I. Controller, Scope
G2esports is a service provided by G ESPORTS HOLDING GMBH (hereinafter also referred to as “Provider”), acting as Controller in accordance with relevant data protection provisions. Please find full company and contact details on the website.
The protection of personal data has the highest priority for us. We would therefore like to inform you about which data we collect when, and how we process your personal data. This privacy notice describes the collection and processing of personal data on the website www.g2esports.com (hereinafter referred to as “Website” or “Platform”).
Please note that some of the data processing activities may be performed in joint controllership with one or more vendors on our marketplace, as described in the relevant section further down. In such cases, please refer to the relevant vendor profile available on the marketplace to learn about the joint controller’s details.
Data Protection Officer
We have appointed a Data Protection Officer, that you can always reach out at: [email protected].
II. General information about data processing
1. Purposes of processing
In principle, we only process personal data of Users if this is necessary to provide a functional Platform, our contents and services and to close or perform contracts with Users.
2. Legal basis for the processing of personal data
Most often we process personal data according to on one of the following legal bases:
Whenever we collect the data subject’s consent to the processing of personal data, Art. 6 para. 1 a EU General Data Protection Regulation (GDPR) serves as the legal basis.
If the processing of personal data is necessary for compliance with a legal obligation which the Controller is subject to, Art. 6 para. 1 c GDPR serves as the legal basis.
contract or pre-contractual measures
If the processing of personal data is necessary for the performance of a contract to which the data subject is party, Art. 6 para. 1 b GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.
If processing is necessary for the purposes of the legitimate interests pursued by the Controller or a third party and if such interests are not overridden by the interests, fundamental rights and freedoms of the data subject, Art. 6 para. 1 f GDPR serves as the legal basis.
Unless otherwise specified within this privacy notice, the processing of your personal data is necessary for the performance of a contract with you or in the framework of pre-contractual measures, which take place at your request, and the legal basis for processing is therefore art. 6 para. 1 b GDPR.
3. Data erasure and retention time
In principle and unless otherwise stated, your personal data will only be stored until the purpose of the collection and storage is achieved. If the storage is based on your consent, personal data can be stored as long as you do not revoke such consent.
Furthermore, data may be stored if it is required by European or national legal provisions, laws or regulations which we are subject to. Personal data will be blocked or deleted if the retention period set forth by the any such regulations expires, unless further storage is necessary for the conclusion or fulfilment of a contract.
4. Transfer to third countries
Unless otherwise stated, all data processing operations take place within the EU or the EEA countries.
Data processing operations carried out by third-party providers established outside the mentioned geographical area may be carried out in part or in full in the countries the respective providers are based in, in accordance with the relevant and applicable data protection regulations.
A transfer of personal data outside the EU or the EEA shall only take place on the basis of on an adequacy decision of the European Commission, including the adequacy decision regarding the EU-US Privacy Shield, or subject to appropriate safeguards, such as standard data protection clauses adopted by the European Commission.
A list of current adequacy decisions is available on the European Commission’s website.
Further information about the EU-US Privacy Shield and a list of participating data recipients can be found on the website of the US Department of Commerce.
III. Processing of personal data in general
Regardless of whether you take advantage of any of the Website’s features – such as the creation of User accounts – we automatically collect data about your use of the Website. This includes in particular the accessed URL, access date and time, transferred data volume, http status code of the access reply, web browser type and operating system, HTTP referrer, as well as IP address. This information is not associated with your person.
We collect and process such data to ensure Website operation and availability. In addition, it is used to analyse, store and evaluate information about User behaviour in an anonymous form and to continuously improve and further develop our service.
We only store your IP address in the log files for a limited period of time, if this is necessary for security purposes.
These purposes constitute our legitimate interest, which justifies data processing pursuant to art. 6 par. 1 lit. f) GDPR.
IV. Data processing when creating a User account
When creating a User account, we store the following data: first and last name, password, e-mail address, age. Your User account will be populated with such data, allowing you to set preferences and keep track of your activity. We need to collect an indication about your age to make sure that you comply with our minimum age requirements, or with specific age requirements applicable to selected features.
The following additional personal data will be collected once the User account has been created in order to access to certain features of the Website (e.g. to place orders on the marketplace): invoicing data (first and last name, if different from user data), invoicing address, delivery address. Also, once an account has been created, all information or data generated and collected via that account, such as login history, site visits or page views will be linked with you.
