PRIVACY AND COOKIE POLICY

I. Introduction

PGL ESPORTS S.R.L. (hereinafter referred to as “PGL”) is committed to respect your right to privacy. This policy explains as clear and simple as possible what personal data we collect from you on our website, how we use such personal data, how long we keep such data and what are your rights.

According to The General Data Protection Regulation (EU) 2016/679 (hereinafter “GDPR”), by “Personal Data”, we mean any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, hereinafter collectively referred to as “Personal Data”.

PGL may process Personal Data according to this Privacy Policy. PGL may process in addition anonymous data in order to analyze and produce statistics related to the use of this website. Such anonymous data is collected through a script and by placing cookies developed by Google Analytics and does not allow your identification.

If you do not accept the terms of this Privacy Policy, please refrain from using our website or our website online functionalities.

The Data Controller (within the meaning of GDPR) is PGL ESPORTS S.R.L. (www.pglesports.com) a company established under the laws of Romania, with its registered office at 9-9A Dimitrie Pompeiu Blvd, building no 2, Iride Business Park, ground floor, district 2, Bucharest, 014284, Romania. You can contact PGL by mail at the above address or by e-mail at [email protected]

II. Personal Data collected by PGL

We collect and process the following Personal Data:

Personal information provided by you when you contact us using a contact form:

Name, surname, e-mail address and other information which you voluntarily provide to us when submitting our online contact forms.

Please be informed that supplying Personal Data is made on voluntary basis and you are hereby informed that in case of failure to supply your Personal Data or if you do not provide correct/complete data, we may not be able to initiate a communication process with you.

The purpose of collecting such Personal Data is to communicate with you. The legal basis for personal data processing is the legitimate interest of PGL for:

  • communication with the person contacting PGL,
  • initiating a legal relationship with the person contacting PGL, and/or
  • providing information to or responding to queries/questions addressed by the person contacting PGL.
  • keeping you updated by sending periodical newsletters by e-mail regarding this Policy, relevant events, tournaments and/or competitions organized by PGL, always ensuring that you have the option to update your subscription preferences and/or you can easily unsubscribe.
  • Data storing period: as long as necessary to pursue the legitimate interest of PGL or a third party, as explained above, however not more than 3 years from providing your Personal Data.

    Personal Data provided when applying for an open position / for a job with PGL:

    When you submit Personal Data through our online recruitment forms or tools, you are considered a potential candidate for an employee position open at PGL.

    The purpose of collecting Personal Data from you is the recruitment process of potential employees.

    The processing of Personal Data provided by potential Candidates for an employee position is made for entering into an agreement.

    Please be informed that supplying Personal Data is made on voluntary basis and you are hereby informed that in case of failure to supply your Personal Data or if you do not provide correct/complete data, we may not be able to initiate a communication process with you and you will not be able to participate in our recruitment process.

    The following Personal Data are necessary for the recruitment process:

    (i) Personal data to identify you: name and surname, sex, age, CNP (Romanian national identification number), date and place of birth, home address / residence, nationality, telephone number, e-mail address, civil status, identity card number / passport number, residence visas, as well as any other identification data provided in the CV and / or letter of intent

    (ii) Personal data to verify the eligibility and selection conditions for the recruitment process: education, diplomas, professional certificates / licenses or authorizations issued by competent authorities, experience and references to professional history, as well as any other relevant data provided in the CV and / or letter of intent;

    (iii) Data about your examination during the recruitment process: references, interview notes, test results, performance analysis;

    (iv) Remuneration data: salary details, bonuses, benefits, taxes and duties owed to the state budget in accordance with the applicable law;

    (v) Health data: information about your medical restrictions, information on any disability or work restrictions.

    (vi) Other particulars provided by a potential candidate may also be processed, such as contact details in the form of a mobile telephone number, a personal e-mail address or image/photo attached to / embedded by you to / into the CV.

    Data storing period: in case of impossibility / refusal to conclude a contract, PGL will store your personal data for a period of 3 years after closing the online recruitment process.

    Personal Data collected when you attend eSports events or tournaments organized by PGL

    PGL may collect Personal Data (such as your name, surname, address, e-mail address, nickname/playname, country of origin, passport details and a copy of your travel documents) from you when you apply to attend an event organized by PGL.

    Processing such Personal Data is regulated by the PGL’s Notice concerning processing of competitors personal data and/or by the PGL’s Notice concerning the processing of personal data of casters, as the case might be. if you are a competitor or a caster, please refer to the relevant information notices received by e-mail from PGL.

    The PGL policy is to process only those personal data strictly necessary for the purposes for which they are collected.

    However, PGL will also be able to process personal data from other individuals, such as your family members - parents and guardians, when processing operations are performed for the purpose of concluding and executing the contract for minor competitors.

