “Objection”).

New Zealand

This section applies to users located in New Zealand:

Overseas Recipients

We take reasonable steps to ensure that third party recipients of your personal information located outside New Zealand handle your personal information in a manner that is consistent with New Zealand privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

Access

Correction

You have the right to request the correction of any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo_gameac-tool@sixjoy.com.

Children

If you are under the age of 16, you undertake that you have the consent of your parent or legal guardian to register an account on and use the App.

Your Rights

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).

Data Transfers

Peru

Transfers and delegation of personal information occur as set out in this Privacy Policy and the section “Republic of Korea”.

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. pursuant to applicable laws such as the Personal Data Protection Law (the “Law”).

You may also exercise these rights through your legal guardian or someone who has been authorised by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Law.

Upon your request, we will take necessary measures without delay in accordance with applicable laws such as the Law.

You can also withdraw your consent or demand a suspension of the personal information processing at any time.

If you consider that your request has not been met you may file a claim with the Peruvian National Authority of Personal Data Protection.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

Data Protection Team, responsible for the management and safety of your personal information
Contact: dpo_gameac-tool@sixjoy.com

Philippines

Minimum Age

You must be at least 18 years of age to be able to use the App.

Your Rights

You are entitled to the following rights:

Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.
Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.
Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.
Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.
Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

Consent

By consenting to this Privacy Policy, you consent to us:

· collecting and processing your personal information as described in the section “How We Use Your Personal Information” above;

· sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and

· transferring or storing your personal information in destinations outside the Philippines as described in the section “How We Store and Share Your Personal Information” above.

Qatar

If you are using the App in Qatar, you consent (for the purposes of Law No. 13 of 2016 on the Protection of Personal Data, as may amended from time to time) to the processing of your information in accordance with this Privacy Policy.

Republic of Korea

We transfer Personal Information to overseas as follows:

Recipient (Contact Information of Information Manager)	Country to which Your Personal Information is to be Transferred	Date and Method of Transfer	Types of Your Personal Information to be Transferred	Purposes of Use by Recipients	Period of Retention of Use by Recipient
Aceville Pte Ltd	Singapore	Transmitted from time to time	See categories of Personal information in the main body	Storage of personal information	See above Data Retention in the main body.
Shenzhen Tencent Computer Systems Company Limited	PRC	Transmitted from time to time	See categories of Personal information in the main body	To verify whether players are cheating.	See above Data Retention in the main body.
Esports tournament vendors	Global	Transmitted from time to time	See categories of Personal information in the main body	To verify whether players are cheating.	See above Data Retention in the main body.

Data Destruction

Personal information is retained in accordance with the data retention periods as detailed in the section “Data Retention” above. Personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.

Your Rights

You may also exercise these rights through your legal guardian or someone who has been authorized by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Enforcement Regulations of the PIPA.

Upon your request, we will take necessary measures without delay in accordance with applicable laws such as the PIPA.

You can also withdraw your consent or demand a suspension of the personal information processing at any time.

Additional Use and Provision of Personal Information

In accordance with the PIPA, we may use or provide personal information within the scope of reasonably related to the initial purpose of the collection, in consideration of whether disadvantages have been caused to data subjects and whether necessary measures have been taken to secure such as encryption, etc. We will determine with due care whether to use or provide personal information in consideration of general circumstances including relevant laws and regulations such as the PIPA, purpose of use or provision of personal information, how personal information will be used or provided, items of personal information to be used or provided, matters to which data subjects provided consent or which were notified/disclosed to data subjects, impact on data subjects upon the use or provision, and measures taken to protect subject information. Specific considerations are as follows:

· whether the additional use/provision is related to the initial purpose of the collection;

· whether the additional use/provision is foreseeable in light of the circumstances under which personal information was collected and practices regarding processing;

· whether the additional use/provision unfairly infringe on the interests of the data subject; and

· whether the necessary security measures such as pseudonymization or encryption were taken.

