Introduction

• We know that your personal data is precious and that you take care how Your personal data is used and shared. Whether you are a User or just going through Our Site (for the purpose of the data privacy policy, you shall be referred as “You” and/or “Your”), We want You to be informed about Our obligations under the law and more importantly, about Our commitment to protect Your personal data. This data privacy policy (hereinafter referred to as the “Privacy Policy”), explains how We manage and safeguard personal information in the course of operating Our business. We are dedicated to adhering to the principles contained in this document, that relate to the collection, use, retention and disclosure of personal data, as defined herein.
• Accordingly, this Privacy Policy describes the types of personal data collected about You and describes other types of information which We might collect to provide You with the Services. This Privacy Policy also explains how personal data may be used Us, when it may be disclosed, how you can take steps to control the use and disclosure of your personal information, and how that information is protected.
• This Privacy Policy applies to all personal data of all users of the Site, and apart from Our Users, this shall include any personal data submitted to Us by unregistered visitors on our Site. This Privacy Policy does not cover any information collected through any other website operated by third parties, such as linked websites operated by sponsors, advertisers or game developers.
• This Privacy Policy and any subsequent amendments shall remain in full force and effect with respect to all your personal data which we retain for a limited period of time even after your use or participation in the Site and the Services rendered therein, and in the event when Your Use Account is suspended or deactivated for any reason as We may deem fit in accordance with the Terms, in order to ensure that you may easily restart gameplay at a later time.
• Some of the links on our Site may lead You to other websites which are governed by their own privacy notices. These may be different to this Privacy Policy. You are required to make sure that you are satisfied with their privacy notices when using those other websites.
• Unless indicated otherwise, all definitions contained in this Privacy Policy, including any capitalized terms that are not specifically defined in this Privacy Policy, shall have the same meaning contained in Section 2 of the Game Champions General Terms and Conditions (hereinafter referred to as the “Terms”) and which are available on the website? www.ihlsozluk.com
• If you do not agree with this Privacy Policy, please do not keep accessing the Site, any of its sections and Services, and/or participate in any of Our Services offered through the Site.
• All titles contained in these Terms are for reference purposes only and shall not be construed to contain any legal enforceability.

2. Accountability

2.1???? We are accountable for all personal data that We receive from You and is in Our control. This includes information under the Our direct control as well as any other personal data that we may process for the provision of the Services. We use different measures to keep all your information safe and secure which may include encryption and other forms of security.

• We may transfer this personal data collected from You to third party service providers, in each case solely for the purposes of performing support functions to the Services offered by Us, such as business analytics, payment processing, data storage and destruction, customer support, printing and mailing.
• We allow Users to create, send, receive and store content on their User Accounts, including but not limited to images, videos, and other graphics produced during the User’s participation on Our Site. All such information as well as any of Your data, whether personal or otherwise, shall not be used for any marketing purposes, unless Your explicit consent has been obtained through our Site. In the event where You give Us Your consent to use such information for marketing purposes, You hereby agree to grant Us a non-exclusive, worldwide, royalty-free, irrevocable, perpetual, assignable license on such information to use, access, reproduce, store, create derivative work from, distribute, transmit, publish and disseminate such information for marketing purposes. The dissemination of such information shall be made in accordance with the Terms and this Data Privacy Policy.
• We shall use contractual or other measures to require third parties that process information or provide services on Our behalf to maintain a level of privacy protection comparable to Our own practices.
• You have a number of rights assigned to You in relation to certain types of personal data that We hold about You. These rights include:

2.5.1?? Your right to access any personal data We hold about You and to obtain any information about how we process it;

2.5.2?? In some circumstances, You have the right to withdraw your consent to our processing of your personal data, which you can do at any time. We may continue to process your personal data if we have another legitimate reason for doing so, and this in accordance with applicable legislation in force from time to time. In some circumstances, You have the right to receive certain information you have provided to Us in an electronic format and/or request that We transmit it to a third party. In certain circumstances to the extent permitted or required by applicable law, access to personal data may be denied. If We deny an individual's request for access to their personal data, We will advise You in writing about the reason for the refusal and You may then challenge Our decision. Where personal data is used on an on-going basis, We undertake to correct any information that is shown to be inaccurate, incomplete or not up-to-date. Otherwise, We do not routinely update personal data;