    The scope of the processed data may include the following categories of personal data concerned, which may vary depending on your age, but not limited to:

    a) Personal data to identify you: name and surname, nickname, gender, age, personal identification number, date and place of birth, home address / residence, citizenship, phone number, e-mail address, civil status, ID card series and number / passport number, bank details and other financial details, contest number, user account and / or passwords allocated for the use of PGL’s computers, as well as, where appropriate, personal data of your parents or your guardian: name and surname, gender, citizenship, home address / residence, telephone number, e-mail address, civil status, ID card series and number / passport number;

    b) Personal data to verify the eligibility and selection conditions for the selection process for participation in events organized by PGL: known foreign languages, education, experience and references to the history of the player's career (training, achievements), profession, data biographies, habits and practices in the field of electronic sports;

    c) Temporary location data: country and place of origin indicated for the purchase of airplane tickets, the destination of the hotel accommodation;

    d) Data concerning health: medical data on physical limitations, medical conditions or physical or mental disabilities;

    e) Biometric data: voice, facial image (both static and moving); customs, motor and verbal tics, handwritten signature.

    The storage of personal data is done both in material and electronically, on the internal server, in both situations PGL has implemented security measures for their protection.

    If PGL intends to process your Personal Data for purposes other than those for which it was collected, it undertakes to provide you with further relevant information so that any processing of your data may be carried out legally

    The failure to provide the Personal Data mentioned above is likely to lead to the impossibility of concluding and executing the contract for the competitors as well as to the impossibility of fulfilling the legal obligations of PGL or the realization of the legitimate interests of PGL or yours, or even the impossibility of concluding a contract with PGL or its termination.

    Purposes of Personal Data Processing and Legal Basis

    Any operation or set of operations made by manual and / or automated means that represents your processing of data (collecting, storing, recording, structuring, adaptation or modification, extraction, consultation, use, disclosure, dissemination, etc.) of your data will be in accordance with the GDPR, national laws on GDPR implementation measures and will be performed only for the following legitimate purposes:

  • Negotiation, execution and termination of the contract for competitors: operations related to the negotiation of the contract for competitors, including verification of the fulfillment of the specific skills and requirements for the conclusion of the contract for the competitors; fulfilling PGL's obligations towards the competitor, including rewarding and awarding the benefits to the competitor in accordance with the contractual provisions; taxation aspects of payments made under the contract to competitors; monitoring and supervising the competitor's activity in the field of electronic sports, including monitoring and evaluation of professional competences, moral probity in accordance with the legal provisions specific to the field of electronic sports; filming, video recording, shooting during electronic sports competitions; dissemination, exploitation and use in any way of images (photo and video) for advertising and / or commercial purposes;
  • Compliance with any legal obligation imposed on PGL: the preparation of the PGL's documents and records; declaring tax obligations to the competent tax authorities;
  • Fulfilling the legitimate interests of PGL: analysing and minimizing the operational risks to which PGL is exposed; making business forecasts, setting budgets, ensuring a high level of security at both IT systems and physical locations; making internal reporting to PGL's governing bodies, preventing operational risk, including fraud, organizing and optimally conducting electronic sports competitions.
  • keeping you updated by sending periodical newsletters by e-mail regarding this Policy, PGL, relevant events, tournaments and/or competitions organized by PGL, always ensuring that you have the option to update your subscription preferences and/or you can easily unsubscribe.
  • Processing your personal data for the above purposes will be based on one or more of the following legal bases:

  • Processing is required for the conclusion, performance or termination of the contract by virtue of which you have the capacity of a competitor (Article 6 paragraph 1 letter b of GDPR);
  • Processing is necessary to comply with a legal obligation under PGL (Article 6 (1) (c) of GDPR;
  • Processing is necessary for the legitimate interests of PGL, unless your interests or rights prevail over PGL's interests (Article 6, paragraph 1, letter f of GDPR);
  • Processing of special categories of personal data (eg. data concerning health or biometric data) will be performed on the basis of your explicit consent (Article 9, paragraph 2, letter a of GDPR).
  • Categories of recipients of Personal Data
  • The data subject, as well as the legal or conventional representatives of the data subject
  • PGL employees, authorized to process personal data as part of their legitimate work duties, within the limits of their professional duties, for legitimate and specific purposes;
  • Third parties, for the purpose of fulfilling the obligations assumed by PGL under the contract for competitors:
  • public authorities and institutions, for example, to declare tax obligations;
  • PGL service and products providers that act as processors for the permitted purposes, on behalf of PGL, only in accordance with PGL's instructions and only after assuming confidentiality obligations with respect to the processing of your Personal Data;
  • PGL service and products providers acting as PGL joint controller or independent data controller for the processing of Personal Datafor permitted purposes, for example, hotel services providers, airline services providers;
  • banking units for the purpose of making material benefits payments.
  • PGL business partners, in order to achieve the legitimate interests pursued by the controller. In view of PGL’s role of organizer of electronic sports events in which you participate as a competitor, your personal data could be disclosed to Romanian and foreign legal persons, PGL business partners who, together with PGL, are the organizers of the events or the suppliers of products and services necessary for organizing and conducting e-sports events.
  • If PGL transfers personal data to suppliers of products and services outside the European Economic Area (EEA), the transfer will only be made if the European Commission has confirmed that there is an adequate level of data protection and if other measures have been taken personal data protection (mandatory corporate data protection rules or EU standard contractual clauses) according to public information at the date of transfer.

