Privacy Policy

Estonian Esports Federation: MTÜ EESTI ARVUTISPORDI LIIT, registered in Estonia

Address: Harju maakond, Tallinn, Vesivärava tn 50, 10152, Estonia 

Reg. code: 80589159

Email: info@e-sports.ee

Tel.: +37258502080

 

This website is operated by: Aurora Gaming OÜ, registered in Estonia 

Address: Harju maakond, Tallinn, Vesivärava tn 50-201, 10152 Estonia

Reg.code: 14745198

VAT number: EE100530247

Email: info@aurora.pm

 

Last updated: December 12, 2020

This document may be available to you in other languages.

Introduction

We respect your privacy and pay great attention to the protection of your personal data. This Policy helps you to understand:

  • what personal data we collect;
  • why we collect it;
  • what we do with it.

The information below will elaborate on these three topics. Please read it carefully as it is very important. Our goal is to present the description and the handling of your personal data concisely, using clear and simple language to make this policy quick and easy to read and understand.

  1. Who we are

1.1. We are MTÜ EESTI ARVUTISPORDI LIIT, a non-profit association registered under the laws of Estonia, registry code 80589159, with its registered office at Harju maakond, Tallinn, Kesklinna linnaosa, Vesivärava tn 50, 10152, Estonia, with Aurora Gaming OÜ, a company registered under the laws of Estonia with its registered office at Harju maakond, Tallinn, Vesivärava tn 50-201, 10152 Estonia, as Passport.gg provider.

1.2. This Privacy Policy sets out how we collect and use your personal information when you use the services («Services») by visiting our site and registering your primary so-called “Main” account, available to you after registration on the Website, and the choices available to you in connection with our use of your personal information (the Privacy Policy).

For the purposes hereof, “Administration Partner” shall mean the individual (individual entrepreneur) or legal entity developing or operating the project, service, platform, game, tournament, competition, event and/or application, selling goods or services (Administration Partner Service), including World Esports Consortium (WeSCO), Esports.NGO and their affiliates as well as our partners and sponsors. 

This Privacy Policy should be read alongside, and in addition to, our terms of use at https://e-sports.ee/tou (Terms) and our Cookie Policy at https://e-sports.ee/cookie-policy

In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail.

As used in this Privacy Policy, except as may otherwise be provided herein, all capitalized terms which are defined in our Terms of use shall have the same meaning herein as therein, all of such terms and their definitions being incorporated herein by reference.

1.3. We may subcontract some services related to our Website to third parties.

  1. This Privacy Policy

2.1. By making available the Services we, acting reasonably and in good faith, believe that you:
(a) have all necessary rights to register on the Website and use the Services and have reached a certain age which allows, in accordance with the applicable laws, being fully liable for your own actions (fully capable) or have all necessary consents (e.g. parental consents) in full compliance with the applicable laws, including for purposes of data protection laws;
(b) provide true information about yourself to the extent necessary for use of the Services;
(c) understand that by the posting your personal information, if there is such technical possibility in the Services and where it is accessible by other users of the Services, you have manifestly made this information public, and this information may become available to other Website users and internet users, be copied and disseminated by them;
(d) are aware of and accept this Privacy Policy.

2.2. We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you or under applicable law.

  1. Information we collect about you

3.1. In order to implement the agreement between you and us, and provide you with access to the use of the Services, we will improve, develop and implement new features to our Services, and enhance the available Services functionality. To achieve these objectives, and in compliance with applicable laws, we will collect, store, aggregate, organise, extract, compare, use, and supplement your data (hereinafter “processing”). We will also receive and pass this data, and our automatically processed analyses of this data to our affiliates and partners as set out below and section 4 of this Privacy Policy.

3.2. We will use the information we collect from all of our products and Website to deliver, support, protect and improve them and develop Service and/or new products and to protect us, our partners and users, for example: 

  • to provide you information, products and technical support that you request from us;
  • to let you know about changes to our Services;
  • to provide you information about other similar products we have;
  • to perform any agreement, we have with you;
  • to comply with laws and regulations that are applicable to us;
  • to improve and check our Websites so that it will be convenient for you and your device to view content of our Websites;
  • to monitor potentially illegal activities;
  • to enable you take part into interactive features of our Websites when you choose to do so;
  • to keep our Website safe and secure;
  • to measure or understand the effectiveness of advertising we send you and others, and to deliver relevant advertising to you;
  • to make suggestions and recommendations to you and other users of our Websites about our products;
  • to test and analyze statistics and survey results.

3.3. We set out in more detail the information we collect when you use our Services, why we collect and process it and the legal bases below.

  1. Information collected: Data you provide for registering in the Services including your email and/or mobile phone number. 

Purpose: We use this information in order to manage and administer the Services provided to you.

We use this data to enable us to fulfill our obligations to you as part of the Services (e.g. in cases where you request restoration of your account). We also use this information in order to provide you with updates and information on our and selected third parties’ products and services we think you may be interested in. 

Legal basis: Legitimate interests, performance of our contract with you. 

