Enthusiast Gaming Inc. (“us”, “our” and “we”) thanks you for your interest in our website, www.enthusiastgaming.com, or any other website on which this Policy is posted, and the activities, products, services and content that we may offer from time to time (collectively, the “Services”).
We value the privacy of those who visit and/or use the Services (individually, “you” or collectively, “Users”). We take your privacy seriously and make it a priority to protect personal information that we obtain from and about our Users.
Although the information in this Policy is generally intended to apply to all visitors and users of our Sites, certain sections only apply to certain individuals. In this respect, residents of California should consult the section titled “Additional Data Rights Applicable to California Residents” for rights that apply to them, and residents of the European Economic Area (“EEA”), which includes the member states of the European Union (“EU”), and of the United Kingdom and Switzerland, should consult the sections of this policy relating to the “Additional Data Rights Applicable to EEA Residents” and “International Data Transfers” for provisions that may apply to them.
i. Session cookies: Session cookies store information only for the length of time that you are connected to a website – they are not written onto your hard drive. Once you leave the website, they expire and are no longer active. We use session cookies to record certain information from your browser including your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, operating system and the dates and times that you use our website. Additionally, we may record certain information regarding your browsing of our website. Session cookies allow us to gather statistical data which provides insight into how we may improve our Services and to identify your current session to our web server.
ii. Persistent cookies: Persistent cookies store information on your hard drive and can be re-read when you return to the site that placed them on your hard drive. We use persistent cookies to remember your preferences and to help block unauthorized attempts to access your Personal Information.
iv. Location information. We may collect and store information about your location if you enable your computer or mobile device to send us location information. You may be able to change the settings on your computer or mobile device to prevent it from providing us with such information.
c. Interactive Information. When you view ads served by us or have other interaction with ads served by us, we may collect information about your interaction with such ads, for example, information that you have viewed or clicked an ad.
d. Third-Party Web Beacons. We may also implement third-party content on our website that uses “clear gifs”, “web beacons” or other similar techniques, which allow third-party content providers to read and write cookies to your browser, or implement similar tracking mechanisms, in connection with your viewing of that third-party content displayed on our website. This information is collected directly by the third-party, and we do not participate in that data transmission. Information collected by third parties in this manner is subject to that third-party’s own data collection, use, and disclosure policies.
f. Your relationship with us. We will collect information arising from your relationship with and through us and your use of the Services. For example, we maintain a record of your name and email address and when you send us an e-mail, speak with one of our telephone service representatives, or communicate with us through any other means, we may monitor, record and retain those communications for our mutual protection and in order to process your inquiries, respond to your requests and improve our Services.
HOW AND WHY YOUR PERSONAL INFORMATION IS USED
a. To Serve you. We use the Personal Information that you provide or that we collect for legal and regulatory purposes, to manage business risks, to provide our Services to you and to establish and enhance our relationship with you. We generally use the Personal Information you provide or that we collect to operate, maintain, enhance, and provide our Services. For example, we may use your Personal Information to: respond to specific requests from you; to help us better understand your use of the Services; and to administer the Services and protect the security of the Services when necessary. The Services may allow you to submit feedback. Should you choose to submit feedback, you consent to us contacting you by way of follow-up e-mail or phone call to discuss your feedback.
b . Aggregate Information. We may generate non-identifying and aggregate profiles from the information you provide during registration for our Services and through your use of our Services. Non-identifying and aggregate profiles are used to improve the quality of our Services and to develop new Services. Aggregated non-personally identifying information may be shared with third parties
c. Marketing and Experience. We may use your Personal Information to provide you with information about our features, services and other offerings that may be of interest to you and facilitate your participation in sweepstakes or contests and to fulfill prizes. This information may be provided to you by mail or phone and/or, with your prior consent, by email. We may also send information or offers to groups of Users on behalf of other businesses. We may share your Personal Information with certain other websites that we link to, to the extent that you click on such links, in order to enhance your experience in connection with our website.
a. Our subsidiaries or affiliates. We may share your Personal Information with our subsidiaries or affiliates (the “Group”) for: fraud or crime prevention, suppression or detection; for legal and regulatory purposes and to meet regulatory, legal or reporting requirements; to manage business risks; to perform analytics; to ensure that we have correct and up to date information about you; and to the extent necessary if you have requested a Service that is jointly offered by more than one member of the Group. We may also share your Personal Information to better manage your total relationship with the Group and enable other members of the Group to bring suitable Services to your attention. We may share your Personal Information within the Group for these purposes unless prohibited by law or you tell us not to.