The provision of all above-mentioned data is required as a precontractual measure of a contract we will be closing with you (e.g. about a membership plan) or in order to perform a contract we have already closed with you and to provide you the relevant service. Failure to provide them so will result in unavailability of our services.
Further data and information, such as your personal interests in terms of games, players, teams etc., may be provided on a voluntary basis.
Registering via a social network
On our Website you may have the option to create a user account and subsequently log into it using a preexisting social media account, as displayed on our Website. If you choose this option, we will pull the following data from your social media profile to populate your user account: username.
Based on your consent, we may also collect the total amount of followers on your social media profile. We use this information to scout for users that could potentially act as influencers for us. Furthermore, you have the option to link any of your accounts on supported social media with your user account on our website.
In these cases, the processing of personal data is based on art. 6 par. 1 a) GDPR.
Creating a vendor account
In addition to what specified above, whenever you register an account as a vendor on our marketplace, we will collect the following data: name & last name, trade name, e-mail, FAX number, payment data, address, invoicing address, VAT number or other tax identification number.
V. Processing of personal data when placing an order
When you place an order via our Website, personal data related to it will be collected to process that order.
If you close a contract over a membership plan, we will process the data you have stored in your user account to perform the contract and – if applicable – to process payments.
2. Purchases on the marketplace
If you purchase goods or services on our marketplace, we will process the data you have stored in your user account to perform the contract and – if applicable – to process payments, and will disclose such data to the respective vendor that you’ve entered into a contract with. In case you place the order without registering or logging into a user account (“as guest”) we’ll collect and disclose to the respective vendor the following data: invoicing data (first and last name, if different from user data), invoicing address, delivery address.
VI. Personal data you freely upload
Personal data processed when contacting us
If you submit a support request to us via the Platform, we will only collect such data and information that you will provide when describing the reason for your request. The provision of personal data is not required to this end. Should any personal data be provided, it will only be used to process your request and reply to it.
If you contact us via the contact form available on our website, you will be required to provide the following personal data: name, e-mail address. This information will only be used to process your inquiry and reply to it.
Personal data processed publishing content on the Platform
If you publish comments, content or any other chat messages to our Platform, any personal data contained therein shall be made available and disclosed to such audience as displayed on the Platform. Unless otherwise specified, content comments shall be made public for everyone accessing the Platform, while chat messages content shall be disclosed only to chat participants.
Personal data processed in connection with surveys, polls and quizzes
Whenever you participate in polls, surveys or quizzes as performed from time to time via our Website, we’ll collect various personal data referring to you on an entirely voluntary basis. We will inform you in connection with each specific circumstance, what personal data are affected and for which purposes they are being collected.
Unless otherwise specified, the processing of personal data described in this section takes place within the framework or in preparation of a contract with us, according to art. 6 par. 1b GDPR. From time to time we may, however, request your consent to perform processing activities not directly linked to a contract with us. In such cases we will ask for your consent according to art. 6 par. 1a GDPR.
VII. Data Processors
In order to provide our services, we may cooperate with selected third-party providers who process data on our behalf (“Processors”). This may for instance be the case whenever we need to send e-mail notifications to Users for contractual purposes. Such e-mail could be managed and sent out via a third-party service.
Similarly, in case the service is provided against a fee, payments shall be processed through one of the Processors we cooperate with. Payment data shall therefore be directly collected and processed by the selected payment service provider, that will then inform us about the payment status. We do not collect or store any personal data regarding payment methods.
Furthermore, we cooperate with processors to handle logistics and fulfilment processes, as well as to operate and maintain our infrastructure.
As far as legally required, we have entered into agreements pursuant to art. 28 GDPR with Processors, including payment service providers, processing your personal data on our behalf.
VIII. Joint controllership, Profiling
Whenever you use our marketplace to purchase goods or services from any of the offering vendors, we and the relevant vendor will act as joint controllers as of art. 4 (7) and 26 GDPR. This means that we and the relevant vendor jointly determine the purposes and means of the processing by way of a binding arrangement according to art. 26 GDPR.
In particular, whenever you place an order, we will collect the necessary data and forward it to the relevant vendor, as described above in sec. V. 2. We will also process this data to analyze and evaluate your use of the marketplace and your interests for the goods and services offered, in order to create user profiles based on criteria such as age, geolocation, purchasing habits, gender, interactions with content on our Website, and thereby improve our service, enhance its functionalities and provide you with customized features or offers. We may share data stored in user profiles with third parties, including vendors, only in an aggregate and fully anonymized manner.
