Privacy & Cookies Policy
effective 25 April 2019
Link to the previous edition of Privacy & Cookies Policy
Table of contents
We are Starladder Limited, Unit F, 11 Floor, CNT Tower, 338 Hennessy Road, Wan Chai, Hong Kong ("Starladder", "we", "our" and "us").
Starladder provides the online platform for amateur, semi-pro and professional eSports tournaments.
Our registered users (“members”) participate in tournaments, create teams, engage with other members, post and view relevant content. Content and data on some of our Services are viewable to non-members (“visitors”).
This Policy applies to the following Internet sites (“Sites”):
We also have other domain names which link to the Internet sites listed above, in which case this Policy will apply to these Internet sites. Furthermore, we may add Internet sites which may not be listed, but which provide a link to this Policy and respect the terms within it.
We collect and use as less of personal data that is needed. We may collect personal data as well as other information when you use the following services:
- using our Sites,
- creating and using an account on any of the Sites,
- using of any of our other services or products (including support services), which may be accessible via a third party platform, web application or social networking service (together with the "ancillary services").
In this Policy, we refer to the Sites, the account, and the ancillary services together as the "Services"
1.1. Registration data
To create an account you can choose direct registration or social network authentication. Depending on what is described below, third parties may provide registration and authentication services. In this case, we will be able to access some data, stored by these third-party services, for registration or identification purposes.
Direct registration (on auth.starladder.com)
The user registers by filling out the registration form and providing the Personal Data directly to us.
Data collected: email address, username, and password.
Place of processing: Germany.
Facebook Authentication (Facebook, Inc.)
Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.
VK Client Authorization (VKontakte Ltd)
VK Client Authorization is a registration and authentication service provided by VKontakte Ltd and is connected to the VK social network.
1.2. Account data
You have choices about the information on your profile, such as your first & last name, birthday, country, city, gender, photo (avatar), team membership, links to social media, battle.net id, steam id, skype, etc.
You do not have to provide additional information on your profile; however, if you want to use special services via our Sites (to enter competitions, to find teammates, etc.) obtaining of some personal data could become necessary. It is your choice whether to include sensitive information on your profile and to make that sensitive information public.
Please do not post or add personal data to your profile that you would not want to be publicly available. We may also collect information related to personal information, ratings, results statistics, and team information in order to follow the career and achievements of our competitors.
We also collect information related to tournaments and store it for up to 2 years for administrative purposes. Examples: method of communication, experience, rating history, ratings, statistics of results, information about the team and the display name of the player, information about participation in tournaments.
Who has access to the specified data types? Tournament Operations department and Support department. We can also collect information provided by players who participate in our e-sports events to provide personalized service, support and assistance during the competition. Examples: dietary restrictions, food allergies and clothing sizes. Who has access to the specified data types? Tournament Operations department and Support department.
1.3. Tracking data
When you use the Services, we may collect and process the following "Tracking Data": Location information associated with your IP address when you visit our Sites or sign-in into your account. Information relating to your use of our Services including, but not limited to, information about when and how you use the Services and data traffic and recordings of the parts of the screen you click on while using our Services (so-called "clickstreams").
Log files and statistics about actions taken in our Services. Technical information about any device that you use when you visit the Sites, including your Media Access Control (MAC), Unique Device Identifier (UDID) or equivalent device identifier, your IP address and the browser you are using.
1.4. Content data
We may collect personal data from you when you provide, post or upload it to our Sites or services: when you fill out a form (contact form, subscribe to newsletters, support request, bug report, respond to a survey, etc.), information you sent or post in any of the forums or chat, data you provide to us when participating in tournaments and other events, information relating to your profiles on social networking sites to allow integration with such social networking sites.
You do not have to post or upload personal data; though if you do not, it may limit your ability to use our Sites or service.
1.5. Transaction data
We collect information about transactions related to the payment of prize winners of cyber tournaments. Transaction data can be stored for up to 7 years (mainly for audit purposes). Examples: refund payments, refunds, payment information, delivery information, information about prizes and accreditations received in competitions. Who has access to the specified data types? Tournament Operations department, Support department, Security, Financial department.
1.6. Data on user activity on resources
When a user interacts with our services, we collect server logs. In most cases, server logs are kept for a period from 90 days to 1 year. Examples: IP addresses, access dates and times, region and activity logs. Who has access to the specified data types? Tournament Operations department, Support department and Security.
1.7. Device Information
We may collect information about devices used to access our services. Examples: hardware models, operating systems and versions, unique device identifiers. Who has access to the specified data types? Tournament Operations department, Support department and Security. Storage time: from 90 days to 1 year.
Starladder may use the information we collect from players and partners to send messages to our players about our current and future products, services, promotions, research, polls, news, updates, and events. Starladder may also use this information to advertise and hold contests and prize draw, to provide relevant awards and to show you relevant advertisements and content related to our services. Data collected about specific events, such as surveys, are stored for no longer than 90 days. Examples: name, email address, mail, survey information, purchase/license history, activity history, email usage data mail, e.g. display names of Facebook and Twitter users and other social networks and any web-platforms.
