This Policy was last updated as of April 24, 2023 and are published herein with immediate effect.
This Privacy Policy (“Privacy Policy”) describes how Vindex LLC and our subsidiaries and affiliated companies (collectively, “Vindex”, “we,” or “us”) collect, use, and disclose information about you. This Privacy Policy applies to information we collect when you access or use our websites, mobile applications, gaming consoles, and other online products and services that link to this Privacy Policy (collectively, the “Services”) or when you register for and attend our events, participate in our surveys, sweepstakes, or contests, or otherwise interact with us. We may supply different notices of our information practices with respect to certain Vindex products, services, subsidiaries, or affiliates, in which case this Privacy Policy will not apply.
We collect information you provide directly to us. For example, we collect information when you create an account, register for or participate in games, tournaments, and events through our Services, respond to a survey, post user-generated content on our Services, make a purchase, request customer service, or otherwise interact or communicate with us.
The types of information we collect include your first and last name, email address, phone number, age, date of birth, postal code, username or other account credentials, profile photo, avatar, and other information you choose to provide. Additionally, if you make a purchase through our Services, we work with third-party payment processors to collect and process your payment information.
We automatically collect certain information about you when you access and use the Services. For instance, we collect information regarding the games you play, the tournaments you participate in, and the advertisements you click on when using our Services. We also collect transaction information, such as the types of products or services you purchase, the purchase amount, and the date and location of the transaction. We may also record audio and video footage of you if you visit or participate in one of our live tournaments.
When you access the Services, we also collect the following:
We also collect information from third party sources, including:
We may derive information or draw inferences about you based on the information we collect. For example, we infer location based on IP addresses. We also generate statistics and analytics about game play and infer interests or characteristics based on this activity.
We process the information we collect about you to enable your access to and use of our Services. We also process the information we collect to:
We disclose information about you in the following circumstances:
We also share aggregated or de-identified information that cannot reasonably be used to identify you. For instance, we provide aggregated reports about game play metrics to our business partners. Vindex processes, maintains, and uses this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.
We engage others to provide analytics services, serve advertisements on our behalf, and perform related services across the web and in mobile apps. These entities may use cookies, web beacons, SDKs, device identifiers, and other technologies to collect information about your use of the Services and other websites and applications, including your IP address and other identifiers, web browser and mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information is used to deliver advertising targeted to your interests on other companies’ sites or mobile apps and to analyze and track data, determine the popularity of certain content, and better understand your online activity. Some of the activities described in this section may constitute “targeted advertising,” “sharing,” or “selling” under some laws. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance, visit www.aboutads.info/choices, or, if you reside in the European Union, visit www.youronlinechoices.eu. Your device may also include a feature that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes.
Vindex is headquartered in the United States and we have operations and service providers in the United States and other countries. As such, we may process and store information about you in jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We provide adequate protection for the transfer of personal data in accordance with applicable law, such as by obtaining your consent, relying on the European Commission’s adequacy decisions, or executing Standard Contractual Clauses. Where relevant, you may request a copy of these Standard Contractual Clauses by contacting us at legal@vindex.gg.
Depending on where you reside, you may have the right to (1) request to know more about and access your personal information, including in a portable format, (2) request deletion of your personal information, and (3) request correction of inaccurate personal information. To request access, deletion, or correction of your personal information, please email us at legal@vindex.gg or call us at (833) 432-8233. Once we receive the request, we will validate the information that you provide and contact you via the contact details you provided in the request. Please follow the instructions in that communication to verify your contact details and/or provide any additional information that may be needed to process your request. If we deny your request, you may have the right to appeal our decision by contacting us at legal@vindex.gg. If you have concerns about the result of an appeal, you may contact the attorney general or data protection authority where you reside.
You may also update and correct certain account information at any time by logging into your Vindex account(s) and editing your profile or account information.
As described in the Targeted Advertising and Analytics section above, we process personal information to serve you advertisements on third-party properties. Some of these activities may be considered “sales” or “sharing” of your personal information or “targeted advertising” under the law that applies to you. You may opt out of these activities by following the opt-out instructions in the Targeted Advertising and Analytics section above.