2.5.3 The right to request that We rectify any of Your information if it is inaccurate or incomplete;

2.5.4 In some circumstances, You have the right to request that we erase any information which We hold when providing You with the Services. We may continue to retain your information if we’re entitled or required to retain it. We may undertake to delete or destroy all such information to the extent that retention of such information is not required or permitted by applicable law, such as for the investigation of claims or the defense of an action, and some Personal Information may remain in back-up storage for this purpose; and

2.5.5 The right to object to, and to request that we restrict Our processing of your information in some circumstances. In some cases, We may have the right to refuse such request.

2.6 You can exercise Your rights by contacting Us using the contact details contained in this Section 2.? You also have a right to complain to the Malta Information and Data Protection Commissioner’s Office by visiting https:// idpc.org.mt, or to the data protection regulator in the country where You live or work.

2.7 You are responsible for making sure that any information you give us is accurate and up to date, and You must tell Us if anything changes as soon as possible. If we have any reason to believe there’s a fraud or money laundering risk, we may refuse to provide the Services. We may also stop providing existing products and services to you. We cannot and will not be responsible for any problems or liability that may arise if You do not provide us with accurate, truthful or complete information or personal data or if You fail to update such information or personal data.

2.8 By visiting our Site and/or accessing Our Services, You accept that your visit and any dispute over privacy is subject to this Privacy Policy and our Terms, including limitations on damages, arbitration of disputes, and application of the law the European Union. If You have any concern about Our data privacy policies and practices, You can contact Our Data Protection Officer on the following e-mail address -? ?[email protected].

3. Collection of Personal Data?

3.1 We collect two types of information (collectively referred to as “Personal Data”), in order to provide You with Our Services when visit the Site. Personal information is all that information which can be used to identify You and Your identity, (hereinafter referred to as “Personal Information”). The second type of data we collect does not identify You personally and is hereinafter referred to as “Non-Personal Information”).?

3.2 We collect Your Personal Information as follows:

3.2.1 Through Your Initial Registration?and collection of information from You as permitted by the Terms, in connection with completing the registration required for you to create the User Account, and this is used to verify Your identity and Your credentials;

3.2.2 Through the deposit of funds into the Your User Account, which will allow You to participate in Matches, Tournaments, Leagues, Challenges and/or Competitions. The Personal Information required in this respect shall include information such as your first and last name, credit card type, number, and expiration date. Also, We shall require Your billing information including but not limited to Your street address, city, postal or zip code, province or state and country;

3.2.3 Through the withdrawal of funds from Your bank account, where we need Your Personal Information, such as Your contact details, credit card details and billing addresses to verify You and Your identity;

3.2.4 When You Edit your User Account where we require the Personal Information for the purpose of updating Your contact information, Your Site information credentials, Your password, and Your communication preferences. In such instances, we shall collect Personal Information including but not limited to Your first name, last name, street address, city, postal or zip code, province or state, country and phone number; your avatar and any other Personal Information which We may require to update, such as information related with the “About You” query where we shall collect Your Personal Information contained in that description;

3.2.5 When You Play on Our Site, we collect Personal Information about Your game challenges, game preferences, User Profile information and any other of Your platform names for platforms supported on the Site for us to track your game results; and

3.2.6 The Site also provides you with certain ways to voluntarily give us your Personal Information including the following instances:

• From social network sites, where You decide to create an account by logging into a social network sites via the Site, personal information which You have provided the social network Sites (for example, the name, email address and other Personal Information which You opted to make publicly available via the social network sites, in each case depending on the privacy settings of the Individual on the social network Sites), for the purpose of completing the opening of the account;
• From You, through Your interaction with the Site, such as information about which games were played, player rating information and player game statistics;
• From You, through Your completion of contest forms or other participation in promotional offers, for the purpose of such contests and promotions, including for the purpose of awarding prizes;
• From You, through Your completion of surveys, for the purpose of gathering Your opinions and comments in regard to Our Services;
• From You, through using links contained on the Site to collect e-mail messages which contains such information, for the purpose identified at the point of collection on the Site;
• From You, to the extent that you post content with such Personal Information to chat windows, user fora or similar fora on the Site, for the purpose of each such forum;
• From You, to the extent that You provide Personal Information when you contact Our customer support representatives via live chat or e-mail;
• From You, through you voluntarily disclosing information about Yourself when you use the "Refer A Friend" feature, for the purpose of inviting others to create a User Account; and
• About other individuals who are identified as your “friends", in the form of the names and e-mail addresses of your friends when you use the "Refer A Friend" feature on the Site, for the purpose of inviting others to create a User Account.