1.9. Media Information
We do not use your email in marketing or promotional newsletters until you subscribe to them yourself. Your email is retained as long as your account exists.
If you want to delete your Account - contact us about this at [email protected]
2.2. Provision of services
Data collected for that purpose will only be kept as long as necessary to provide the requested Services and to comply with applicable laws. The Account data is optional - you do not have to provide additional information on your profile. However, if you want to use some special services via our website, it will be necessary to add some data to your profile.
For example, if you want to enter some tournament, competition or another kind of event, filling out your profile becomes necessary: we need to make sure that you meet the requirements of the tournament. Such requirements are specified in the rules of the tournament and published on the relevant site. Account Data is retained as long as your account exists.
2.3. Security and Investigations
2.4. Marketing and advertising
We may promote our Services to you and others. We target (and measure the performance of) ads to Members, Visitors and others both on and off our Services directly or through a variety of partners, using the following data, whether separately or combined, including, but not limited to, using publishing newsletters to email addresses and marketing companies:
Data from advertising technologies on and off our Services, like web beacons, pixels, ad tags, cookies, and device identifiers, Member-provided information (e.g., profile, contact information), Data from your use of our Services (e.g., content you read, page visits, videos you watch, clicking on an ad, search history, feed, tournaments participation, etc.), including as described in Section 1.4.
We do not share your personal data with any third-party advertisers or ad networks for their advertising except for (i) with your separate permission (e.g., lead generation form) or (ii) data already visible to any users of the Services (e.g. profile).
However, if you view or click on an ad on or off our site, the ad provider will get a signal that someone visited the page that displayed the ad, and they may through the use of mechanisms such as cookies determine it is you. Advertising partners may associate personal data collected by the advertiser directly from you with our cookies and similar technologies. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.
2.5. Developing Services and Research
We use data to conduct research and development for the further development of our Services to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services.
2.6. Customer Support
We use the data (which can include your communications) to investigate, respond to and resolve complaints and Service issues (e.g., bugs).
2.7. Aggregate Insights
We use your data to produce and share aggregated insights that do not identify you. For example, we may use your data to generate statistics about our members, their geographic and interests, to calculate ad impressions served or clicked on, etc.
We may disclose and allow access to information collected through our Services to facilitate the targeting, delivery, and measurement of advertising through and in connection with the Service: to facilitate the targeting, delivery, and measurement of online advertising on third-party services on our behalf; and otherwise to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to our users.
Where necessary to provide you with Services you request from us, we may share your personal data with third parties who provide services to us, including to countries outside the European Economic Area. We reserve the right to transfer personal data of participants who expressed a desire to take part in tournaments to other processors for the purpose of (not limited to): buying tickets for various types of transport for the Participant in order to organize his transfer to the venue of the tournaments (both LAN, and Online); submission of documents to visa centers, consulates, embassies for the purpose of documenting the procedure for crossing the border by the Participant in the event of such crossing during the transfer to the venue of the tournaments (both LAN and Online); rent / order apartments of any type (e.g. hotel rooms, flats, etc.) to accommodate the Participant of the tournament; conducting cash transactions. Information about third parties to whom such personal data was transmitted, the Participant can receive after a corresponding written request to the email address specified in clause 7.3. of these rules.
Nevertheless, Starladder guarantees that with each of the information processors, who are third-party data processors, an appropriate personal data protection agreement has been concluded. In any case, the nature of the transfer of user data by third parties is a one-off character and strictly in the cases mentioned above. We may share anonymous information, i.e., information which does not directly or indirectly disclose your identity, and aggregated information (meaning information about groups and categories of users, including game statistics and behavior, but which does not identify and that cannot reasonably be used to identify any individual user) with our advertising partners. We may also allow our advertisers to collect anonymous information and aggregated information within the Services and they may then share that information with us. Our advertisers may collect this information through the use of tracking technologies like cookies and web beacons.
This enables our advertisers to develop and deliver targeted advertising in the Services and on the websites of third parties so that they can try to serve you with advertisements for products and services that are most likely to be of interest to you. Advertisers will also use this information to monitor, improve, or modify their operations.
4.1. What are Cookies?
A cookie is a small file placed on your device that enables features and functionality. For example, cookies enable us to identify your device, secure your access to our sites generally, and even help us know if someone attempts to access your account from a different device. Cookies also help us serve relevant ads to you.
Cookies can be used to recognize you when you visit our sites, remember your preferences, and give you a personalized experience that's in line with your settings. Cookies also make your interactions with our services faster and more secure. Additionally, cookies allow us to bring you advertising both on and off the Starladder sites and bring customized features to you through social media widget such as our "Share" button.