The processing of personal data for the creation of user profiles is based on your consent as of art. 6 par. 1a) GDPR.
IX. Processing in compliance with a legal obligation
Please note that, in addition to what specified in this privacy notice, your data may be processed in compliance with legal obligations to which we or out joint controllers are subject to. For instance, we may be obliged to store your data for a legally determined period to comply with tax law provisions. Please contact us in case you want to learn further details about such processing activities.
In such cases the legal basis of the processing is art. 6 par. 1c GDPR.
X. Use of Trackers
1. Description and scope of data processing
In order to improve User experience of our Website and to enable selected functions, we implement cookies or other trackers (hereinafter jointly referred to as “Cookies”) on various pages. These are small data sets being stored on your device. Some of the Cookies we use expire after the end of the browser session, i.e. after closing your browser (so-called session Cookies). Other Cookies remain on your device and enable us or our partner companies to recognize your browser or device on your next visit (persistent Cookies).
You can set your browser preferences in order to be notified about the setting of Cookies and decide individually about accepting or refusing them in certain cases or generally. You can also manually delete Cookies from your device at any time.
Failure to accept Cookies may result in minor limitations in our service’s functionalities.
2. Strictly necessary Cookies
Some of the Cookies we use are strictly necessary to allow us to deliver the service you requested or to operate our Website and Platform. Some elements of our Website require that your browser be identified after page changes. Such technical Cookies may collect personal information about you, such IP address, log-in information, etc.
The strictly necessary Cookies we implement have a lifetime that ranges between the duration of a browsing session (“session Cookies”) and 12 months.
The processing of personal data through strictly necessary cookies is art. 6 par. 1f GDPR. In case such cookies are necessary as a pre-contractual measure or for performing a contract with you, the legal basis is art. 6 par. 1b GDPR.
3. Other Cookies
In addition, we use third-party Cookies to monitor and evaluate User behavior for statistics and market analysis purposes. Such Cookies are provided by third parties and implemented in our Website. Please refer to the following sections for details.
Such Cookies allow us to analyse your use of the Website and improve it continuously. Analytics allow us to offer you a better service that meets your interests better.
Unless otherwise specified, the legal basis of processing through other Cookies mentioned below is your consent pursuant to art. 6 par. 1a GDPR. Unless otherwise specified, the lifetime of Cookies used based on your consent ends upon withdrawal of your consent.
Google Ads is an advertising, analytics and conversion tracking service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. If you access our Website via a Google ad, Google Ads places a conversion cookie on your device. This cookie expires after 30 days. It doesn’t allow for your identification. If the cookie has not expired when you visit certain pages of our Website, we and Google may recognize that a User clicked on the ad and has been redirected to our Website. Each Google Ads customer is assigned a different cookie. As a result, cookies cannot be tracked across Google Ads customer Websites. The information collected by the conversion cookie is used to generate conversion statistics for Google Ads customers who have opted for conversion tracking. Google Ads customers will know the total number of Users who clicked on their ad and were directed to a page tagged with a conversion tracking tag. However, we will not receive any information that personally identifies Users. If you do not wish to participate in the tracking process, you can also opt out of the cookie-setting process required for this, for example via your browser setting, which generally disables automatic cookie-setting. You can also deactivate cookies for conversion tracking by setting your browser to block cookies from the “googleadservices.com” domain.
On our Website we integrate the so-called “Facebook pixel”, operated by Facebook Inc, 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are resident in the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, for purposes of analysis, optimization and economic operation of our online offer.
Facebook is certified under the Privacy Shield Agreement and thereby offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
The Facebook pixel enables Facebook to create target groups for the display of advertisements based on our Website’s visitors. Accordingly, we use the Facebook Pixel in order to display the such ads placed by us only to those Facebook users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook Ads correspond to the potential interest of the users and do not appear annoying. With the help of the Facebook Pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users are redirected to our website after clicking on a Facebook ad (so-called “conversion”).
The processing of data by Facebook takes place within the framework of Facebook’s data usage guidelines. Accordingly, general information on the display of Facebook ads is provided in the Facebook Data Usage Policy: https://www.facebook.com/policy. Specific information and details about the Facebook pixel and its functionality can be found in the Facebook help section: https://www.facebook.com/business/help/651294705016616.
