PRIVACY POLICY

Last updated: October 20, 2022

This Privacy Policy (this Policy) describes how ArenumIO OÜ (Arenum, we) process your (User, you) personal data, and sets out your rights in relation to our processing of your personal data.

Document version: 1.0

Where this Policy applies
1. This Policy applies to the collection and processing of personal data in connection with the performance by Arenum of its obligations, namely:
  - under the Terms of Use of the Arenum Platform (Terms of Use) to provide you with access to the entire functionality of the streaming and esports platform Arenum, including the module for conducting esports tournaments, as well as the entire functionality of the mobile streaming application Arenum (collectively referred to as the «Platform»). The server side of the Platform, as well as the module for conducting esports tournaments is deployed on the site https://arenum.io and their subdomains;
  - to provide access to additional software that is operated by Arenum or any of its affiliates;
  - to respond to your requests submitted to our support function, other services and online chats (Requests);
  - to execute the respective legal obligations by Arenum;
  - to process your personal data subject to your prior consent.
2. By granting you access to Platform and additional software (hereinafter collectively referred to as «Software»), Arenum, acting reasonably and in good faith, believes that (a) you hold all necessary rights to use the Software; (b) you ensure security of your password and authentication data; © you have provided valid information about yourself; (d) you are aware that by publishing your personal data to a domain where it is accessible to other users of the Software, you have explicitly made this data publicly available and you are aware that it may become available to third parties and be copied and/or distributed by such third parties; (e) you have read and accepted the terms of this Policy.
3. If you do not agree with the terms of this Policy, please do not use the Software.
4. This Policy shall not apply to software, mobile applications or services of third-party developers, providers, advertisers or sponsors and social media, services that might be available through or integrated with the Software, including links thereto (Third-Party Services). For example, when effecting a payment, you may be redirected to the payment system’s website and in such cases, the processing of data is beyond the control of Arenum. Such Third-Party Services act as independent data controllers guided by their own policies, we therefore recommend that you make yourself aware of them. We shall not bear any responsibility for privacy policy of such Third Party Services and your shall use these services at your own risk.
5. We aim to protect and respect your privacy. If we determine the purpose of processing the personal data provided by you via the Software, we shall be considered the data controller. This Policy complies with the EC Regulation 2016/679 of the European Parliament and of the Council of the 27th April of 2016 (the General Data Protection Regulation or GDPR). It further complies with all other applicable laws and aims to ensure due protection and care relating to the processing of your personal data pursuant to GDPR.
Information collected and processed by Arenum
1. Arenum may collect and process any personal data that helps to identify you, as well as any other information (including anonymized) that is not directly related to personal data such as device specifications, connection details, error reports and interface interaction methods (Other Data).
2. How Arenum obtains and processes the data as follows:
  1. The data to be provided at registration:
    In order to be granted access to the closed sections of the Software, the information as below shall be required:
    - Country;
    - Currency.
    1. When you register or log into the Software, the information as below shall be required:
      - Unique user identifier which identifies you via the social network you selected to log in;
      - Authenticated user identifier;
      - Type of the used device;
      - IP address;
      - Geo-location details, including region, country, state and city;
      - Type of the browser used;
      - Identifiers associated with your device.
    2. To setup dual authentication, the information as below shall be required:
      - Phone number.
  2. Additional information provided in your personal account optionally.
    If you wish, the below information can be added to your profile after registration:
    - Nickname;
    - Avatar;
    - Background;
    - Gaming preferences;
    - Subscriptions to content of other users;
    - Nicknames used in games.
  3. The data which we receive when you participate in a tournament, challenge or competition:
    - Statistics of matches;
    - Results of matches;
    - Information on the game chosen by the user;
    - Gaming nicknames;
    - Skill level;
    - Gaming statistics;
    - Event logs;
    - Chat logs;
    - Anti-cheat logs.
  4. The data indicating your access path:
    - Address of the web-page which you used to access our Software.
  5. The Data we collect for analytics of user behaviour:
    We may collect technical information on your use of the Software through tracking and analytic technologies.
    - Number of visits to the Software;
    - Pages you access;
    - Traffic data;
    - Your IP and MAC addresses;
    - Your Internet service provider;
    - Your console ID;
    - Operating system and version of your device;
    - Brand and model of your device;
    - Number of games played, gaming progress and results;
    - Time and duration of communication session;
    - Country of your device;
    - Identified breakdowns and defects.