    This website uses personal data in connection with Gears 5®, Xbox® and Xbox® Live. The following link https://privacy.microsoft.com/en-US/privacystatement contains all information regarding processing of personal data in connection with Gears 5®, Xbox® and Xbox® Live.

    This website was developed and is being maintained by Webedia, a French company registered under RCS Nanterre 501 106 520, headquartered at 2 rue Paul Vaillant Couturier, 92300 Levallois-Perret, France. Some personal data that you provide is transferred during the normal use or for the purpose of maintenance of this website to Webedia and its contractors acting as sub-processors, for different but limited purposes related to hosting services, audience measuring cookies, messaging or newsletter platform, e-mail communication servers, error tracking services, object storage services (backup). Such processors are either EU registered companies or US companies that are EU-US Privacy Shield adherent. Here is a link to Webpedia’s privacy policy where you can obtain more information on its applicable policy - https://www.toornament.com/en_GB/privacy-policy.

    PERIOD OF STORAGE OF PERSONAL DATA

    PGL will store your Personal Data for as long as it is necessary for the purpose for which it was collected, in accordance with GDPR and applicable national law.

    Storage times are determinable by reference to storage obligations of economic operators' records and registers, as well as by reference to the applicable limitation periods and deadlines for compliance with the statutory and archiving obligations imposed by national laws, as follows:

  • in the pre-contractual stage, PGL may store your personal data for a period of 1 year from the date of PGL’s notice on the impossibility / refusal to complete/conclude the contract;
  • in case of a contract between you and PGL, your Personal Data will be retained throughout the term of the contract for the competitors and after the termination of the contract in any way for a term of 10 years from the date of conclusion of the financial year during which the contract was executed, given the nature of accounting supporting documents and PGL’s legal obligation to retain such documents for this period; after the expiry of this retention period, your Personal Data will be delivered to an authorized company for destruction.
  • III. Cookies used on this website

    A cookie is a small text file that is placed on your computer or mobile phone when you browse websites. Cookies help us:

  • to use this website login functionality (session cookies);
  • to remember your settings (such as language or cookie preferences);
  • to allow you to connect with your Social Media account in order to simplify the login process;
  • to improve the speed of the site (by remembering your last visit, so that some resources are not reloaded again); or
  • to improve the security of the site (generally used on a large scale for login/session purposes).
  • PGL does not use cookies to collect Personal Data or any other sensitive information and any identifiable data to third parties (unless this is needed for providing a service and we have your express consent).

    In order to use this website, users are requested to express their explicit consent for using cookies. Users are hereby informed that they can block or customize the cookies in the settings of their preferred browser. You are advised that by default, internet browsers allow storage of cookies on your devices, therefore by simply using this Website, cookies are used. By changing settings on your preferred Internet browser, you can block automatic storage of cookies by PGL or by third parties.

    PGL uses Google Analytics cookies. These cookies provide anonymous/ aggregated information about where you go and what you do on our website. These cookies monitor with the help of a script that your browser is loading upon visiting each page of this website, how many visitors are visiting this website, which country/county/region (and sometimes cities) are the visitors coming from, how visitors navigate through the site, how much time are the visitors spending in average on our website, how fast are the pages loading and how the visitors reached our website. All such information is displayed in an aggregated, anonymized way (statistics).

    List of necessary / functional cookies used on play.gears.gg (main page):
    Name Description of the cookie / Purpose Origin Expiry
    SFGU Session ID PGL User session
    cookie_policy Memorization of your choice of acceptance of cookies. PGL 13 months
    ARRAffinity used for load balancing to make sure the visitor page requests are routed to the same server in any browsing session PGL Session
    List of third-parties cookies used on play.gears.gg (main page):
    Name Description of the cookie / Purpose Origin Expiry
    __cfduid maximize network resources, manage traffic, and protect our Customers’ sites from malicious traffic .cloudflare.com One year
    __cf_bm part of Cloudflare’s Bot Management service and helps manage incoming traffic that matches criteria associated with bots .cloudflare.com One day
    _biz_flagsA .cloudflare.com One year
    _biz_nA1 .cloudflare.com One year
    _biz_pendingA .cloudflare.com One year
    _biz_sid .cloudflare.com One year
    _ga Allow Google Analytics statistics on the number of visits made to the Website Google 2 years
    _gid Allow Google Analytics to distinguish users.s Google 1 day
    _gat_gtag_UA_13046878_23 Allow Google Analytics to throttle request rate. Google 1 minute
    PGL’s integration of Social Media plugins

    PGL has opened social media accounts inter alia with Facebook, Instagram, LinkedIn, Twitter, Twitch and Youtube. These social media platforms are used to communicate with visitors/registered users and inform them about the services PGL offers, keeping them updated and/or informing them about the events that PGL will organize or has organized.