Preferences, features and services
Cookies can help you fill out forms on Starladder sites more easily. Cookies can tell us what your preferences are (such as language preference, country location, or other online settings). They also provide you with customized content and experiences.
Performance, Analytics, and Research
4.3. Third-party cookies we may use
We may use the services listed below to monitor and analyze web traffic, for ads targeting and can be used to keep track of users behavior.
Google AdWords conversion tracking (Google Inc.)
Google AdWords conversion tracking is an analytics service provided by Google Inc. that connects data from the Google AdWords advertising network with actions performed on the Sites.
Google Analytics with anonymized IP (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of the Sites, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
Twitter Ads conversion tracking (Twitter, Inc.)
Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on the Sites.
Facebook Ads conversion tracking (Facebook, Inc.)
Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed the Sites.
Display Advertising extension for Google Analytics (Google Inc.)
Google Analytics on the Sites might use Google's Interest-based advertising, 3rd-party audience data, and information from the DoubleClick Cookie to extend analytics with demographics, interests, and ads interaction data.
Yandex Metrica (YANDEX, LLC)
Yandex Metrica is an analytics and heat mapping service provided by YANDEX, LLC. Yandex Metrica can be used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are.
User ID extension for Google Analytics (Google Inc.)
Google Analytics on the Sites makes use of a feature called User ID. This setup allows for more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device.
The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by the Sites.
4.4. Cookies settings
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org or www.aboutcookies.org.
We recognise that we have a special obligation to protect personal information obtained from minors. We will not knowingly collect personal information from any minors, or process such information, without parental consent. For the purpose of this Policy, a minor means any individual who is under the age of 18 (or the minimum legal age to consent to the collection and processing of personal information where this is different under applicable law).
All users who are minors in the jurisdiction in which they reside must have the permission of, and be directly supervised by, their parent or guardian to use the Services. If you are a minor, you must have your parent or guardian read and agree to this Policy prior to you using the Services.
By signing up for an Account, you represent and warrant that you are a "natural person" who is over the age of eighteen (18) or whose legal guardian has accepted and agreed to these Privacy & Cookies Policy.
6.1. Data retention
We retain your personal data while your account is in existence or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. In any case, Starladder is not intended to keep your personal data longer than the circumstances and the purpose of processing such personal data. The storage period of personal data that is not used to the extent necessary to provide services to the user does not exceed 3 years, with the exception of certain data categories, for example, we keep an archive of documentation to support any existing or expected legal cases and audit for up to 7 years. Examples: professional player contracts, personal affairs, transaction information. Who has access to the specified data types? Tournament Operations department, Legal department and security service, Financial department.
6.2. Rights to Access and Control Your Personal Data
For personal data that we have about you have the right to:
- Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
- Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
- Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
- Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of the personal data you provided in the machine-readable form.
- To Transfer data to the resource indicated by you: you can request us to transfer your personal data in favor of the resource indicated by you. If you wish to exercise any of these rights, then please contact us at [email protected]
Privacy and data protection of our visitors & members are of a particularly high priority for the management of the Starladder. Any information stored on Starladder's platform is treated as confidential. All information is stored securely and is accessed by authorized personnel only. Starladder has implemented numerous technical and organizational measures to ensure the complete protection of personal data processed through our Services.
To manage it, Starladder operates and uses systems and programs that allow anonymizing and encrypting user data during storage and processing in order to minimize unwanted user personalization. Starladder also applies the means of timely restoring the availability and access to personal data in the event of a natural or technical incident and periodically conducts a procedure for regularly checking and evaluating the effectiveness of technical and organizational measures, ensuring the safety of processing.
7.2. Third party sites
7.3. Contact Information
If you have any questions or comments about this Policy, please contact us at [email protected]. When you contact us (for example, via the contact form, by email or through social networks), your data provided by you is subject to processing by us. Information may be stored in the Customer Relationship Management System ("CRM System") or a similar system for processing requests. We delete requests if they are no longer required. We check their relevance every two years. In addition, there are legal obligations for archiving and storing such requests.
7.4. The language of the Policy
Where Starladder has provided you with a translation of the English language version of the Policy, then you agree that the translation is provided for your convenience only and that the English language versions of the Policy will govern your relationship with Starladder.
If there is any contradiction between what the English language version of the Policy says and what a translation says, then the English language version shall take precedence
7.5. Changes to this Policy
We may change this Policy from time to time for various reasons such as changes to reflect in law and regulation, changes in industry practices and technological developments. In case you have a registered Account, you will be notified of any changes of this Policy via e-mail to the e-mail address related to your Account. The latest version of this Policy will always be available on the Sites. Any new version of this Policy shall take effect (i) immediately upon the date of your receipt of the notification e-mail where the changes to this Policy relate to non-material changes which do not reduce your rights; or (ii) no less than thirty (30) days after your receipt of the notification e-mail where the changes to this Policy potentially reduce your rights; or (iii) in case you do not have a registered Account, the moment they are uploaded to our Services.
8. Data Protection Officer