  6. The data that you provide to us when contacting support:
    Any contact information provided by you or requested by us.
    - Username in social networks;
    - ID in social networks;
    - Avatar;
    - Mobile number if you use Whatsapp or Telegram.
  7. The data you provide to us at subscription to our newsletters:
    - Your email address;
    - Your name.
  8. The Data required for calculations.
    By buying virtual currency or virtual items or withdrawing prizes, you hand over the following data to payment systems:
    - Your first and last name;
    - Your email address;
    - Tax number;
    - State;
    Should you have any concerns regarding the use of certain billing information, please refer to the Privacy Policy of the chosen payment system.
  9. The data posted by the user in the Software chats (User Content):
    - Any data, personal data or Additional data, including user content or information on user content, such as file location or file posting date etc.
  10. The data supporting the operation of the Software’s security system (Anti-cheat):
    Anti-cheat prevents any type of cheating — an activity granting a user an unfair or dishonest advantage over other players in games, competitions or tournaments offered by Arenum; also prevents attempts to exploit any mistake or defect of the Software; detects any actions violating the Arenum agreements, as well as actions contradicting sportsmanship or fair game.
    - Photographs;
    - Screenshots of the user’s mobile phone;
    - Emiu of the user’s device;
    - Data on the installed game you play;
    - Data on the presence or absence of jail break or cheat apk.
3. Cookies.
  Cookies are small-sized text files stored in the user browser that save user interface settings. We use cookies and other tools such as web beacons (electronic images that are used to track the number of visits to a certain page without collecting any personal data that could enable us to identify your personality) as well as tracking pixels. These data help us to operate the Software, personalize and optimize your browsing experience on Software pages, direct you via the links, improve functionality of the Software, provide you support and conduct monitoring and analytics.
  1. We may use all of, or several types of the below cookies on our Software:
    - Necessary cookies. These are cookies that are required for certain parts of our Software to function properly. They allow you to navigate through our Software, help us to recognize you on the Software and thereby enable the requested service to be provided, e.g., when you participate in a tournament.
    - Functional cookies. These help us to customize the content of our Software to your preferences. They remember your preferences, language and country from which you visited our Software. The information collected by these cookies can be anonymous and they cannot track your activity on other websites. Such cookies help Arenum to provide you with information regarding whether you have given your express consent to the use of cookies pursuant to GDPR.
    - Performance cookies. These files collect information on how you use our Software, thus helping us to improve such functions as navigation and help us in resolving technical issues or errors. For example, we use performance cookies to understand how you access our Software, whether you surf and use our Software and identify areas that would benefit from improvement.
    - Targeting cookies. These files collect information about your browsing habits to enable us to show you more relevant content. They are also used to limit certain content, as well as to measure the effectiveness of marketing campaigns. Such cookies are usually deployed by Third-Party Services.
  2. Arenum employs technologies of some Third-Party Services to enhance interaction with users including for the Platform’s modules deployed on the website: Facebook Analytics services (Privacy Policy: https://www.facebook.com/about/privacy), as well as for Software Sections available in Arenum mobile application: the services AppMetrica (Privacy Policy: https://yandex.ru/legal/confidential/), Google Analytics (Privacy Policy: https://policies.google.com/privacy?hl=ru). Yandex.Metrica , Privacy Policy: https://yandex.ru/legal/confidential/?lang=en, Google Analytics, Privacy Policy: https://policies.google.com/privacy?hl=en, Tableau Analytics (Privacy Policy: https://www.tableau.com/privacy), Firebase (Privacy Policy: https://policies.google.com/privacy), Branch Metrics (Privacy Policy: https://branch.io/policies/#privacy), Sentry (Privacy Policy: https://sentry.io/privacy/), VKontakte (Privacy Policy: https://vk.com/privacy), AdRoll (Privacy Policy: https://www.nextroll.com/privacy). This enables the Software to track how many users visit the Software’s respective pages, analyze user behavior on the Software and provide access to certain functions of the Software. Such Third-Party Services shall be liable for cookies they install on your device. All Third-Party Services receive data in an encrypted format. Data available to Third-Party Services does not allow identifying you.