  1. Information collected: Where necessary, a copy of your identity or another document containing your name, surname, nationality, address, photograph, number of the principal identity document of you or your representative, payment details and another additional data, with that you may provide us, including through our support service.

We may take additional verification steps where we consider reasonable in order to verify your account and your identity. 

Purpose: We use this data in order to identify you, verify your account and prevent abuse and infringements of your or other persons’ rights. For example, we use this information to verify your identity if you lose your credentials and wish to access your account with us. We use this data to identify you if you submit application for special services. 

Legal basis: Legitimate interests, performance of our contract with you. 

  1. Information collected: Additional data you provide when you register or edit your profile page including your first, middle and last name, username (nickname), nationality, citizenship, gender, date of birth, geo location, country, city, district, university, school, faculty, address, personal bio, phone, email, avatar picture, team, language preferences and social network ids. 

Purpose: We use this information in order to provide our Services to you, to manage and administer Services and as additional information to verify your account to prevent abuse and infringements of your or other persons’ rights. We also use this information in order to provide you with updates and information on our and selected third parties’ products and services we think you may be interested in. We use this information in order to tailor and improve the adverts that may be presented on the Site and in our and our partners’ others different products and services that you choose to use and measure the effectiveness of these advertisements. 

Legal basis: Legitimate interests, performance of our contract with you. 

  1. Information collected: Additional data received when you access the Services, including information regarding technical devices, technical interaction with the Service such as your IP-address, time of registration in the Service, device ids, country and language settings, device model and operating system used, your installed apps, type of browser, your Internet provider and/or phone network operator, network type, screen resolution, RAM size and your browsing behavior. 

Purpose: We use your data for internal review in order to constantly improve the content of our Services and web pages, optimizing your user experience, to understand any errors you may encounter when using the Services, to notify you of changes to the Services and to personalize the use of our Services. We use this information in order to tailor and improve the adverts that may be presented on the Site and in our others different products and services that you choose to use and measure the effectiveness of these advertisements. 

Legal basis: Legitimate interests, performance of our contract with you.

  1. Information collected: Information that is automatically received at the time of access to the Services with the use of cookies. 

Purpose: Please see our cookies policy which sets out the types of cookies we use and what we use these cookies for. We use this information in order to tailor and improve the adverts that may be presented on the Site and in our others different products and services that you choose to use and measure the effectiveness of these advertisements.

Legal basis: your consent. 

  1. Information collected: Information that is created by you while using the Services (if there is such technical possibility in the Services) this information can be available to some or all other users of our Services. 

Purpose: We use this information in order to manage and administer the Services including providing our services to you. 

Legal basis: Legitimate interests, which inter alia, include the processing of manifestly made public by you, data where it is accessible by other users of the Services, performance of our contract with you. 

  1. Information collected: Information that is obtained by the Main account from your extra accounts such as information that is received as the result of your behavioral actions when using the Services, that is received as the result of your using payment functionality of the Services (e.g. first and last four digits of your card number that are required in order to match these details with your account), etc. 

Purpose: We use this information in order to manage and administer the Services including providing our services to you. We use this information in order to tailor and improve the adverts that may be presented on the Site and in our others different products and services that you choose to use and measure the effectiveness of these advertisements.

Legal basis: Legitimate interests, which inter alia, include the processing of manifestly made public by you, data where it is accessible by other users of the Services, performance of our contract with you. 

  1. Information collected: Information that is created by you while placing requests to our Services support. 

Purpose: We use this information in order to verify your identity and to fulfil your support request. We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service. 

Legal basis: Legitimate interests, performance of our contract with you. 

  1. Information collected: Data collected via third parties, including your social network ids, application store ids, nickname, email and friends list, when you register in our Services via you social or application store accounts and/or connect your social account to our Services (e.g. Facebook, Twitter). 

Purpose: We use this information in order to manage and administer the Services provided to you. We use this information for certain social functions of our Services, such as to show you who of your friends play the same game as you. We also use this information in order to provide you with updates and information on our and selected third parties’ products and services we think you may be interested in. 

Legal basis: Legitimate interests, performance of our contract with you.

3.4. Our legitimate interests include (1) maintaining and administrating the Services; (2) providing the Services to you; (3) improving the content of the Services and web pages; (4) processing of the data that was manifestly made public by you where it is accessible by other users of the Services; (5) ensuring your account is adequately protected; and (6) compliance with any contractual, legal or regulatory obligations under any applicable law. 

3.5. As part of maintaining and administrating the Services we use the information to analyze user activity and ensure that rules and terms of use for the Services are not violated.

3.6. Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defense or exercise of legal claims.
We will not delete personal information if it is relevant to an investigation or a dispute.
It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.

3.7. You may withdraw your consent to sending you marketing and/or advertising information by clicking to unsubscribe in email sent to you by us or our selected third party partners or via email sent at info@aurora.pm

3.8. Please note, if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and your sexual orientation) you should take care not to post this information or share this data on the Website.
Once you have provided this data it will be accessible by other Website users and it becomes difficult for us to remove this data.

