Privacy

Privacy Policy

 

  1. Introduction
  2.  Personal information that we collect
  3.  Information we collect through Cookies and similar technologies
  4. Information collected from third parties and how we use it
  5. How we use your Personal Information
  6. Disclosure of your Personal Information
  7. Marketing Preferences
  8. Transfer of your Personal Information outside of the EEA
  9. Updating your Personal Information
  10. Your rights
  11. Retention of your Personal Information
  12. Changes to our Policy
  13. Security
  14. Contact Details

1. Introduction

1.1. This privacy policy (“Privacy Policy”) sets out how FTX Games Ltd (CY) Limited (“we” or “us”) whose registered office is at 146-148 Strovolos Avenue, Petousis Building, 2048 Strovolos, Nicosia, Cyprus, will use the personal information that you provide to us or we collect from you, or which is provided to us by a third party (for example, the operator of a social network or an app store) on your behalf, in relation to your use of the Services (as defined in the Terms of Service (“Terms”)). This Privacy Policy is incorporated into and subject to the Terms.
1.2. We are committed to protecting your privacy. This Privacy Policy sets out the basis on which your personal information (meaning information which, on its own or in combination with other information, can be used to identify you) will be processed by us. By using our Services, you acknowledge, understand and agree to this policy, and that both we and any of our group companies, as well as any partners and subcontractors will process your Personal Information in accordance with this Privacy Policy, including for the purposes set out in section 7 below. If you do not wish to provide your Personal Information on the basis set out in this Privacy Policy, you should not enter the relevant information on our Services, or otherwise provide us with your Personal Information. However, if you do not provide your Personal Information, you may not be able to use all of the Services. We aim to only process your personal data where it is necessary. We will always keep your personal data secure. Your enjoyment of our services and your safety are our primary concerns.
1.3. This Privacy Policy may be amended from time to time providing you with prior notification. We will publish the revised Privacy Policy on the Services and you should review the Privacy Policy periodically to review any changes. We recommend that you print out a copy of this Privacy Policy for your records.
1.4. Since the Services are accessible via social networking sites and app stores, if you access the Services in that way you should read and accept the terms and conditions of the relevant third party, as well as their privacy policies and other relevant documents. We do not accept any responsibility or liability for such third party policies, nor do we endorse such websites, social networks or services. Please check before you submit any personal information to these third parties.

2. Personal information that we collect

2.1. As part of providing our Services, we collect Personal Information from you or from a third party (for example, a social networking site or app store) acting on your behalf. “Personal Information” means any information from which you can be personally identified, including first name, surname, email address, date of birth, home address, user ID/username and profile picture.
2.2. In addition, when you download, install, access and/or use the Services, we may record information relating to your use of the Services.
2.3. We may collect personal information which is available on your social network page in accordance with the terms of service of the relevant social network operator.
2.4. You agree that you will only provide information to us that is accurate, complete and up-to-date, and that you will notify us of any changes to your Personal Information.

3. Information we collect through Cookies and similar technologies

3.1 We may collect anonymous information about your use of the Services using “cookies”, pixel tags and similar functionality. A “cookie” is a small file of text which is downloaded onto your access device used when you access the Services, and it allows us to recognise when you come back to use our Services. We use cookies for the operation of our Services, and to remember you when you return to the Services. We also use cookies for our own analytical purposes so that we can identify where users have encountered technical problems on the Services, and therefore help us improve our customers’ experiences. We also use services provided by third parties for fraud prevention purposes. For these purposes, Cookies are placed on your device to identify it in the future when you use our Services.
3.2. We don’t store your personal information in cookies we create, but we do use encrypted information gathered from them to help improve your experience of the Services.
3.3. By using the Services, you expressly agree to us placing cookies on your computer or other access device for the purposes set out in this Privacy Policy.
3.4 The cookies used on the Services are either set by us or by our third party service providers, and fall (without limitation) into the following category:
Targeting – these Cookies record the fact that you have used our Services, including which web pages you have accessed, which device you have accessed them from and which links you have followed. We use this information to make our Services relevant to your interests and for fraud and website abuse detection purposes, including detecting users who have abused offers and/or promotions.
Some of these are “session cookies”, which stay in place only for the duration of your visit to our Services and are deleted at the end of your browsing session. Others are “persistent cookies”, which remain on your device for a period of time after you have stopped using our Services.
3.5. During your use of the Services, third parties (for example advertisers or a social network) may also place cookies on your computer or other access device, over which we have no control. Please check their privacy policies for details of how they use the data they collect in this way.
3.6. Most web browsers have cookies enabled. If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software.
3.7. Information on deleting or controlling cookies is available at narcos@ftx.com. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of the Services.