  3. Opting out of cookies.
    1. You can manage your cookies using browser settings. You can set up your browser to prevent cookies from being stored or to send a notification every time it is attempted to set up cookies. You may disable cookies altogether by ticking the respective boxes in the browser. You should however be aware that if you clear the cookies, all of your preference settings will be lost (such as your browser settings for interacting with the website), including your cookie opt-out preference. Blocking cookies may also affect your interactions with the interface and the User Profile, and you may lose the ability to access certain parts of the Software.
    2. The links below provide information on how to manage and block cookies in your browser:
    3. You can find more information on how to refuse cookies using this link http://www.youronlinechoices.eu. If you want to learn more about cookie files or how to manage, disable or delete cookies, please refer to the detailed guidelines at https://www.aboutcookies.org. Furthermore, certain third-party advertisement networks, including Google, enable users to opt out of cookies or manage cookies settings. To learn more about this option with Google, visit https://adssettings.google.com/u/0/authenticated?hl=en. Google Analytics allows users to opt out from its service, for details please see the link https://tools.google.com/dlpage/gaoptout?hl=en. Yandex.Metrica also allows users to opt out from its service, please visit https://yandex.com/support/metrica/general/opt-out.html.
    4. We would recommend that you consider the possibility of having cookies placed on your device, as once you disable cookies from our Software, you will not be able to use certain features of the Software, in particular those needed to personalize your experience.
  4. By using the Software you provide Arenum with your consent to uploading cookies onto your device (generating cookies using the Software) as described above. Also, by using the Software you consent to your user information being handled in accordance with this Policy. If you are located in the EEA, you will also be requested to provide your express and explicit consent to the collection, processing and transmission of your personal data using cookies and similar technologies.
4. Arenum strongly recommends that you do not enter your personal data on the publicly accessible sections of the Software, in online chatrooms, comments, video and audio content posted by you and other public sections of the Software, and that you disable pop-up notifications on your mobile device, while creating content by means of video screen capture from your mobile device. Arenum does not moderate on a mandatory basis any data entered and shall bear no liability for its public disclosure.
5. In the event that you refuse to provide certain personal data to Arenum, you can nonetheless access the Software, however, you will not be able to buy virtual currency and virtual items, participate in tournaments or other competitions, contact Arenum by using certain methods, sign up / authorize on the Software, enable or use certain features of the Software (such as commenting) or receive certain information about Arenum’s products.
6. Subject to your separate consent or where expressly permitted by applicable laws regulating electronic newsletters, Arenum may send you promotional emails about products and services offered by Arenum. In this event we may also use the information collected from you to customize our promotional emails, as well as to track whether you open the emails we send you and which links you are clicking on.
  You may at any time cancel or withdraw your consent to receiving promotional emails by clicking the «Unsubscribe» link that is included in each promotional email.
7. Arenum may allow advertisers to show their advertisements directly to you within the Software. While providing such advertisements directly to you, advertisers may place their own cookies on your computer and use their own web beacons and other technologies enabling them to track the effectiveness of advertisements, as well as to collect and track such information as demographical data, likely interests, aggregated information and actions that help them to personalize advertisements delivered to you. Arenum shall not provide any information that could enable us to identify you without your consent. However, if you react to advertisements targeted at a particular audience (for instance, males aged between 20 and 25 who took part in certain campaigns), the advertiser may conclude that you belong to its target audience. This Policy does not cover any actions of such advertisers. Before responding to an advertisement, you should get familiarized with the respective privacy policy of such advertisers.
8. When providing us with third-party personal data, you shall warrant that you have obtained the respective party’s consent to providing their personal data to Arenum (for example, by sending invitations to join the Software using the contacts stored on your mobile device).
How Arenum uses your personal data
1. Arenum uses personal data in strict compliance with the applicable law and for the purposes for which it is collected.
2. Personal data may be used by Arenum for the following purposes:
  - to discharge the mutual obligations arising between Arenum and yourself (User) under agreements for the use of the Software agreed by the parties to ensure you gain full access to the entire functionality of Software, among other — to process your requests to support, provide you with services as well as enhance the Software and your user experience;
  - to comply with all relevant laws such as tax law, etc;
  - to protect the legitimate interests of Arenum and/or third parties, with the exception of where these interests are overridden by your prevailing legitimate interests and rights (when investigating copyright infringement, fraud or other bad faith conduct);
  - to discharge our obligations based on your separate consent.