3.2.7 In order to provide a fair playing environment for all Users and to protect the integrity of the Site, we also collect Personal Information which We use to investigate complaints of cheating or behavior that we believe may be contrary to the Terms. This may include screenshots of players' computer desktops or footage of in-game play.

3.2.8 In addition to collecting Personal Information directly from visitors to the Site, we may also collect Personal Information from third parties such as marketing partners to which permission has been granted to share that information with us.?

3.2.9 Our Site is intended for a general audience and We do not knowingly:

• Allow people under eighteen (18) years of age to create User Accounts on the Site; and
• Collect Personal Information from people under eighteen (18) years of age through our Site.

3.2.10 In addition, in the event that a visitor to our Site identifies himself or herself as a person under the age of eighteen (18), We will not collect, store or use any Personal Information of such individual.

3.2.11 In the event that We receive Personal Information that we discover was provided by a person under the age of eighteen (18), We will promptly delete all such Personal Information not required for purpose of continuing to block such person's use of the Site, and will comply with applicable laws.

3.3 We collect different types of Non-Personal Information about You through Your use of Our Services. This information is collected through various media, including but not limited to through Our webservers, automatic recordings of certain technical information related to your visit to the Site and others. This information is anonymous and does not identify you personally. We collect the following Non-Personal Information:

3.3.1 The Internet domain for your Internet Service Provider;

3.3.2 The Internet Protocol address of the computer accessing the Site;

3.3.3 The address of the last webpage that You visited prior to clicking through to the Site;

3.3.4 The browser used and the type of computer operating system that Your computer is using;

3.3.5 Information about Your computer hardware;

3.3.6 The date and time that You visited the Site; and

3.3.7 A record of which pages you viewed while you were visiting the Site.?

3.4 We also collect Non-Personal Information including demographic information which does not identify any individual logging onto Our Site.?

3.5 Other Non-Personal Information may be collected by Us when You make use of certain social networking sites. You can register to join Our pages on social media sites where You will be required to log into Your account via Our Site. Nevertheless, if You decide to create an account by logging into a social network sites via the Site, We shall extract the Personal Information You have provided to the social network site such as Your real name, email address and other information You make publicly available via the social network Sites, from the User Account You have with such social network Sites and use that information to create your account. The extent and quality of Personal Data collected by Us shall depend on the privacy settings that you have provided Your social media network when setting up Your account.

3.6 For Facebook, if You are not currently registered as a Member and You click on "Sign in Using Facebook", You will first be asked to enter your Facebook credentials and then be given the option to register and join Us. By using Facebook Connect, you are allowing Us to access Your Facebook account information for the purpose of completing Your registration as member and You are agreeing to the Facebook Terms of Use regarding your use of the Service via Facebook.

4. Cookies

4.1???? Cookies are small text files, they cannot run on your computer, search your computer for other information, or transmit any information to anyone. A cookie containing a unique identification number that is transferred (through your browser) from a website to the hard drive of your computer. The cookie identifies your browser but will not let a website know any Personal Information about you, such as your name or address. These files are then used by such Sites as a kind of electronic identification tag when users revisit that Site. As with many major websites, Our Site use cookies. Cookies are used by the Site so that we can recognize you when you return to the Site and personalize your settings and preferences. Most browsers are initially set up to accept cookies.

4.2???? If You wish, You can change Your browser settings either to notify You when You have received a cookie, or to refuse to accept cookies.

5. Limits to Collecting Personal Information

5.1 We collect only the Personal Information that is required for the purposes described in this Section, hereinafter referred to as the “Purposes”.