b. Suppliers. We may use other companies, to provide certain Services on our behalf. We may share your Personal Information with our suppliers, agents and other organizations that perform Services for us or on our behalf to the extent necessary to provide and administer the Services that you have requested from us. These companies will only be given the information needed to perform those Services. Our suppliers may perform activities outside of your jurisdiction. As a result, your Personal Information may be used, stored or accessed in other countries and may be subject to the laws of those jurisdictions. These companies may be required to disclose your Personal Information in response to valid demands or requests from governments, regulators, courts and law enforcement authorities in those jurisdictions or countries.
c. Partners. We may share your Personal Information with third parties, which we partner with, for example on a promotion or competition. Such partners will process your Personal Information in accordance with their own privacy policies, which we encourage you to read.
d. Corporate Restructuring. We may share some or all of your Personal Information in connection with or during a merger, financing, consolidation, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets, or in the unlikely event of bankruptcy. If another company acquires our company, business, or assets, that company will possess the Personal Information we collected and will assume the rights and obligations regarding your Personal Information as described in this Policy.
e. Where required by law. We may disclose your Personal Information if we have a good faith belief that access, use, preservation or disclosure of such Personal Information is reasonably necessary to satisfy any applicable law, regulation, self-regulation, legal process or enforceable governmental request. When we provide Personal Information in response to a legal inquiry or order that we believe to be valid, we disclose only the Personal Information that is legally required. Note that we may store or process your Personal Information outside of your jurisdiction which physical storage of your Personal Information may span multiple jurisdictions or countries and we may disclose your Personal Information in response to valid demands or requests from governments, regulators, courts or law enforcement authorities in those jurisdictions or countries.
f. Protection of our interests. We may also disclose your Personal Information if we believe, in good faith, that it is appropriate or necessary to take precautions against liability; to help us collect a debt or enforce an obligation owed to us by you; to protect against fraudulent, abusive, or unlawful uses; to investigate and defend ourselves against any third-party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of our Services; or to protect the rights, property, or personal safety of our Users, employees or others.
g. Social Networks. We may share your Personal Information with Social networks for the reasons described above.
h. Consent. We may disclose your Personal Information where you have authorized us to do so. For example, if you have given us consent, we may share your Personal Information with business partners and other entities that are not affiliated with us who would like to send you information about their products and services. We do not share Personal Information with other third-party organizations for their marketing or promotional use without your consent or except as part of a specific program or feature for which you will have the ability to opt-in.
We retain the Personal Information we receive as described in this Policy for as long as you use our Services or as necessary to fulfil the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. This length of time will vary depending on the Service and the nature of the information and may extend beyond the end of your relationship with us.
In determining this, we will be considerate of the amount, nature and sensitivity of the Personal Information, the potential risk of harm to the Personal Information, and whether our purposes can be achieved through other means.
PROVIDING OR WITHDRAWING YOUR CONSENT
You may withdraw your consent provided that: you provide reasonable notice; we are not legally required to collect, use or disclose your Personal Information; and withdrawing your consent does not impede our ability to fulfill our obligations to you. You may withdraw your consent by contacting us at [email protected] Our staff will be pleased to explain your options and any consequences of refusing or withdrawing your consent, and record your choices.
Several of the privacy preferences available to you, subject to legal, business or contractual requirements, are outlined below.a. Direct marketing. The Services may provide an option for you to consent to receive information that may be of interest to you such us our newsletters and updates on our new services through various channels including direct mail, telephone, electronic or other means. You may opt-out of receiving such communications from us at any time by clicking on the “unsubscribe” link in any such electronic messages or by contacting us at [email protected] We will honor your opt-out instructions within 10 business days after we are informed of your request without any further action being required by you.
b. Sharing with our subsidiaries, affiliates or Suppliers. We may share your Personal Information with the Group or our suppliers, agents and other organizations that perform Services for us or on our behalf for the reasons outlined in paragraphs 3(a) and 3(b) above. If you withdraw your consent for this sharing, we may not be able to provide you with your requested Service.
Please note that we may store or process your Personal Information outside of your jurisdiction. The physical storage of your Personal Information may span multiple jurisdictions or countries and the governments, regulators, courts or law enforcement authorities in those jurisdictions or countries may be able to obtain disclosure of your information through applicable laws. Your use of the Services or your submission of any Personal Information to us will constitute your consent to the transfer of your Personal Information outside of your jurisdiction, which may provide for different data protection rules than those in your own jurisdiction.