3. When processing personal data for the purposes specified in clause 3.2 of this Policy, Arenum relies on the existence of a reasonable, legitimate interest.
Data storage period
1. We will only store your data for as long as is necessary in relation to the purposes for which it was collected and processed or (provided that the applicable law stipulates a longer storage period) — during the period as required by law. Upon expiry of this period your personal data shall be deleted, blocked or anonymized, as specified by the applicable law.
  Including without limitation:
  - If you close your Account all of your personal data will be marked for deletion, unless a longer retention period is necessary due to legal or other prevailing lawful requirements;
  - In certain cases, where it is necessary to ensure the consistency results of tournament or other competitions, personal data cannot be deleted in its entirety. Thus, data related to matches you played will not be deleted, insofar as this information affects partner data and other users’ scores. However, your participation in matches will be anonymized on a permanent basis;
  - Please note that Arenum is obliged to retain certain transaction data for up to ten (10) years as set out in the applicable commercial and tax regulations;
  - In the event that you withdraw your consent to the processing of your personal data we shall delete your personal data without undue delay to the extent that the collection and processing of personal data are based on the consent withdrawn;
  - In the event that you exercise your right to object to the processing of your personal data, we shall consider your objection and without undue delay delete your personal data processed for the purpose objected to, unless there are other legal grounds for processing and retaining of this data or unless it shall be retained under the applicable law.
2. Regardless of User’s Request to delete their data, Arenum may retain the data provided that it is deemed necessary for legitimate business interests, discharging obligations and resolving disputes.
3. Once the purposes of processing are achieved or in the event there is no longer a necessity for achieving these purposes, the data shall be destructed or anonymized.
4. User content and information that you post in chats are shall be saved for indefinite period of time. Should you wish that we delete your account or any of your posted user content, please contact us using any of the methods set out in the «Contact Information» section.
Disclosure
1. Arenum shall keep confidential and not disclose any user information to third parties without your consent, except for the cases stipulated in this Policy or by the applicable law and to the extent necessary for disclosure.
2. Personal data may be disclosed in the circumstances described below:
  - When we are instructed to do so by User. In particular, User’s instruction shall mean, without limitation, when you decide to to sign up / authorize on the Software via social media or express a wish to link your Account with a third-party software account. In the event that the linking of accounts requires your personal data to be transferred from Arenum to a third party, you shall be given prior notice and an opportunity to provide your consent for the linking of your accounts and transferring your personal data. The use of your personal data by a third party shall be governed by the privacy policy of this respective third party, which you are recommended to read carefully before linking the accounts. Furthermore, personal data may be disclosed when you (User) post your personal data at your own risk and peril on publicly accessible pages of the Software, such as User Profile, online chatrooms, comments, video and audio content. If you find out that your personal data is displayed on publicly available sections and you would like to have it removed, please notify Arenum of your wish using one of the methods set out in the «Contact Information» section. Besides, we use third-party providers for credit card processing, emailing and hosting on the website. In the event that you decide to use this service, we shall provide the third party with your personal data to the extent necessary to render you this service. Such third parties may not use your personal data for any other purposes. As concerns the processing of credit cards, we do not collect, store or process any information related to credit cards. If you are not willing to have your personal data disclosed to any third party, you may refuse from consenting to disclosing your personal data by way of not using this particular service;
  - To other users and partners of Arenum (access to your Profile’s public data, including your nickname and avatar, as well as your progress in games, participation in tournaments or other competitions, rating and content). In addition to your public data displayed in your Profile, as well as posted by you on publicly accessible modules of the Software, Arenum partners (tournament organizers) will have access to data directly related to your participation in tournaments they support (such as your right to participate in a tournament);
  - To providers of additional services. For example, payment systems, services that provide support to users, monitor their activity, as well as network services providers who deliver digital content requested by you and game servers in connection with the Software. Such providers shall use personal data in strict compliance with and for the purposes specified in this Policy;
  - To comply with the applicable law. For example, data may be disclosed upon the request of a competent authority;
  - To affiliated parties of Arenum, in order to meet the obligations to User and to the extent required for this purpose;
  - To prevent illegal activities, protect the rights and to ensure the security of Arenum and other parties and to defend against claims and lawsuits;
  - When data is transferred as a part of Arenum’s reorganization, as well as when entering into agreements for the transferring of rights within contracts. In this case Arenum may disclose data to a party acquiring the rights under such contracts, as well as to a party formed as a result of the reorganization;
  - Generalized, aggregated and non-personalized data. Arenum may disclose non-personalized statistical data, such as the most frequently used features of the Software;
  - In other cases subject to User’s consent.