    If you communicate with PGL using Social Media platforms, your Personal Data will be processed by the respective Social Media platforms and PGL. We will only use your Personal Data for the purpose of contacting or communicating with you and for a period necessary in order to communicate with you.

    If you are not a registered user of the Social Media platforms mentioned above and you do not want any Personal Data processing when using this website, you can log-out of any relevant Social Media and visit this website after deleting all cookies.

    In case you wish to exercise any of your rights as conferred inter alia by the GDPR or by this Privacy Policy, you may wish to contact the Social Media platforms directly and/or PGL (using the contact information and details above).

    For any further details, please refer as well to the terms and conditions, privacy policies and cookie policies of the Social Media platforms inter alia Facebook, Instagram, LinkedIn, Twitter, Twitch and Youtube.

    V. Automated decision-making

    PGL shall not process Personal Data in an automated manner in order to take decisions or for profiling purposes.

    VI. Making Personal Data available to third parties

    Your Personal Data might be made available to third party entities authorized to process such data on the basis of legal regulations. Your personal data may also be transferred to entities affiliated with PGL, to PGL contractors (and their representatives), as well as to PGL’s business partners and service providers, in particular advisors, law offices, notarial and tax advisory offices, IT service providers, marketing service providers (e.g. event/PR agencies, photography studios, printing shops), travelling companies, insurance companies, finance and accounting services companies, whereas such entities will process your Personal Data on the basis of an agreement with the PGL and in accordance with its instructions.

    VII. Transfer of Personal Data outside the European Economic Area (EEA)

    Your Personal Data might be transferred to third parties located outside the EEA. If such transfer is needed, it shall take place in accordance with GDPR and any other binding regulations adopted by the European Commission with the observance of and in full compliance with standard clauses of protection of Personal Data.

    VIII. Your rights

    The individuals whose data are processed by PGL according to this Privacy Policy, shall have the following rights under the provisions of Art. 15 - art. 22 of GDPR:

    a) the right of access to personal data – the right to obtain confirmation that the personal data are processed by the Company and, if so, to be aware of the relevant details of such processing activities

    b) the right to rectify personal data – the right to obtain the rectification of inaccurate personal data or the completion of the processed personal data;

    c) the right to delete data – the right to obtain the deletion of personal data, in compliance with the legal provisions in force (for example, if the data are no longer necessary for the purposes for which they were collected);

    d) the right to restrict processing – the right to obtain, to the extent that the legal conditions are met, the limitation of further processing of the personal data concerning you;

    e) the right to data portability – the right to receive personal data in a structured way, commonly used in an easy-to-read format, as well as the right to transmit these data by the PGL to another data controller, to the extent that the legal conditions are met;

    f) the right to object – the right to oppose at any time, for good and legitimate reasons relating to your particular situation, that personal data which you are seeking to process are subject to the legal requirements;

    g) the right is not the subject of an automatic decision or additional profiling related to automated decisions – the right to request and obtain the withdrawal, cancellation or re-evaluation of any decision based solely on automatic processing (including the creation of profiles) for you or similarly affect you to a significant extent

    h) If your consent was necessary for the processing of certain personal data, you have the right to withdraw this consent at any time, which will not affect the lawfulness of the processing prior to the withdrawal of the consent.

    i) To lodge a complaint with the PGL’s lead supervisory authority, the Romanian Data Protection Authority (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal – ANSPDCP www.dataprotection.ro) or with your local supervisory authority.

    In order to exercise your rights, please submit your written request, dated and signed to the e-mail address [email protected] or by post, at the PGL headquarters in Bd. Dimitrie Pompeiu, no. 9-9A, building 2, ground floor, within Iride Business Park, sector 2, Bucharest, 014284, Romania.

    PGL will always handle any personal data request in a timely manner and will be notified no later than one month after receipt of your request regarding the actions taken to exercise one or more of the previously listed rights. However, the period of one month may be extended in duly justified cases of up to two months, considering the complexity and the number of applications received, circumstance in which you will be duly informed no later than month after receiving your request.

    This Privacy Policy was first published on September 12, 2019 and might be subject to updates. You will be kept informed about any updates operated in this Privacy Policy.

    Last update: November 5, 2019.