4. Information collected from third parties and how we use it

We use information from third party service providers, such as a social networking site or an application store. Third party service providers help us verify your identity by registering and remembering your device information (such as the model, operating system, browser version and IP address), which is used to confirm device identification.

5. How we use your Personal Information

5.1. In accordance with data protection laws, we will only process your Personal Information where we have a lawful basis for doing so. In respect of your Personal Information, these bases are: (i) where it is necessary to provide services to you under the performance of the contract we have with you; (ii) where we are required to do so in accordance with legal or regulatory obligations; (iii) where you have given your consent; and, (iv) where it is in our legitimate interests to process your Personal Information, provided that none of these prejudice your own rights, freedoms and interests.
5.2. The following are a list of the “Purposes” for which we (including any of our agents, group members, sub-contractors and/or employees) process your Personal Information, and the lawful basis on which we carry out such processing:

Purpose

Lawful Basis

To provide, modify, improve and personalize our Services Necessary for the performance of a contract
To facilitate the purchase of any Virtual Items (as defined in the Terms) Necessary for the performance of a contract
To receive and respond to your communications and requests Necessary for the performance of a contract where such communication relates specifically to our Services, otherwise consent
To ensure that the Services are presented in the most effective manner for you and your computer or other device from which you access the service Necessary for the performance of a contract
To allow you to participate in interactive features of the Services if you wish to do so; Necessary for the performance of a contract
To comply with our obligations under applicable Laws and to regulators in jurisdictions where we and members of our group are based Necessary to comply with a legal or regulatory obligation
To investigate, and assist with the investigation of, suspected unlawful, fraudulent or other improper activity connected with our Services (including, the sharing of information and disclosure to such authorised entities) Necessary to comply with a legal or regulatory obligation
To carry out market research campaigns Legitimate interests so that we can better understand the products and services that our customers most enjoy
To prepare statistics relating to the use of our Services by you and other customers Legitimate interests so we can understand the use of, and therefore improve, our Services
To provide you with information about, and support for, our Services, including changes to our Services, technical updates to our Services, and changes to the Terms (including this Privacy Policy) Necessary for the performance of a contact and necessary to comply with a legal or regulatory obligation
To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes Legitimate interests so we can send you information about our Services (and promotions and offers) that you may be interested in, and Consent
To keep you informed of offers and promotions relating to our Services and those of other entities within our group, provided that you don’t “opt-out” from this option Legitimate interests so we can send you information about our Services (and promotions and offers) that you may be interested in
To keep you informed of offers and promotions for which you have specifically opted-in Consent
For general marketing purposes, but only where you have provided your express and informed consent Consent
To support any other purpose necessary for performance of our contractual obligations or specifically stated at the time at which you provided your Personal Information Necessary for the performance of a contract

6. Disclosure of your Personal Information

We may, for the Purposes specified above, disclose your Personal Information to any of the following recipients:

6.1.1. any company within our group (including to its employees and sub-contractors) which assists us in providing our Services or which otherwise has a need to know such information;
6.1.2. any third party which assists us in providing our Services, including (but not limited to) payment processors, customer services representatives and chat moderators;
6.1.3. any third party which can assist us in verifying the accuracy of your Personal Information,
6.1.4. any third party which assists us in monitoring use of our Services, including the detection and prevention of fraud and collusion,
6.1.5. any contractors or other advisers auditing any of our business processes or who have the need to access such information for the purpose of advising us;
6.1.6. any law enforcement body which may have any reasonable requirement to access your Personal Information;
6.1.7. any regulatory body or authorised entity which may have any reasonable requirement to access your Personal Information; and
6.1.8. any potential purchaser of our business or any investors in it or in any company within our group (including in the event of insolvency)
If at any time you wish us to stop processing your Personal Information for the above Purposes, you should contact us and we will take the appropriate steps to stop doing so. Please note that this may mean that your account will be closed.

7. Marketing

7.1 Neither we nor any company in our group will send you unsolicited information regarding any third party’s products or services.

