Privacy policy

CHALLENGEME.GG
PRIVACY POLICY

Challengeme Esports GmbH (“CMES,” “we,” “us,” or “our”) was founded on the principle of providing the services, software applications, and networks that allow for playing video games for fun (this includes playing for high scores, virtual currency, items, etc.) and the authorized streaming of video game content over the Internet. We know that you care about how your personal information is used and shared, and we take your privacy very seriously.

Your privacy is our top concern, thus we adhere to the following principles to protect your privacy:

  • We do not rent or sell your personal information to third parties for marketing purposes.
  • Any personal information that you provide will be secured with industry standard protocols and technology.

If the content or information that you share with CMES apps or websites contains personal information of other individuals, you must be legally permitted and authorized to share the personal information with CMES.

What Does This Privacy Policy Cover?

We provide this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal data and other information we receive from users. We discuss in this Privacy Policy what personal data we collect from you, why, how we use and share that data, how long we will hold it, and how we will protect it.

We will notify you of any changes to this Privacy Policy by posting the new version of the Privacy Policy on our Website. We reserve the right to modify this Privacy Policy at any time, so please review it frequently.

Unless otherwise defined in this Privacy Policy, capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Use.

You willingly provide us certain personal data, which we collect in order to allow you to benefit from the CMGG Platform functionalities. If you have any hesitation about providing such personal data to us or otherwise used in any manner permitted in this Privacy Policy and in our Terms of Use, you should not become a user.

The CMGG Platform and Third Party Websites

This Privacy Policy applies solely to the CMGG Platform. Our Website may contain links to third parties' websites, which are not owned or controlled by CMES. CMES has no control over, and assumes no responsibility for, the privacy policies (if any), or practices of any third parties' websites. You acknowledge that you are responsible for reviewing and understanding privacy policies (if any) of any third parties' websites you may access through this Website.

Our primary goals in collecting your personal data are to provide and improve the Website and the CMGG Platform and the related features, to manage your account and subscription and to enable users to enjoy and easily navigate the Website. Below are the types and categories of information we collect.

What Information Do You Collect About Me?

When you visit our Web page, create an account with us, post materials on one of our chat rooms or bulletin board, or contact us for support or other offerings, we collect information that identifies you. This includes information such as your email address, or payment information. We may also sometimes collect other information that does not identify you, such as country and region. In addition, when you access an offer by one of our advertisers, we collect online identifiers. We provide more detail in the list below.

  • Contact Information: If you are a customer of our products or services, we will collect general contact information that you provide to us. This includes: your email address and in some cases address and phone number. It also includes the content of your customer support communications. We use this information to communicate with you. This helps us to carry out your purchase or requested services and to notify you about updates to our Sites and Apps. This also helps us to ensure we are providing adequate support and fulfilling your requested services.
  • Payment Information: When we provide a product or fee-based service to you, we will collect payment information (for depositing and withdrawing). We use this information for billing purposes and to carry out your requested services.
  • Login and Account Information: If you are a customer or our products or services, we will collect your user id, password and Steam ID to control access to and security of our Sites and Apps.
  • Eligibility information: We will collect certain information to ensure you are legally eligible to use our products and services, including your date of birth and location (i.e. your region, country, and your state or province). The laws of many countries in which we operate require customers meet minimum age requirements. The laws of many countries also require that we exclude from our customer list individuals who are politically exposed or a person of interest.

Where your consent is required, we will obtain your permission before sending you news and promotional material about CMES. You can withdraw your consent to such activities or ask us to stop processing your personal information at any time by simply contacting our customer service team at ‘Contact Us’ or emailing us at support@challengeme.gg.

To help keep our databases current and to provide you the most relevant content and experiences, we may combine information provided by you with information from third party sources, in accordance with applicable law.

Personal data we collect when you use our apps and websites to enhance our offerings.

We collect information about how you use our Sites and Apps and how you got there. These include:

  • Online Identifiers: When you access an offer by one of our advertisers, we obtain your Internet Protocol address, browser user agent, and sometimes your device id.
  • Data Trackers: Data trackers include Cookies and Web Beacons. Through these data trackers, we collect information on
  • The webpage that led you to our Site;
  • The search terms entered into a search engine which lead you to our Site;
  • Use and navigation of websites and apps (collected through cookies and similar technologies, or by CMES servers when you are logged in to the app or website); and
  • Analysis of your content (e.g., activity logs, and direct feedback from you) which is stored on Unikrn servers.