3. Data that we collect will be stored in the European Economic Area (the EEA). The data of citizens of the countries where legislation allows storage and processing of such data in these countries only shall be stored in accordance with the legislation of such countries. Thus, the data of citizens of the Russian Federation is subject to processing and storage in a database located in the Russian Federation.
4. Arenum may transfer data without User’s instruction to partners (contractors, subcontractors, service providers, etc.) listed in this Policy. To this end, such partners shall ensure that the security level is no less adequate than as is set out in this Policy. All data is provided to partners in an encrypted format, the exception being when your nickname is required for your identification and the linking of your accounts, in which case you will be requested to provide your informed consent to such identification and account linking.
5. Our databases are powered by Chat2desk (Privacy Policy: https://chat2desk.com/policy) and Google Optimize (Privacy Policy: https://policies.google.com/privacy?hl=en). We recommend that you review these Third Party privacy policies and/or terms and conditions of such Third Parties if you are concerned about the transfer of your data outside the EEA.
6. Such partners may receive data in the scope strictly limited to that needed for performing their functions. When we transfer your data to partners outside the EEA, we shall conclude agreements with such partners which include standard data protection clauses adopted by the data protection authority and approved by the European Commission to ensure appropriate security measures to protect your personal data. Should you wish to know more about these precautions, please contact us using any of the methods set out in the «Contact Information» section.
Your rights and available controls
1. Data protection laws applied in the European Economic Area and other territories give their citizens certain extended rights in respect of their personal data, while other jurisdictions might grant fewer rights. Our tools, however, are designed to ensure the maximum rights for our users worldwide.
2. Notably, User is entitled to:
  - Right of access.
    You have a right to access your personal data stored with us, i.e. to make a free Request: 1) as to whether any of your personal data is stored with us, 2) to send a full list of your personal data stored with us to your email. You may exercise your right to access your personal data by sending a Request to Arenum using one of the methods set out in the «Contact Information» section. In the event that such a Request affects the rights and freedoms of other parties or appears to be manifestly unreasonable or excessive, we shall reserve the right to charge you a reasonable fee (on account of administrative expenses associated with the provision of such information, communications or requested actions) or refuse to act on the Request.
  - Right to rectification.
    In processing your personal data, we shall take appropriate measures to maintain the accuracy and relevance of your personal data for the purposes for which it is collected. If your personal data is inaccurate or incomplete, you can either change it by yourself or by contacting Arenum using one of the methods set out in the «Contact Information» section.
  - Right to erasure.
    You shall have the right to demand of us the erasure of your personal data provided that it is no longer required in relation to the purpose for which it was collected (see clause 3.3 above) or that there are legal grounds for erasure. Where a portion of personal data needs to be erased, you can do this in your Profile or by submitting a Request to our support function.
    You may also request the deletion of your Account, in which case we shall delete your Account without undue delay. Such a request can be sent through your Profilet, when you open the top menu, you must select the «settings» section, then select the «Delete account» tab in the expanded menu, or send the Request directly to the support service using the link in the footer.
    As a result of deleting your Account, you will lose access to the Software, including your Account, followings and game related information linked to your Account, as well as access to other services for which your Account has been used.
  - Right to object.
    Where personal data is only processed based on legitimate interests pursuant to Article 6(1)(f) GDPR / paragraph 3, clause 3.3. of this Policy, you may use your right to object. In the event that you express your objection, we will not process your personal data, unless there are compelling and prevailing legal grounds therefore as described in Article 21 GDPR, in particular, when the data is needed for establishing, exercising or defending legal claims.
  - Right to restriction of processing.
    You have the right to demand from us the restriction of processing provided that one of the conditions stipulated in Article 18 GDPR applies.