Unless you have informed us that you wish to receive promotional information and emails, we will not send you such communications.

8. Transfer of your Personal Information outside of the EEA

Your Personal Information will be transferred outside of the European Economic Area, both to us and other members of our group. This includes, but is not limited to, Russia and Israel. Where we transfer your personal data outside of the EEA, we will put in place adequate measures to ensure that your Personal Information is kept secure (and such adequate measures shall include (without limitation): (i) transferring to a jurisdiction which the European Commission recognises as providing adequate protection for the rights and freedoms of data subjects in connection with the processing of their personal data; and (ii) transfers pursuant to standard contractual clauses in accordance with European Commission decisions on transferring personal data).

9. Updating your Personal Information

You may update or delete your Personal Information at any time via the Services or by contacting our Customer Services team.

10. Your rights

10.1. You have the following rights in relation to your Personal Information:

10.1.1. a right to access your Personal Information as held by us;

a right to receive certain Personal Information in machine-readable format;

a right to object to processing where the lawful basis is that it is in our legitimate interests, but please note that we may still process your Personal Information where there are other relevant lawful bases or where we have compelling grounds to continue processing your Personal Information in our interests which are not overridden by your rights, interests or freedoms;

a right to have inaccurate Personal Information rectified;

a right to have certain Personal Information erased where it is no longer necessary for us to process it, where you have withdrawn your consent pursuant to paragraph 10.1.8, where you have objected pursuant to paragraph 10.1.3, where your Personal Information has been unlawfully processed, or where erasing your Personal Information is required in accordance with a legal obligation;

a right to request an explanation of the logic involved where we make decisions about you solely through automated means;

a right to complain to your national data protection regulator;

where we have specifically requested your consent to process your Personal Information and have no other lawful conditions to rely on, you have the right to withdraw this consent; and

a right to object to direct marketing, which can be done by opting-out of direct marketing either through your account or by opting out via the communication itself. You also have a right to object to any profiling to the extent that it relates to direct marketing only.

If you are unsure about your rights or are concerned about how your Personal Information may be processed, you should contact your national data protection regulator.

We have appointed a data protection officer (DPO) who is responsible for all requests relating to the privacy of your Personal Information. If you would like to exercise any of your rights then you can do so by contacting us as at privacy@ftxgames.com . Please be aware that while we will try to accommodate any request you make in respect of your rights, they are not absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.

Where you make a request in respect of your rights we will require proof of identification. We may also ask that you clarify your request. If we receive repeated requests, or have reason to believe requests are being made unreasonably, we reserve the right not to respond.

11. Retention of your Personal Information

We will retain your Personal Information for the period necessary for us to provide you with our Services. Accordingly, your Personal Information will be retained up to 3 years following the last game session in any of our games. Where it is no longer necessary for us to process your Personal Information, we will delete it. Please note, however, that we may be subject to legal and regulatory requirements to keep personal data for a longer period, in particular pursuant to any applicable statutory limitation period.

12. Changes to our privacy policy

We may change this privacy policy at any time: please take a look at the “LAST UPDATED” date at the top of this page to see when this privacy policy was last revised. Any amendments to this privacy policy will come into effect a reasonable period of time after this “LAST UPDATED” date (normally we consider 30 days to be a reasonable time period) unless you contact us before that date to discuss or query any of the amendments.

13. Security

13.1. We are committed to ensuring that your Personal Information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the Personal Information that we collect.
13.2. All the Personal Information that you provide us is stored in a secure computing environment protected by secure firewalls to prevent unauthorized access. We control access so that only people who need to access the Personal Information can.  All staff are provided security training and are required to adhere to a comprehensive set of security policies, procedures, and standards related to their jobs.
13.3. When you use secure areas of our Services, we use SSL with 2048bit encryption. This means that all the information sent between your computer and our secure computer environment is encrypted or scrambled so that no one can read it in transit. Secure areas of the site have a time-out feature. If you leave your secure session inactive for some time, it times-out to prevent unauthorized access.
13.4. Where your Personal Information needs to be disclosed to our service providers, we require them to process and protect your Personal Information in a manner consistent with this Privacy Policy and applicable laws.

14. Contact details

If you have any questions, comments or requests regarding this Privacy Policy please contact us via narcos@ftxgames.com.

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