Privacy Policy

Last Updated: 5/30/19

Introduction

FTX Games Ltd. whose registered office is at 146-148 Strovolos Avenue, Petousis Building, 2048 Strovolos, Nicosia, Cyprus and its affiliates (“FTX Games,” “we,” “our,” and/or “us”) value the privacy of individuals who use our applications, games, websites, social media services and other products and services (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from users of our Services (“Users” or “you”).
By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our End User License Agreement and Terms of Service.

Information We Collect

As part of providing our Services, we may collect a variety of information from or about you or your devices from various sources, as described below. 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 information.

A. Information You Provide to Us.

Registration and Profile Information. When you sign up for an account, or sign up for notifications or updates, we may collect your name, email address, gender, company name, birthday, and phone number. By signing up via social media channels like Twitter, we would receive personal data from them regarding yourself, for example: name, email address, gender, date of birth and profile photo. We can only obtain such data if the underlying permissions have been granted by you via the social media channels connected to our game network. Should you wish to deactivate or withdraw these permissions, you would need to go to the social media accounts and amend your permission in line with their privacy policies. You will also have to inform us directly in line with your social media permissions, so we can apply your preferences.

Communications. If you contact us directly, we may receive additional information about you. For example, when you contact our customer support team, post in chat sessions or request to receive updates about our product launches, we may receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide.

Forums. If you post on one of our community forums, we collect the information you choose to provide, including comments, messages, and posts. Please ensure you do not share more than your own personal data within these open forums, as others will be able to see the shared contents. You as a player are solely responsible for the contents of your messages and other communications.

B. Information We Collect When You Use Our Services.

Device Information. When you use, play or access the Services we receive information about the device and software you use to access our Services, including IP address, web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers – IDFA (Apple devices) and GAID (Android devices), mobile advertising identifiers, and push notification tokens.

Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, the searches you conduct, any content you post, and the dates and times of your visits.

Information from Cookies and Similar Technologies. We and our third-party partners (such as analytics and advertising providers) may collect information about your online activities over time and across different services using cookies, pixel tags, or similar technologies (e.g. mobile advertising identifiers).

Cookies are small text files containing a string of alphanumeric characters. We may use session cookies, persistent cookies and targeting cookies, as well as Google Analytics (a web analytics service provided by Google, Inc.). A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.

Most web browsers have cookies enabled. Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.

You can find out more about our use of cookies and such technologies in our Cookie Policy here. The Cookie Policy forms part of this Privacy Policy.

C. Information We Collect from Third Parties.

We use information from third party service providers, such as a social networking sites 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.

How We Use the Information We Collect

In accordance with data protection laws, we will only process your information where we have a lawful basis for doing so. In respect of your 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 information, provided that none of these prejudice your own rights, freedoms and interests.
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 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

If at any time you wish us to stop processing your 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.

How We Share the Information We Collect

Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Services (e.g. payment processors, customer services representatives, attribution and analytics partners and chat moderators).
User Content.  Our forums are social in nature, allowing you to review content posted by others and post content yourself. In addition to the content you post, your username and public profile content will also be accessible to other Users on the Service. We are not responsible for other Users’ use of available information, so you should carefully consider whether and what to post or how you identify yourself on the Services.

Analytics Partners. We use analytics services to collect and process certain analytics data.. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

There may be other third parties collecting analytics data from you depending on the platform you access our Services from.

As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement or regulatory requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.

Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.

Corporate Group. We may transfer your information to any company within our group (including to their employees and sub-contractors) which assists us in providing our Services or which otherwise has a need to know such information, in accordance with applicable law.

Verification and Monitoring. We may need to share your information to third parties who assists us in verifying the accuracy of your information. We may also need to engage third parties who assist us with monitoring use of our Service, to detect and prevent fraud and collusion.

Advisors. We may need to share your information with our contractors or other advisors auditing any of our business processes or who have the need to access such information for the purpose of advising us.
Consent. We may also disclose your information with your permission.

Your Choices

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us. We will never share your information with third parties for their own marketing purposes without first obtaining your consent.

Third Parties

Our Services may contain links to other websites, products, or services that we do not own or operate.  We are not responsible or liable for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

Security

We are committed to ensuring that your 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 information that we collect.
All the 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 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. 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. We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as our Services are hosted electronically, we can make no guarantees as to the security or privacy of your information.
Where your information needs to be disclosed to our service providers, we require them to process and protect your information in a manner consistent with this Privacy Policy and applicable laws.

Children’s Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services are directed to children. Legally you must be at least 13 years old to use the Services (but this might be older depending on whether or not a particular Service has a required minimum age rating) as per our Terms of Service. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at support@ftxgames.com.

Data Transfers outside the EEA

We predominantly use Amazon Web Services, which is certified under the EU – US Privacy Shield Framework, for our Services: https://aws.amazon.com/compliance/eu-us-privacy-shield-faq/

You acknowledge that your 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, Israel, Los Angeles USA, San Francisco USA, California USA and Georgia USA. Where we transfer your personal data outside of the EEA, we will put in place adequate measures to ensure that your 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).

Update Your Information or Pose a Question

You can update your account and profile information or close your account through settings within the Services. If you have questions about your privacy on the Services or this privacy policy, please contact us at Privacy@FTXgames.com.

EU Data Subject Rights

If you are based in the European Union, you have the following rights in relation to your information:
(i) a right to access your information as held by us;
(ii) a right to receive certain information in machine-readable format;
(iii) 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 information where there are other relevant lawful bases or where we have compelling grounds to continue processing your information in our interests which are not overridden by your rights, interests or freedoms;
(iv) a right to have inaccurate information rectified;
(v) a right to have certain information erased where it is no longer necessary for us to process it, where you have withdrawn your consent pursuant to paragraph (viii), where you have objected pursuant to paragraph (iii), where your information has been unlawfully processed, or where erasing your information is required in accordance with a legal obligation;
(vi) a right to request an explanation of the logic involved where we make decisions about you solely through automated means;
(vii) a right to complain to your national data protection regulator;
(viii) where we have specifically requested your consent to process your information and have no other lawful conditions to rely on, you have the right to withdraw this consent; and
(ix) 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 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 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.

Retention of your information

We will retain your information for the period necessary for us to provide you with our Services. Accordingly, your 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 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.

Changes to this Privacy Policy

Our company keeps its privacy policy under regular review and places any updates on this page and the revised version will be effective when it is posted. Please take a look at the “LAST UPDATED” date at the top of this page to see when this privacy policy was last revised; this privacy policy was last updated on 27th May. If we materially change the ways in which we use or share personal information previously collected from you through the Services, we will notify you through the Services, by email, or other communication. If you do not agree to the new version, you must stop using the Services completely – in order to make the Services work properly we need to have everyone using them under the same rules instead of different people having different rules.

Contact Information

If you have any questions, comments, complaints or concerns about our processing activities, please email us at Privacy@FTXgames.com or write to us at 146-148 Strovolos Avenue, Petousis Building, 2048 Strovolos, Nicosia, Cyprus.
Should you wish to report a complaint or if you feel that Our company has not addressed your concern in a satisfactory manner, you may contact the Office of the Commissioner for Personal Data Protection http://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/page1i_en/page1i_en?opendocument