5.2 We collect, use and disclose your Personal Information for such internal purposes to which You consent at the time of collection or in any case prior to such use, and as otherwise permitted or required by applicable law, including the following cases:

• To prevent fraud and protect the integrity of the Site;
• To collect subscription and entry fees from you and to process payments;
• For promotional or related purposes without additional compensation, including with respect to tournaments and the awarding of prizes;
• To operate our Site; to open and maintain Your customer accounts with Us;
• To deposit or withdraw funds into and/or from your User Account;
• To edit Your profile; and for the purpose of game Challenges, in each case as more particularly described above;
• To provide our Services as requested by You;
• To contact You regarding updates to the Site, your account status, any new services which We might introduce from time to time and upcoming events;
• To deliver prizes to You;
• To ensure that you comply with the Terms; and
• To use Personal Information to contact you regarding changes to the Terms and any other policies or agreements relevant to the Site, including this Privacy Policy.

5.2.1 In the eventuality where You use Our "Refer A Friend" feature, We will use the name and e-mail address that You provide to invite your friend to create a User Account.

5.2.2 When you create Your User Account and when we collect Your Personal Information, You can customize these preferences. If you wish to change Your account preferences to modify the ways that We contact You, please contact [email protected]?

5.3 In addition to sharing information between Our affiliated, subsidiary, and/or related entities to carry out the Purposes, and in order to better serve You, we may share and/or transfer Personal Information to third-party service providers who are legally or contractually obligated only to use that information to help us provide our Services and not for any other purpose.

5.4 From time to time the entities referred to in the above mentioned Section may hold, use or disclose Your Personal Information outside the Republic of Malta and such Personal Information may be accessed by regulatory authorities pursuant to the laws of such other jurisdictions. We shall do Our utmost to ensure that such third-party service providers will process Your Personal Information according with Our instructions based upon Your consent. We shall not, however, be held responsible for their handling or dissemination practices with respect to Personal Information, should such parties go against Our instructions.

5.5? We may also share Your Personal Information with Co-branded partners, which are third parties with whom We may jointly offer a service or feature, including but not limited to Tournament. You can tell when you are accessing a service offered by a co-branded partner because the co-branded partner's name will be featured prominently. You may be asked to provide information about yourself to register for a Service offered by a co-branded partner. In doing so, You may be providing Your Personal Information to both us and the co-branded partner, or, with Your consent, we may share Your Personal Information with the co-branded partner. Please note that the co-branded partner’s privacy policy may apply to its use of your Personal Information. We shall do Our utmost to ensure that such co-branded partners will process Your Personal Information according with Our instructions based upon Your consent. We shall however, not be held responsible for their handling or dissemination practices with respect to Personal Information, that go against Our instructions.

5.6 In the case where You shall give Us Your consent to do so, We may also disclose Your Personal Information that You have provided Us with, to third party marketing partners who provide products, information or services you have expressly requested or which we believe you may be interested in purchasing or obtaining, in order that they may provide you with information regarding such products, information or services.

5.7 In doing so, we will make reasonable efforts to ensure that these third parties only use the Personal Information for the marketing of Our Services and that they provide a method of opting out from receiving future communications from such parties.

5.8 By giving Us Your consent to share Your Personal Information in accordance with this Section, You hereby agree and accept such marketing partners shall process Your Personal Information and that We shall do Our utmost to ensure that such marketing partners will process Your Personal Information according with Our instructions based upon Your consent We shall not be held responsible for their handling or dissemination practices with respect to Personal Information, that go against Our instructions. If you subsequently wish to change your account preferences to not receive information from such third party marketing partners, please contact [email protected] ?or use the "unsubscribe" link included in email messages sent by such parties.

6. User Generated Information

6.1 We retain the right to use any information generated through the use of Our Services to maintain a live feed of activities on Our Site, such as live scoreboards, which shall be available to other Users and the general public accessing the Site. In view of this, You hereby authorize Us to use Your user name and any results obtained in any Competition that You have participated in, for the purpose of publishing such information on dedicated scoreboards.