Data trackers help our Sites and Apps work. They also help us to improve our content and to customize the content and/or layout of our page for each individual visitor. In addition, online identifiers and data trackers to prevent and reduce fraudulent practices. For more information about our use of cookies, web beacons, and similar technologies, please click on the link to our “Cookies Notice.”

Emails we send you that include web beacons tell CMES whether you have received or opened our email, or clicked a link in the email. If you do not want us to collect this information, you can opt out of receiving CMES marketing emails via your settings under ‘Account Settings’ on our website, or alternatively by contacting us at support@challengeme.gg.

Personal data we collect to support CMES’ online advertising efforts.

CMES advertises online in a variety of ways, including displaying CMES ads to you on other companies' websites and apps and on social media platforms, such as Facebook and Twitter. CMES websites use cookies and similar technologies that allow us to gather additional information to measure and improve the effectiveness of our advertising. We collect information such as:

  • Which ads are displayed;
  • Which ads are clicked on; and
  • Where the ad was displayed.

CMES apps and websites may include buttons, tools, or content that link to other companies’ services (for example, a Facebook "Like" button). We may collect information about your use of these feature, such as content “liked”. In addition, when you see or interact with these buttons, tools, or content, or view a CMES web page or app containing them, some information from your browser may automatically be sent to the other company. We will advise you via a notification before you access one of our partner websites for which we do not have control their use of customer data, requesting your acceptance of their applicable Terms of Service. Please read that company’s privacy policy for more information.

Personal data we collect through our social media functions.

CMES has its own pages on many social networking sites (for example, the Unikrn Facebook page). We will collect information which you have made publicly available on your social networking account, such as name and interests in our products and services, when you interact with our social networking pages.

How Did You Obtain The Information You Collect And How Do You Use It?

Registration

In order to become a user, you do not need to create an account on the Website. However, in order to access some features of the CMGG Platform you will have to create an account. When creating your account you benefit from additional services we provide through the CMGG Platform. To create an account you are required to provide the following information login and a password chosen by you.

We may also ask you to provide additional information after you register if you want to obtain additional services or information or to resolve complaints or concerns. You are responsible for ensuring the accuracy of any personal information you submit.

If you choose to associate an account managed by a third party with your account on the Website you authorize us to have access to personal data stored by third parties such as Facebook, Twitter, Steam and you agree that we may collect, store and use these personal data in accordance with this Privacy Policy. Scope and categories of personal data we may receive in this case depends on policies of third parties' websites and is controlled by these third parties (these personal data may include, but are not limited to, your name, gender, profile photo, location/hometown, website, email address and other information you make publicly available via third parties' websites).

Forums, Message Boards, Q&A, Groups, Blogs, Etc.

When you post any message to a forum, message board, Q&A, group, blog or any other public forum within the Website where users can post their observations and comments on designated topics, your basic information will be available for all registered users to see. This basic information consists of your username. You should not post any information about you or any other person to a forum, message board, Q&A, group, blogs or other public forums within the Website if you want to keep such information private or you are required by law to do so. Information you post to public forums within the Website is considered public information and may be used by us and third parties. As with any public forum on any website, this information may also appear in third party search engines like Google, Yahoo, MSN etc. We do not control the information indexed and cached by search engines.

Log Data

When you visit the Website, whether as a registered user or a non-registered user just browsing, our servers automatically record information about your use and your visit to the Website ("Log Data"). The Log Data may include information such as your computer Internet Protocol (IP) address, time and date of your requests, your browser type, what software you were using, the web page you were visiting immediately prior to visiting the Website, access times and dates, your location, mobile network information and other statistics. We use this information to monitor and analyze the use of the Website and for the Website's technical administration, to improve the CMGG Platform's functionalities and user-friendliness, and to better tailor it to the users' needs. We only use pseudonymous data for these purposes, unless personal information is required – e.g. for the prosecution of illegal activities on our Website. In any case, we delete or anonymize personal information after a reasonable time, which shall be no longer than four weeks.

Cookies

Like most websites, we use cookies and web log files to track the use of the Website. A cookie is a tiny data file that resides on your computer and allows CMES to recognize you as a user when you return to the Website using the same computer and web browser. You can control how websites use cookies by configuring your browser's privacy settings (please refer to your browser's help function to learn more about cookie controls). If your browser settings do not allow cookies, you may not be able to use the Website. Like the information you enter at registration, cookies and log file data are used to customize your experience on the Website.

