Last Modified: January 03 ,2019
We are Smilegate Entertainment, Inc., a company located at 5F, Solidspace Bldg. 220, Pangyoyeok-ro, Bundang-gu, Seongnam-si, Gyeonggi-do, Korea ("SGE", "us", "we" or "our").
We are the organiser of various eSports tournaments, events and associated services (including but not limited to the Crossfire Stars 2018 tournament) (the "eSports Tournaments").
Name : Ilhwan Kim
Title : Chief Technology Officer
Email : firstname.lastname@example.org
For the purposes of applicable EU data protection legislation, we also have a representative located within the European Union. The contact details of our EU representative are set out below:
Name : Dr. Angela Harth
Address : v. Keussler Consulting GbR, partnership,
Schepp Allee 47, 64295 Darmstadt, Germany
Telephone : +49 6151 39177-0
Fax : +49 6151 39177-17
Email : email@example.com
We collect personal data about you in the following ways in connection with the eSports Tournaments.
Information we collect about you indirectly
We generally collect information about you (including personal data) indirectly through our partner companies (called publishers) who service the eSports games for us in the country where you live. When you qualify or choose to participate in our eSports Tournaments, these publisher companies will provide us with certain personal data about you.
The information we receive is likely to include the following:
• Nickname; In-Game Name; First Name; Last Name; Gender; Nationality; Date of Birth; Passport Number; Passport Expiration Date; Cell phone Number; Email; SNS URL; Skype ID; WeChat ID; Languages Spoken; Years playing Pro; Position; Favoured Weapon; Favoured Character; Awards; T-shirt Size; Dietary Requirements; Photo ID
Information we collect from you directly
During your participation in our eSports Tournaments, we will collect certain personal data about you. For example, information relating to your gameplay, in-game activity and progression through the eSports Tournament.
If you are fortunate enough to win, we will also ask you for your bank account and payment details so that we can arrange for your prize money to be transferred to you.
Information we collect about you automatically
We may collect the following information from you automatically when you visit our eSports Tournament websites:
• Technical information such as the internet protocol (known as IP) address used to connect your computer to the internet, your log-in information, time of access, date of access, time zone setting, web page(s) visited, software crash reports, type and version of browser used, browser plug-in types and versions used, and operating system and platform to ensure the security of your account and to verify that the person operating your account is you;
• Your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our websites (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call out customer service team; and
• Information about your computer or device allowing us to analyse trends, administer our websites, track your web navigation, and gather broad demographic information for aggregated use.
Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with certain data, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our relationship. We will inform you if your failure to provide any requested personal information is going to result in these consequences.
You have a right to choose whether cookies are installed on your device or not. You may choose to refuse all cookies, confirm each time a cookie is saved, or permit all cookies by going to [Tools]>[Internet Option]>[Security]>[Custom Setting], or by using the Settings or Options function on mobile devices. However, if you refuse all cookies, you may not be able to access certain services or functionality of our websites.
We collect, use and disclose your personal data for a number of reasons, including:
To organise and provide the eSports Tournaments and associated services
• for the purposes of providing and organising eSports Tournaments, including all associated logistics such as:
(A) broadcasting and production
(B) event travel and logistics, including accommodation and nutrition
(C) tournament administration
(D) event ticketing
• to post tournament information on our website for general users in “player information” format
• for settling fees, provide contents, purchase and fee payments, delivery of goods (prizes from events, etc.)
To manage our players
• for customers services purposes
• to prevent unlawful and unauthorized use by rogue players, to check if they want to join, to deal with civil complaints including resolving dissatisfaction and customer advice, to preserve records for any disputes mediation and to give notifications
Business optimization and service development
• to conduct troubleshooting, research, analysis and product and service development to provide our players with the best gameplay experiences when participating in our eSports Tournaments.
Legal proceedings and requirements
• to investigate or address claims or disputes relating to your participation in the eSports Tournaments or as otherwise allowed or required by applicable law
For marketing and promotion purposes
• for specialization or development of new services (products), to deliver promotional information such as events and to provide services based on demographic information, statistics related to access frequency and the members' use of the service
We may share your personal data with the following categories of recipients:
• Your personal data will be used by us and may be disclosed to our group companies (for example Smilegate Holdings, Inc.).
• As described above, we have relationships with a number of publisher companies that service our games in different jurisdictions. These companies share your data with us.
• In order to provide the eSports Tournaments, we work with service providers (e.g. broadcasters, event organizers and travel agencies) who may, in the course of providing their services, receive and process personal data on our instruction and on the basis of a contractual data processing agreement.
Other players and/or the general public
• We post tournament information on our website for general users in “player information” format. This information may be viewable by your friends, people in games, or the public in general.