OUR COMMITMENT TO CHILDREN’S PRIVACY
We process minor’s personal information according to requirements of related laws and regulations. Except as otherwise provided by law, we will only collect, use, store, disclose, or make available to the public the personal information where permitted by law, with consent of parents or other guardians, or for the necessity of protection of the minors. If we notice the collection of personal information of minors without verifiable consent of parents, we will take measures to delete related information as soon as possible.
If you are parents or other guardian of minors, please contact us at [email protected] when you have any question regarding to the protection of minors.
If you are Users in the U.S., we ensure that we comply with the Children’s Online Privacy Protection Act (COPPA). If our business partners operate applications directed to children under the age of thirteen (13) or knowingly collect, use or disclose personal information of children under the age of thirteen (13) during our cooperation, they will obtain verifiable parental consent for us to collect, use or disclose such personal information according to this Policy. Further, such business partners must enable the COPPA settings when using our Services. This allows us to ensure that any persistent identifiers collected about Users of applications that are flagged as “child-directed” will be processed according to the requirements of COPPA, including not being used to serve behaviorally-targeted ads or track users for such purposes in violation of COPPA. In addition, we will not knowingly collect any other personal information (such as the precise geo-location of Users’ devices) from Users that we know to be directed to children under the age of thirteen (13).
If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should promptly contact us at [email protected] and we will take reasonable steps to ensure that such information is deleted from our files.
We take commercially reasonable steps to protect our customers’ Personal Information against unauthorized access, disclosure or loss. However, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, while we strive to protect Personal Information and any other user information we cannot ensure or warrant the security of any information you transmit to us or from the Site. You engage in such transmissions at your own risk.
If you have a security-related concern, including if you believe your Personal Information is being improperly used by us or any third party, please immediately notify us via email at [email protected]
ADDITIONAL DATA RIGHTS
You have the right to access, modify, correct or delete any personal data which we may have collected. To exercise this right please contact privacy [email protected]
Additional Data Rights Applicable to EEA Residents
All processing of Personal Information of EEA Residents is performed by us in accordance with the privacy laws applicable in those jurisdictions including the General Data Protection Regulation (2016/679) of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of Personal Information and on the free movement of such data (“GDPR”) and the GDPR as it is enacted in the UK.
Under applicable law, Enthusiast Gaming Inc. is the controller of the Personal Information of EEA Residents. If you would like to contact us, please use the contact details in this policy.
We only process your Personal Information where it is lawful to do so and in accordance with the purposes described above. When doing so, we rely on the following lawful bases:
As an EEA Resident, you may have the following rights with regards your Personal Information:
At all times, you also have the right to submit a complaint to a data protection regulator in the EEA, UK or Switzerland
Additional Data Rights Applicable to California Residents
The following section pertains to the rights of individuals or households in California (“California consumers”).
Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California consumer, a business may be required to provide detailed information regarding how that business has shared that customer’s Personal Information with third parties for direct marketing purposes. However, the foregoing does not apply to businesses like ours that do not disclose Personal Information to third parties for direct marketing purposes without prior approval or give customers a free mechanism to opt out of having their Personal Information disclosed to third parties for their direct marketing purposes.
The CCPA (California Civil Code Section 1798.100 et seq.) provides California consumers with additional rights regarding Personal Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The categories of Personal Information we collect are generally described above but differ for individual consumers depending on the Services used by such consumers.
Under certain circumstances, we will not provide such Personal Information, including where the disclosure creates a substantial, articulable and unreasonable risk to the security of that Personal Information, customers’ accounts with us, or the security of our systems or networks. We also will not disclose California consumers’ social security numbers, driver’s license numbers or other government-issued identification numbers, financial account numbers, any health insurance or medical identification numbers, or account passwords and security questions and answers.
If you are a California consumer and would like to make any requests under the CCPA, please direct them as follows: Enthusiast Gaming Inc., Attention: Privacy Officer, 90 Eglinton Ave E Unit 805, Toronto, ON M4P 2Y3; or at [email protected]
If we receive any request, we will use a two-step process for online requests where the California consumer must first, clearly submit the request and then second, separately confirm the request. We will use other appropriate measures to verify requests received by mail or telephone.
In submitting a request, a California consumer must provide sufficient information to identify the consumer, such as name, email address, home or work address, or other such information that is on record with us so that we can match such information to the Personal Information that we maintain. Do not provide social security numbers, driver’s license numbers, account numbers, credit or debit card numbers, medical information or health information with requests. If requests are unclear or submitted through means other than as outlined above, we will provide the California consumer with specific directions on how to submit the request or remedy any deficiencies. If we cannot verify the identity of the requestor, we may deny the request.