One type of cookie, known as a "persistent" cookie, is set once you have logged in to your account. The next time you visit the CMGG Platform, the persistent cookie will allow us to recognize you as a registered user, so you will not need to log in before using the CMGG Platform.

Additionally, if you log out of your account you will need to re-enter your password the next time in order to log in to your account. Another type of cookie, called a "session" cookie, is used to identify a particular visit to the Website. Session cookies expire after a short time or when you close your web browser. That means that they will no longer collect or store information after you close your web browser.

In the course of serving advertisements or optimizing services to our users, we may allow authorized third parties to place or recognize a unique cookie on your browser. Any information provided to third parties through such cookies will not be personally identifiable. If you would like more information about this practice and to know your choices about not having this information used by third parties, please click here. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Unfortunately, if your browser settings do not allow cookies or you opt to refuse all cookies, you may not be able to use the Website. CMES does not store personal data in the cookies.

Furthermore, we use Google Analytics, a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter referred to as "Google"). Google Analytics uses "cookies", small text files placed on your computer to help websites analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Due to the activation of the IP anonymization, Google will truncate/anonymize the last octet of the IP address for Member States of the European Union as well as for other parties to the Agreement on the European Economic Area (E.E.A.). Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. Data that is anonymized cannot be used to identify anyone and therefore does not require protection under many laws, including under E.U. law. Data that is not anonymized may be subject to protections. Google has confirmed that personal data that is transferred from the E.E.A. to a country outside the E.E.A. will have adequate safeguards, confirming to E.U. law. On behalf of CMES, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to the website provider. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, CMES points out that if you do this, you may not be able to use the full functionality of this website. Furthermore you can prevent Google’s collection and use of data (cookies and IP address) including its processing by downloading and installing the browser plug-in available under the following link: The current link is http://tools.google.com/dlpage/gaoptout?hl=de

Alternatively to using the browser plugin or in the browser on mobile devices, you may click the following link to prevent the collection by Google Analytics in the future: download link. By doing so, a cookie will be placed on your device. In case you delete your cookies, you will have to click the link again.

Web Beacons

We allow other companies, called ad networks, to serve advertisements to users through our Website. Ad networks include third party ad servers, ad agencies, ad technology vendors and research companies.

To deliver these ads properly, we may include a file, called a web beacon, from these ad networks within pages served by CMES so the ad networks may provide anonymized, aggregated auditing, research and reporting for advertisers as well as to target ads to you while you visit other websites.

Because your web browser must request these advertisements and web beacons from the ad networks’ servers, these companies can view, edit or set their own cookies, just as if you had requested a web page from their website. You can control how websites use web beacons by configuring your browser's privacy settings (please refer to your browser's help function to learn more about cookie controls).

These general targets may also be used by ad networks to display targeted ads on other websites as a substitute for random, irrelevant ads. CMES does not provide personal data to any advertiser or any other third parties.

Do You Share My Personal Information?

Sharing Information with Third Parties

CMES takes the privacy of users very seriously. Thus, we do not sell, rent, or otherwise provide your personal data to third parties for marketing purposes. We will only share your personal data with third parties to carry out your instructions or to provide specific services or information. Unless you have agreed to it, these third parties do not retain, share, or store any personal data except to provide these services and they are bound by confidentiality agreements that limit their use of such information.

We may provide aggregated anonymous data about the use of the Website to third parties for such purposes as we deem, in our sole discretion, to be appropriate, including to prospective advertisers on the Website. But anonymous data cannot identify any individual.

We will also share your personal information with companies that help us to run our business by processing personal information on behalf of CMES. Such companies include providers of customer support services, payment processing services, fraud monitoring and prevention, email, social media, and other marketing platforms and service providers, and hosting services.

Disclosures to Others

CMES may also disclose your personal data and other information you provide, to another third party as part of reorganization or a sale of the assets of CMES' division or company. Any third party to which we transfer or sell our assets will have the right to continue to use the personal data and other information that you provide to us.

Aggregate Information and Non-Identifying Information

We may share aggregated information that does not include personal data and we may otherwise disclose non-identifying information and Log Data to third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your personal data.

Links to Other Websites

Our Website contains links to other websites. If you choose to visit an advertiser by clicking on a banner ad or other type of advertisement, or click on another third party’s link, you will be directed to those third parties' websites. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third parties' websites. These other websites may place their own cookies or other files on your computer, collect personal data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the personal data you submit to them. We encourage you to read the privacy policies (if any) or statements of the other websites you visit.