Regulatory bodies/industry bodies
• We may disclose your personal data to a regulatory authority, government agency or law enforcement body with jurisdiction over our activities.
• In the event that we sell or buy any business assets, we may disclose your personal data to the prospective seller or buyer of such business or assets. If SGE or substantially all of its assets are acquired by a third party, personal data held by us about our clients will be one of the transferred assets.
You have various rights in relation to the data which we hold about you. To get in touch with us about any of your rights under applicable data protection laws, please use the contact details set out in section 오류! 참조 원본을 찾을 수 없습니다. above.
We will seek to deal with your request without undue delay, and in any event within any time limits provided for in applicable data protection law (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.
In addition, for players located in the EU only, applicable privacy laws in the EU grant you the following rights in relation to your personal information:
• you can object to us processing your personal information in certain circumstances (for example, where we have done so on the basis that it is in our legitimate interests to do so);
• you can withdraw consent at any time;
• you can ask what information we hold about you and be provided with a copy. We will also give you extra information, such as why we use this information about you, where it came from and what types of people we have sent it to;
• you can ask us to send you, or another organisation, certain types of information about you in a format that can be read by computer;
• you can ask us to delete the information that we hold about you in certain circumstances (for example, where we no longer need the information);
• you may in some cases restrict our use of information about you (for example, if you tell us that the information is inaccurate we can only use it for limited purposes while we check its accuracy);
• if information is incorrect you can ask us to correct it;
• you may have the right to ask us to assist you in transferring your personal data to a third party; and
• you can lodge a complaint with your local supervisory authority. Contact details for data protection authorities in the EU are available at:
We have in place appropriate technical and organizational security measures to protect your personal data, including:
• In order to protect the unauthorized disclosure of users' personal data from hacking or any external break-ins, we currently use equipment that blocks any external break-ins, which protects the data from any hacking, attacks, or unauthorized access, and we also use encryption, etc., so that personal data may be transferred safely. In particular, the server containing users' personal data managed separately so that is not directly linked to the external internet line.
• In preparation for any unexpected emergencies, we have a policy to back-up the system and data.
We are taking protective measures to try and minimize damages caused by computer viruses by using vaccines that are regularly updated.
Only the minimum number of people have right of access to the users' personal data.
We train our staff who handle personal data on new security technology and personal data protection obligations. Further, through an internal designated personal data protection unit, etc., we try and correct any errors immediately upon detection by checking the company's personal data processing procedure implementation and the relevant personnel's compliance with the personal data protection policies.
In general, your data will be stored in the Republic of Korea. However, it may be transferred to other jurisdictions. For example, your personal data will be transferred to any country in which our eSports Tournaments are taking place.
We will not keep your personal data for longer than is necessary for the purposes for which we have collected it, unless we believe that the law or other regulation requires us to keep it (for example, because of a request by a tax authority or in connection with any anticipated litigation) or if we require it to enforce our agreements.
Where there is a need to store data because of relevant legislation, for the period stipulated in the legislation, the player data may be:
• stored for 5 years if records related to contracts or subscription cancellations
• stored for 5 years if records related to supply of goods and payments
• stored for 3 years if records related to customer complaint or dispute resolution
• stored for 6 months if records related to marks or advertisements
• stored for 3 months if records related to website visits
When it is no longer necessary to retain your personal data, we will delete the personal data that we hold about you from our systems. While we will endeavour to permanently erase your personal data once it reaches the end of its retention period, some of your personal data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists in the electronic ether, our employees will not have any access to it or use it again.
For players from the EU only, applicable privacy laws in the EU require us to inform you of the different legal bases that we rely on to legitimize our processing of your personal data. We have set these out below.
Where using your data is in our legitimate interests
We are allowed to use your personal data where it is in our interests to do so, and those interests aren't outweighed by any potential prejudice to you.
We believe that our use of your personal data is within a number of our legitimate interests, including but not limited to:
• To provide and manage the eSports Tournaments and associated services;
• To manage our players;
• For business optimization and service development;
• For marketing and promotion services;
• To ensure that our systems run smoothly; and
• To protect against improper use or unauthorized use of our services.
Where you give us your consent to use your personal data
We are allowed to use your personal data where you have specifically consented. When we seek your consent we will provide you with a full explanation of what we will be doing with your data. You will also have the right to withdraw your consent at any time.
Where using your personal data is necessary for us to carry out our obligations under our contract with you
We are allowed to use your personal data when it is necessary to do so for the performance of a contract that we have with you. For example, if you have won a competition, we need to process your bank account information in order to be able to pay you your prize money.
Where processing is necessary for us to carry out our legal obligations
As well as our obligations to you under any contract, we also have other legal obligations that we need to comply with and we are allowed to use your personal data when we need to in order to comply with those other legal obligations.