PRIVACY AND DATA POLICY PRIVACY

ISSUED BY DOUBLE ELEVEN LTD.

Last Updated: July 2018

1. INTRODUCTION AND GENERAL TERMS

These terms apply to the use of games and other products developed by Double Eleven Ltd. (“Double11” / “we“ / “us”). Our office is at Boho One, Bridge Street West, Middlesbrough, Cleveland, TS2 1AE.

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all games, related online services (including the DoubleID service) and other software and products made available by us (together the “Game(s)“), as well as any other online features relating to the Games, including our website (double11.com) (the “Website”). Together the Game(s) and the Website are referred to herein as the “Online Services”.

If you have any questions or comments about this Privacy Policy, please contact us at [[email protected]]

We are committed to protecting and respecting your privacy. The Privacy Policy explains the basis on which personal information we collect from you will be processed by us. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

Please read this Privacy Policy carefully as it contains important information about the following:

What information we may collect about you;

How we will use information we collect about you;

Whether we will disclose your details to anyone else; and

Your choices and rights regarding the personal information you have provided to us.

This Privacy Policy should be read in conjunction with, our terms of use at https://www.double11.com/terms... and also in conjunction with terms applicable to a specific Game (see terms for each Game).

The Online Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate, we may notify you of changes by email or through the Game and/or on the Website.

2. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information, which may include your personal data.

Information provided by you when using the Game(“Basic Information”)

We will collect the following information from you when you play our Games:

This may include:
Steam ID
Xbox Gamertag
PSN Online ID
Steam, Xbox or PSN Profile/Display Name
your IP address
the country in which you are playing our Games

Contact information provided by you when using the Website, DoubleID (“Contact Information”)

We may ask you for, or you may submit, certain contact information to us whenever you use DoubleID or contact us through the Website (via the “Contact Us” form

This may include:

your name
your username
your email address

Information on your device which you make available to us (“Content Information”)

Our Online Service may also collect information which you make available to us and which is stored on your device, or in your Facebook or other social media profiles.

This may include:

contact information
images
video or other digital content such as records of your gameplay
characters and other in-game content you have created
How you use our Online Services (“Game Analytics”)

We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics.

Personal data we may collect includes the following:

your Steam ID
Xbox ID
PSN Online ID
Steam, Xbox or PSN Profile/Display Name
your IP address
the country in which you are playing our Games
game play results (e.g. wins/losses, kills/deaths)
game play progress
game play time
user interface usage (e.g. buttons clicked, screens viewed)
hardware information (e.g. CPU, RAM, video card configuration)
any purchases and spend you have made in the Game, and
identification of crashes and bugs.

How you use our Website (“Website Analytics”)

Our Website uses cookies to collect analytical information, such as your internet protocol (IP) address, your browser and/or other internet log information, to help analyse how visitors use the Website.

Google Analytics

We use Google Analytics on our Website for anonymous reporting of Website usage. If you would like to opt-out of Google Analytics monitoring your behaviour on our Website please use this link (https://tools.google.com/dlpag...)

3. WHY WE COLLECT INFORMATION ABOUT YOU

To provide the Game and the Online Service to you

As applicable, we will use information about you (including Basic Information and Analytics) for delivering our Online Services to you under the terms of use agreed between us, as well as contacting you about matters requiring your attention.

The processing of information in this way is necessary for us to record your progress and current status within a Game, and to ensure the Games deliver the features promised and function properly, so that you have the best experience when playing any one of our Games.

To help us improve the Online Services and fix any problems

We may process information about you (including Basic Information and Analytics) so that we can analyse and improve the Game and Online Services.

This processing is also necessary for us to pursue our legitimate interests of (i) ensuring that our Online Services function properly so that you and other users have the best experience when playing any of our Game(s) and using the other Online Services; (ii) improving the quality of our Online Services, and providing a better experience to our users; and (iii) identifying and correcting any bugs in the Games and Online Services.

Marketing

If you ask to be added to our mailing list, we will keep you updated with information on news and releases by email unless you would like to be removed from that list (in which case please let us know by clicking unsubscribe at the bottom of any marketing email that you receive).

In line with the legitimate interest we have in promoting our business, we will use the email address you gave us via our Website to provide you with this information.

There may also be circumstances where we will ask you for your explicit consent in respect of our use of your data in which case you will be notified at the time.

To respond to your enquiries and requests for support

We may process Basic Information and Contact Information so that we are able to properly respond to your enquiries and support requests and so you are able to use the Online Services, in accordance with the terms of use agreed between us.