What Rights Do I Have To The Personal Information That You Collect?

Under the law of some countries, you have the right to:

  • Access the personal information that you provide us and that we maintain;
  • Correct, update or delete that personal information that we no longer have business reasons for retaining;
  • Restrict processing while we review any concerns you may have over the accuracy of the personal information we maintain;
  • Object to
  • Data processing based upon legitimate interests,
  • Data processing for research or statistics,
  • Direct marketing, and
  • Decisions based exclusively on automated processing, such as profiling, so long as the decision does not impact our ability to enter or perform our contract services for you or is not based on your explicit consent;
  • Withdraw your consent in instances where we must have your consent to contact you; and
  • Transfer, or port, your personal information that you provided us in a structured, commonly used, machine-readable format.

You can review the information you provided to us and make any desired changes to them at any time by logging in to your account on the CMGG Platform. Please be aware that even after your request for a change is processed, CMES may, for a time, retain residual information about you in its backup and/or archival copies of its database. We take your rights seriously and encourage you to use them if you deem this to be appropriate. You may exercise these rights by emailing us.

If you choose to delete your account, we may retain certain data contributed by you if we may reasonably believe it may be necessary to prevent future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable data, account recovery, or if required by law. In order to delete your account please visit "Delete Account" section associated with your account; or contact us as aforementioned.

If you are an E.U. resident and you have a dispute about how we are handling your personal information, you have the right to complain to a supervisory authority to enforce your rights. You can contact CMES’s lead supervisory at:

Berliner Beauftragte für Datenschutz und Informationsfreiheit

Maja Smoltczyk
An der Urania 4-10
10787 Berlin
GERMANY

Is My Personal Information Secure?

We understand that the security of your personal information is important. We have reasonable and appropriate administrative, technical, and physical security measures in place to protect against the loss, misuse or alteration of information that we have collected from you at our site.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your "personal data" stored by us (as defined in applicable laws related to security breach notification).

Where Do You Store My Personal Data?

Your personal information and files are stored on CMES servers and the servers of companies we hire to provide services to us. Your personal information may be transferred across national borders because we have servers located worldwide and the companies we hire to help us run our business are located in different countries. We discuss these data transfers in our section “Will You Transfer My Personal Information Across National Borders?”

How Long Will You Keep My Personal Data?

CMES may retain your personal data and account information as long as they are required for purposes they were collected. CMES will retain personal data in accordance with applicable legal requirements. If no longer required CMES will purge personal data from its systems. In the event of an investigation by law enforcement or a response to claims or legal process, CMES may retain personal data until such investigation or process is completed.

Will You Transfer My Personal Information Across National Borders?

Your information may be transferred to and maintained on computers and servers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. We will undertake in these cases to assure an adequate level of data protection of any third party receiving your personal information. If you are a European resident, we transfer your data based on one or more of the following legal mechanisms: the EU-U.S. Privacy Shield or Standard Contractual Clauses.

How To Contact Us

If you have any queries regarding your personal data or comments on this Privacy Policy, please email us. You may also contact us by the contact details below:

Data Protection Officer

Sven Patrick Jacobshagen
Reinberg Meyer von Beust LLP
Friedrichstr. 55a
10117 Berlin
+4989044550
dataprotection@challengeme.gg

Miscellaneous Provisions For U.S. Law

Use Of Services By Minors

The Sites and Apps are not directed to individuals under the age of thirteen (13). CMES does not knowingly collect personal information from such individuals and we request that they not provide personal information through the Sites or Apps. If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under the age of 13, please contact us at support@challengeme.gg (any such request must include “Privacy Policy” in the subject line).

Your California Privacy Rights

Subject to the terms herein regarding a change in business ownership or structure, we do not share personal information (as defined by California Civil Code Section 1798.83) collected by us for the products or services we provide you with third parties for their direct marketing purposes without giving you the opportunity to opt in or opt out as more fully described above in the “Opting Out Of Direct Marketing” section. If you are a California resident, you may request information about our compliance with California law by emailing us at support@challengeme.gg or by sending a letter to Alexanderstr. 9, 10178 Berlin, GERMANY , Attention: Legal Counsel. Any such request must include “California Privacy Rights Request” in the subject line and include your name, street address, city, state and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this designated email address or mailing address.

California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how CMES responds to “Do Not Track” browser settings. CMES does not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

This Privacy Policy was updated on: 25 May 2018