In addition, we disclose your information to our business partners and corporate affiliates for their own marketing and business purposes as described in Disclosures of Information above. Such disclosures may constitute “sales” of your personal information in certain jurisdictions and you may have the right to opt out of such activities by emailing us at legal@vindex.gg.
If you are submitting an access, correction, deletion, or opt-out request as an authorized agent, we may ask for proof of your authorization to make the request, such as a valid power of attorney or proof that you have signed permission from the individual who is the subject of the request. If you are an authorized agent seeking to make a request, please email us at legal@vindex.gg. Please do not provide any sensitive personal information in connection with this request, such as a driver's license or other government-issued ID. In some cases, we may be required to contact the individual who is the subject of the request to verify their own identity or confirm you have permission to submit this request.
If you would like to stop receiving promotional emails or text messages from us, please unsubscribe by following the instructions in those communications or logging in to your account to manage your communication preferences. If you opt out, we may still send you non-promotional emails, such as emails about your account or our ongoing business relations.
We use cookies and similar tracking technologies to analyze visits to our websites and interactions with our communications to help us improve our website, services, and marketing campaigns. You can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of some of the Services.
The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) and the Shine the Light law (Cal. Civ. Code § 1798.83) afford consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.
We collect, and in the preceding 12 months we have collected, the following categories of personal information: identifiers (such as your name, email address, or IP address), commercial information (such as records of products or services purchased), internet or other electronic network activity information (such as browsing history and information about your activities on our Services), geolocation data (such as your approximate location), audio and visual information (such as phone recordings when you call customer service), inferences drawn from the foregoing, and other categories of personal information that relate to or are reasonably capable of being associated with you. For more information about the precise data points we collect and the sources of such collection, please see Information We Collect above. We collect personal information for the business and commercial purposes described in the Use of Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:
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We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you.
Our retention periods for personal information are based on business needs and legal requirements. We retain personal information for as long as is necessary for the processing purpose(s) for which we originally collected it and for other business purposes explained in this Privacy Policy. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired. In addition, we retain your email address and information about your marketing preferences to ensure that we can honor those preferences.
We “share” and “sell” personal information with third parties in connection with advertising and marketing activities, including to expand the reach and effectiveness of our own marketing campaigns and for third parties’ own marketing purposes, and to corporate affiliates for their own business purposes. We share and sell the following categories of personal information with the following categories of third parties:
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We do not knowingly sell or share personal information about consumers under the age of 16.
Please see the Your Privacy Rights and Choices section above for information about your privacy rights, how to exercise them, and how we will verify requesters. We will not discriminate against you if you exercise your rights under the CCPA.
California’s “Shine the Light" law permits California consumers to request certain details about how their personal information is disclosed to third parties for the third parties’ direct marketing purposes. Under the law, a business must respond to these requests or provide California consumers with the ability to opt into or opt out of this type of disclosure. If you want to opt out of having information about you disclosed to third parties for their direct marketing purposes, please email us at legal@vindex.gg.
If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you have certain rights and protections under applicable laws regarding the processing of your personal data, and this section applies to you.
The names of our data controllers are:
The contact information of our data controllers is:
Attn: Legal Department
10 East 53rd Street, Floor 4
New York, NY 10022
When we process your personal data, we will do so in reliance on the following lawful bases:
Subject to certain limitations, you have the right to request access to a copy of the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please email us at legal@vindex.gg.
If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:
Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which we originally collected it and for other business purposes explained in this Privacy Policy. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired. In addition, we retain your email address and information about your marketing preferences to ensure that we can honor those preferences.
From time to time, we may modify this Privacy Policy. When we change this Privacy Policy, we will notify you by revising the date at the top of this policy. If we make material changes, we will provide you with additional notice (such as by posting a notice within the Services or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.
If you have any questions about our privacy practices or this Privacy Policy, please feel free to contact us at: legal@vindex.gg.