  - Right to personal data portability.
    You shall have the right to receive personal data in a structured, commonly used and machine-readable format and have the right to transmit this data to third parties in the cases stipulated by Article 20 GDPR. In such event Arenum will provide you with your personal data by email.
  - Right to have personal data managed after death.
    In the case that you are subject to the French law on data privacy, you are entitled to set out the rules on preserving, erasing or transmitting personal data after your death as per Article 40-1 Act 78-17 as of the 6th of January 1978 ‘On Data Processing, Data Files and Individual Liberties’.
  - Right to lodge a complaint with a supervisory authority.
Security
1. You should be aware that absolute security of data transmission through the internet cannot be guaranteed. In order to safeguard your privacy, we use standard physical, electronic and organizational security measures to protect your personal data from loss or theft, as well as from unauthorized access or disclosure. We treat data as an asset that needs to be protected against loss and unauthorized access. We use a variety of security methods to protect such personal data from unauthorized access both internally and externally of Arenum, namely:
  - There is a person designated to organize the processing of personal data, whom you can contact using one of the methods set out in the «Contact Information» section.
  - There are approved local regulations on personal data processing. They establish procedures for the prevention and detection of violations, as well as for remediation of the consequences of such violations.
  - Legal, organizational and technical measures are in place to ensure the security of personal data processing, including, where possible, encryption.
  - Periodic checks are conducted to assess the conditions of personal data processing.
  - Arenum employees who are directly involved in the processing of personal data are familiarized with the provisions of the applicable law on personal data, including personal data p
2. Arenum cannot guarantee that data is securely protected from intrusion whilst transmitted over the internet or when stored. To this end, Arenum uses data pseudonymization and encryption, wherever practicable. If you are concerned that your privacy might have been compromised, please contact us using one of the methods set out in the «Contact Information» section.
3. Arenum cannot guarantee the security of personal data where this is beyond the control of Arenum. This includes, but is not limited to, your Account access data, while you shall be responsible for maintaining the confidentiality of this data. You shall not disclose this data to third parties, and Arenum recommends that you take appropriate measures to ensure the confidentiality of this data.
Age restrictions
1. Arenum will deliberately not process personal data of persons under the age of 13. Users between the ages of 13 and 16 should discuss their use of the Software with a parent or guardian and transfer personal information to us only with the approval of their legal representatives. Some Software must not be used by anyone under the age of 18, in which case users under the age of 18 should refrain from using such Software.
2. If you are a parent or guardian who discovered that Arenum could have received personal data from your child — person under the age from which he can provide independent consent to processing, or if the registration of such a person requires the consent of his legal representatives, and the consent of legal no representatives have been provided, please inform Arenum using one of the methods described in the Contact Information section, we will use reasonable efforts to delete the information. If possible, please include in your message the username, email address and password that your child submitted.
Updates to this Policy
1. Arenum may change this Policy at any time to incorporate changes in legislation and business processes. The revision date shall be indicated in the upper left-hand corner of this Policy. All updates and amendments shall take effect forthwith upon notice, which we may give you by any means, including but not limited to notifications in your personal account, push notifications as well as other notification methods.
2. Arenum recommends that you read this Policy as often as is practicable to be aware of changes that may affect you. In the case that you disagree with the changes made to this Policy, you shall delete your Account and stop using the Software.
3. Your continued use of the Software after any change introduced to this Policy shall constitute your acceptance of such changes.
Contact information
1. You can contact our Data Protection Officer via email: ap@arenum.io or by post to: Harju maakond, Tallinn, Kesklinna linnaosa, Tartu mnt 67/1-13b, 10115, Estonia. This will enable us to process your Request efficiently. Please refer to this Privacy Policy in the text of your Request. We will try to respond within thirty (30) days upon receipt of your Request.
2. The Data Protection Officer shall review your Request, provide clarifications and take measures to protect the data. If you report a problem or an issue, Arenum shall take all necessary measures to remove the alleged violations, identify the liable parties and resolve disputes extrajudicially.
3. Any correspondence received from you (Requests in paper or electronic form) shall be classified as restricted access information and may not be disclosed without your written consent. Your personal data and other information may not be used without your consent for any purposes other than responding to your Request, except as expressly permitted by law.