Domestic Privacy Representative

Pursuant to the Article 32-5 of Network Act and Article 39-11 of the amended PIPA, the information regarding the domestic agent is as follows:

Name: Kite Bird Korea Yuhan Hoesa

Address: 25F, 55, Sejong-daero, Jung-gu, Seoul (taepyeongro 2-ga)

Telephone Number: +82-2-2185-0902 / E-mail: dpo_gameac-tool@sixjoy.com

Contact

Contact: dpo_gameac-tool@sixjoy.com

Singapore

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, Singapore, Brazil, India, the European Union, and the PRC (for the purpose of this Privacy Policy, this term excludes Taiwan, Hong Kong and Macau).

Access

You have the right to access your personal information, how we use it, and who we share it with. If you want to access the information we are holding about you, please contact us at dpo_gameac-tool@sixjoy.com.

Correction

You have the right to correct any of your personal information that is inaccurate. If you believe we hold any personal information about you and that information is inaccurate, please contact us at dpo_gameac-tool@sixjoy.com.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted at dpo_gameac-tool@sixjoy.com.

South Africa

You have the right to lodge a complaint with the Information Regulator (South Africa) by emailing it at inforeg@justice.gov.za. The Information Regulator (South Africa)’s physical address is 33 Hoofd Street Forum III, 3rd Floor Braampark, Braamfontein, Johannesburg, South Africa.

Sri Lanka

By clicking “accept”, you consent to the terms and conditions of the Privacy Policy and permit the collection, use and disclosure of your personal information. However, if you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the App.

Where you request to withdraw consent or, refrain from further processing of data or, erase or, rectify or, complete your personal information, we will provide you with our response to the request within 21 working days.

Taiwan

We do not knowingly collect or solicit personal information from anyone under the age of 7 or knowingly allow such persons to register on the App platform. If you are under 7 years of age, please do not attempt to use or register for our App or send any personal information about yourself to us. No one under the age of 7 may provide any personal information to us while using the App. In the case of users located in Taiwan, persons under the age of 20 are required to obtain parental/guardian consent prior to using the App.

Thailand

By clicking “accept” below, you acknowledge that you have read, understood, and agree to this privacy policy. If you do not agree with this privacy policy, you must not use the App.

You may request us to discontinue, to restrict the use or provision of, and/or to request for data portability of any and all of your personal information which is stored by us, to the extent provided by the Act on the applicable data privacy laws and regulations in Thailand, including the Thai Personal Data Protection Act. When you wish to make such requests, please contact us at dpo_gameac-tool@sixjoy.com.

We will also give you notice by email of any changes to this privacy policy, and give you an opportunity to reject such changes, failing which the changes will become effective as stated in the notice.

Turkey

Our Data Controller Representative in Turkey is Özdağıstanli Ekici Avukatlık Ortaklığı for the purpose of compliance with Turkish Law on Personal Data Protection Law (“DPL”) and its secondary regulations can be contacted at turkeydatarep_proximabeta@iptech-legal.com. Please include the word “Turkey” in the subject line of your email.

You have legal rights, which are set forth in Article 11 of the DPL, in relation to the personal information data we hold about you. As a Turkish data subject, you may have right to apply to the data controller and (and to the extent permitted under applicable laws and regulations):

a) learn whether or not your personal data has been processed;

b) request information about processing if your personal data has been processed;

c) learn the purpose of processing of your personal data;

d) know the third parties in the country or abroad to whom personal data has been transferred;

e) request rectification in the event personal data is incomplete or inaccurate;

f) request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the Personal Data Protection Law (Turkey);

g) object to certain processing of data, and seek certain remedies in accordance with the Personal Data Protection Law (Turkey).

Ukraine

By accepting this Privacy Policy, you expressly authorize us to collect, use, store, and process your personal data, including disclosing to third parties and transferring to countries other than Ukraine, to the extent and for the purpose provided by this Privacy Policy.

United Arab Emirates

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws) and storage of your personal information, as described in the Privacy Policy.

We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber security threats in the UAE.