3.9. Please note, if you withdraw your consent to processing or you do not provide the data that we require in order to maintain and administer the Services, you may not be able to access the Services or register with the web pages.

  1. Data sharing

4.1. We take technical and organizational measures to ensure that your data is safe. Please note that by posting your personal information (if there is such technical possibility in the Services and where it is accessible by other users of the Services) you have manifestly made this information public, and this may become available to other Service users and internet users and be copied and/ or disseminated by such users.

4.2. We may share your data with our affiliates and Administration Partners and their subsidiaries to provide, support, protect, improve and develop our Services. Sometimes we may also need to share your data with a third party in order to provide our Services to you or to administer the Services, for example if you choose to share your data across other social media platforms. 

4.3. We may share your personal data with our affiliates and trusted third parties who process personal data on our behalf. 

4.4. We may also share your data with our third party contractors and application developers provided these third parties assume confidentiality obligations regarding your personal data collected by your use of the applications they offer. The developers use the information provided to them in order to provide you with additional services. Data will only be shared with these developers with your consent. You can authorize developers to access your information via our products.

4.5. Our affiliates and our selected third party partners with our permission, using their own ad servers, can show and/or send advertisements to you subject to your consent. If you agree to receive marketing and advertising materials from us and/or our partners and sponsors, including World Esports Consortium (WeSCO), Esports.NGO and their affiliates, we may share you email address with our selected third party partners for the sole purpose of provision of such best marketing and advertising materials to you.

4.6. In some circumstances, it may become necessary for us to share your information with a government authority.

We will share information with these state authorities, partners, companies, persons or others when we feel that it is reasonably necessary to:

  • Comply with applicable laws, legal actions or lawful request of state authorities;
  • Protect our rights, property or safety, our users or others under the applicable laws;
  • Fulfil our obligations under our agreement with you;
  • Check, prevent and investigate fraud, security or technical issues.
  1. Privacy Settings

5.1. The Services may contain links to sites operated by third parties. We are not responsible for your data privacy when you access these links or engage with third party services and you should ensure you review the relevant third party’s privacy statement, which will govern your data privacy rights.

5.2. We bear no liability for the actions of third parties, which, as the result of your use of the internet or the Services, obtain access to your information in accordance with the confidentiality level selected by you.

5.3. We bear no liability for the consequences of use of the information, which, due to the Services nature, is available to any internet user. We ask you to take a responsible approach to the scope of their information posted on the Website.

  1. International Transfers

6.1. We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA).

6.2. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.

  1. Retention Periods

7.1. We will retain your personal information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.

7.2. You may delete your personal data by removing the data from your account; alternatively, you can delete your account.

7.3. We may remove your account, or the information you post as provided by the Terms.

  1. Your Rights

8.1. You have the following rights, in certain circumstances, in relation to your personal information:
(a) Right to access your personal information.
(b) Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.
(c) Right to restrict the use of your personal information.
(d) Right to request that your personal information is erased.
(e) Right to object to processing of your personal information.
(f) Right to data portability (in certain specific circumstances).
(g) Right not to be subject to an automated decision.
(h) Right to lodge a complaint with a supervisory authority.

(i) For processing based upon your consent, the right withdraw that consent at any time.

(j) You may have other rights under your legislation of your country of residence, including right to define the instructions relative to the outcome of your personal data after your death.

8.2. If you would like to exercise these rights, please contact Support Service at info@aurora.pm or send your request to us, in writing to Harju maakond, Tallinn, Vesivärava tn 50-201, 10152 Estonia ​. We will aim to respond to you within 30 days from receipt of request. We will need to verify your identity before we are able to disclose any personal data to you.

  1. Security Measures

9.1. We take reasonable technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination. We continuously analyze and check our procedures of collection, storage, and use of information including trainings of our staff.

Please note that although we work hard to protect security of our products and Websites, the confidentiality of any communication or material sent to or from our products and Websites cannot be guaranteed. We ask you to take every precaution to protect your personal data when you are on the Internet.

9.2. Access to the Services is authorized using your login (e-mail address or mobile phone number) and password. You are responsible for keeping this information confidential. You should not share your credentials with third parties and we recommend you take measures to ensure this information is kept confidential. 

9.3. If you forget your login details, you can request us to send you an SMS or email, which will contain a restoration code.

9.4. To reduce the probability of third parties gaining unauthorized access, if you login to your account from an unusual place or after several failed attempts to provide valid login details, we may block entry to your account. You will then need to contact Service support and provide certain additional information to verify your credentials and gain access to your account. 

  1. Changes to this Policy

10.1. From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation archive. When we determine that such changes are significant for your rights and interests, we will notify you by email or by a pop-up banner on our Website that requests your individual consent. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such.

  1. Contact Us

11.1. If you have any questions, please send your inquiries to Service support at info@aurora.pm or in writing to Harju maakond, Tallinn, Vesivärava tn 50-201, 10152 Estonia. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within 30 days from receipt of request. 

11.2. All correspondence received by us from you (written or electronic inquiries) at info@aurora.pm or in writing to Harju maakond, Tallinn, Vesivärava tn 50-201, 10152 Estonia is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.