Prevent Fraud and Illegal Activity

We process personal data for the legitimate interests of ensuring that use of the Online Services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, and to enforce our legal rights and comply with our legal obligations.

Where we reasonably believe that you are or may be in breach of any of the applicable laws, we may use your personal information to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.

We work with Steam (the Valve Corporation), Microsoft (Xbox) and Sony (PlayStation) to assist us with fraud prevention and the detection of any illegal activity (e.g. to verify in-Game purchases made through Steam, Xbox or PlayStation). We also implement anti-cheat measures to detect cheating. Please see the section on “detecting cheating” for more information on this.

4. DATA SHARING

Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

Merger or acquisition: If we are involved in a merger, acquisition or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches or to protect the rights, property or safety of Double11, our customers or others.

Digital Content Stores: The Game is made available to download via Steam (operated by the Valve Corporation), Xbox Live (operated by Microsoft) and PSN (operated by Sony) and we may disclose your personal information to Steam, Microsoft or Sony (as appropriate) for the purposes of making the Game available and facilitating any in-Game payments made through Steam, Xbox Live or PSN.

5. DETECTING CHEATING

PLEASE NOTE: We do not use automated decision-making methods which do not involve human involvement to process your information only in the ways that are described in this Privacy Policy.

We do however process your personal information in order to identify users who are cheating in the Games. Our methods are designed to detect cheating by looking out for irregularities in game play behaviour.

If users are determined to be or suspected of cheating, the following actions may be taken:

they will be temporarily or indefinitely suspended from playing the Game, although they will still have access to their Game account; and

anything acquired relating to the Game, be it through credits or real-money purchase, will be lost.

Please also see our terms of use for each Game as applicable.

In this scenario, the user will be informed of the outcome and will have the right to obtain human intervention to express his or her point of view and to contest the decision to block access to the Game. If this applies to you, please contact us at [email protected].

6. CONSUMER CONTROL AND OPT-OUT OPTIONS

Where you have linked your Steam, Xbox Live and/or PSN accounts to any of your social media accounts, you can unlink these at any time by changing your settings in Steam, Xbox Live or PSN (as applicable). You can also remove access in your account settings on Facebook, Twitter and/or YouTube.

7. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay and within one month at the latest.

To make a request, please let our Data Protection Officer know via [email protected].

Ask for a copy of data we are processing about you and have inaccuracies corrected

You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.

We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).

Object to us processing data about you

You can ask us to restrict, stop processing or delete your personal data if:

you consented to our processing the personal data and have withdrawn that consent;

we no longer need to process that personal data for the reason it was collected;

we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Double11 or a third party, you don’t agree with that processing and there is no overriding legitimate interest for us to continue processing it;

the personal data was unlawfully processed;

you need the personal data to be deleted in order to comply with legal obligations;

the personal data is processed in relation to the offer of a service to a child.

You can delete your accounts by following the instructions in your account settings.

Obtain a machine-readable copy of your personal data, which you can use with another service provider

If (i) we are processing data in order to perform our obligations to you or because you consented and (ii) that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.

If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

Make a complaint to a Supervisory Authority

If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.

If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.

8. DATA RETENTION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements

If you decide to delete your Game account, we will delete your account information, unless we consider it necessary to retain, within 28 days. If your account is dormant for more than 10 years, we will delete your account information, unless we consider it necessary to retain. Please note that where you have purchased in-game items or perks you may no longer have access to these if you ask us to delete your personal information (this will be the case even where you have paid for these items or perks).

9. CHILDREN

We do not use our Online Services to knowingly solicit information from, or market to, children under the age of 13. Our terms of use prohibit users aged under 13 years from accessing our Online Services. In the event that we learn that we have collected personal information from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age, please contact us at [email protected].

10. SECURITY

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases are password protected and limited to essential employees only (such as Double11 management or employees whose main role requires system access).

Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

11. INTERNATIONAL DATA TRANSFERS

Information we collected about you will be stored within the European Union (EU) on a secured server.

Your personal information may be transferred outside of the EU by Steam (i.e. Valve Corporation), Microsoft (Xbox Live), Sony (PlayStation Network) or Nintendo (Nintendo Switch).

Where we transfer your information outside of the EU, we have agreements in place with those parties which include standard data protection clauses adopted by a data protection regulator and approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to us at [email protected].

CONTACT INFORMATION

All questions, comments or enquiries should be directed to Double11 at [email protected]. We will endeavour to respond to any query or questions within two business days.