7. Legal Compliance

7.1 There may be instances when We may disclose Personal Information without providing notice or choice, as required or permitted by applicable laws, which may include:

7.1.1 To Our advisers, including but not limited to Our legal advisers and other concerned employees, technical experts and/or other technical individuals appointed by Us in defending claims lodged against Us;

7.1.2 Where required pursuant to a subpoena, other form of legal process such as investigations and/or requests made by any local, provincial, state, or federal governmental department or agency;

7.1.3 In an emergency, to protect the safety and physical security of Users of the Services or members of the public; or

7.1.4 As otherwise permitted by law.

8. Business Transfers

In a case where We decide to sell all or part of its business or makes a sale or transfer of Our assets or otherwise involved in a merger or transfer of all or a material part of Our business, We may opt to transfer your Personal Information to the party or parties involved in the transaction as part of that transaction, if such transfer of Personal Information will ensure the continuity of Services.

9. Management of Personal Information

9.1 We have different policies and procedures in place which dictate how long We should retain information that We collect in order to provide Our Services. Personal Information that is no longer required to fulfill the Purposes is either destroyed, erased or rendered anonymous to prevent unauthorized parties from gaining access to that Personal Information.

9.2 We retain Personal Information received from third parties in accordance with our legal and contractual obligations. The file containing your Personal Information will be made available to Our authorized employees, contractors or agents on a “need-to-know” basis, who are required to access that Personal Information in connection with the Purposes, and will be held primarily in an electronic database.

9.3 Personal Information included in computer databases is typically stored in a secure data center with an extra copy of the data stored at an alternate location of equal security to ensure that we will be able to retrieve the data even in the event of a disaster. These computer databases may be located in Europe or elsewhere in the world. From time to time, we may transfer Personal Information stored in these databases (as otherwise permitted under this Privacy Policy) to third-party service providers located in other locations. For example, certain third-party service providers such as Our data storage companies, database technicians, computer security specialists, or corporate affiliates may have remote access to Personal Information in Our custody for the purposes described herein, but we use contractual and other safeguards to ensure that Personal Information transferred to such parties is provided with a comparable level of protection as We habitually s provide, regardless of the format in which that Personal Information exists.

9.4 We have implemented a variety of commercially reasonable security safeguards to protect Personal Information under Our control against loss, theft, misuse and interception by third parties. These safeguards include organizational, technical and physical measures designed to protect information from unauthorized access, disclosure, copying, use or modification. Among the steps taken are:

9.4.1 Premises security;

9.4.2 Restricted file access to Personal Information;

9.4.3 Technology safeguards, including the operation of security software and firewalls, in order to prevent hacking or other unauthorized computer access; and?

9.4.4 Internal password and security policies.

9.5 Notwithstanding our commitment and employment of controls, no data transmission or storage can be guaranteed to be 100% secure. You agree to take reasonable steps to guard against identity theft, including 'phishing' attacks. You are responsible for maintaining the confidentiality of your password and account, and You are fully responsible for all activities that occur under Your password or account. In the event of unauthorized use of Your password or account or any other breach of security, You must notify us immediately and promptly change Your password.

10. Governing Law, Jurisdiction and Change of The Data Privay Policy

10.1 The Site is governed by and operated in accordance with the laws of the Republic of Malta, including but not limited to the Data Protection Act (Cap.586 of the laws of Malta), and any national and European Union legislative developments that shall be applicable from time to time. Any disputes shall be resolved in the Courts of the Republic of Malta as stipulated under Section 27 of the Terms.

10.2 We make no representation that this Site is operated in accordance with the laws or regulations of, or governed by, other nations. By utilizing the Services and participating in Site activities, You certify that you meet the age and other eligibility requirements for the Site and the Services set forth in the Terms. If You do not meet the age and other eligibility requirements, please discontinue using the Site and the Services immediately as your continued use of the Site and the Services indicates that you are agreeing to the collection, use, disclosure, management and storage of your Personal Information as described in this Privacy Policy.

10.3 All of Our policies and procedures are reviewed and updated periodically to reflect changes in our practices and Services, including this Privacy Policy. If We modify this Privacy Policy, We will update the "Effective Date" and such changes will be effective upon posting to the Site. We shall however inform You with the changes carried out to the Privacy Policy, by virtue of a notice uploaded on our website to this effect.