You may object to the collection by the Facebook Pixel and use of your information to display Facebook Ads. To control the types of ads that are displayed to you within Facebook, you can go to the Facebook-established page and follow the usage-based advertising settings instructions at https://www.facebook.com/settings?tab=ads. The settings are platform-independent, meaning that they are applied to all devices, such as desktop computers or mobile devices.
Our CRM system Salesforce (provided by Salesforce.com Germany GmbH, Erika-Mann-Str. 31, 80636 Munich, Germany) allows us to analyze and evaluate user behavior in order to target users with ads that are more relevant to them and consistent with their preferences and interests. To achieve this purpose, Salesforce places cookies on users’ devices via our Website in order to keep track of their choices, purchases and preferences. Based upon this information, we are able to create user profiles and improve our service. Salesforce is certified under the Privacy Shield Agreement and thus offers an additional guarantee to comply with European data protection law if data is processed in the USA (https://c1.sfdcstatic.com/content/dam/web/de_de/www/documents/legal/german-privacy-shield-notice.pdf).
XI. Promotional e-mail messages
If we have collected your e-mail address in the context of the purchase of one of our services, we may send you promotional e-mail messages about our own products and service similar to those you’ve already purchased. You can object to receiving such promotional e-mail messages at any time at no cost by sending an e-mail to [email protected] We will inform you about the right of objection when collecting the email address and within each e-mail sent.
The legal basis of data processing is art. 13 par. 2 of dir. 2002/58/EC and the respective implementing provisions in German law (§ 7 par. 3 UWG).
You can subscribe to our newsletter by entering your e-mail address in the respective form or by checking the respective check-box upon registration of your user account. You will then receive an automatic confirmation e-mail to the address you entered, which contains a link. The registration process is only completed once you confirm it by navigating to that link.
We use your email address to send you promotional content and offers about our own services and those of partner companies. The data will not be passed on to third parties.
You can withdraw your consent to receive newsletters at any time without stating reasons by following the instruction provided in each newsletter sent, or by sending us an unambiguous notice at firstname.lastname@example.org. We will inform you about the right to withdraw your consent upon subscription to the newsletter service and within each newsletter sent.
Our newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use our mailing service provider Salesforce.com (provided by Salesforce.com Germany GmbH, Erika-Mann-Str. 31, 80636 Munich, Germany), from their server. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and time of retrieval are initially collected.
This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined by means of the IP address) or the access times. Statistical surveys also include determining whether newsletters are opened, when they are opened and which links are being clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our nor Salesforce’s intention to track individual users. Twe use this feature to learn more about the reading habits of our users and to adapt our content to their preferences or to adapt the content of our newsletters to the interests of our users.
The legal basis for processing your personal data is art. 6 par. 1a) GDPR.
XII. Social Media plugins
We implement social media plugins of various providers in order to improve our service and make it more attractive for you and to allow for the sharing of content. This is our legitimate interest justifying the processing of personal data according to art. 6 par. 1f GDPR.
In order to increase the protection of your data when you use our Website, such plugins are not fully integrated. This way we ensure that no connection to the servers of the respective social network’s provider is established, unless you decide to activate the plugin.
If you click on one of the plugin buttons, a new window will appear and load the respective social network provider’s page, on which you may (after entering your login data, if required) e.g. press the Like or Share button.
Please find further details about the purpose and scope of the data collection and the further processing and use of the data by the respective social network providers as well as contact details and your rights and setting options for the protection of your personal data in the respective privacy statements:
- Twitter: Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA; https://twitter.com/privacy.
- Facebook: Facebook Inc, 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are resident in the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; https://www.facebook.com/policy.php.
- Reddit: Reddit, Inc., 548 Market St. #16093, San Francisco, California 94104, or, if you’re based in the EU, Reddit Ireland Limited, c/o Matheson, Attn: Reddit EU Data Inquiries, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; https://www.redditinc.com/policies/privacy-policy.
- Pinterest: Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland; https://policy.pinterest.com/en/privacy-policy.
- Weibo: https://www.weibo.com/overseas
- Whatsapp: WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; https://www.whatsapp.com/legal/#privacy-policy.
- Telegram: Telegram Inc., Craigmuir Chambers, Road Town, Tortola D8, British Virgin Islands, 1110; EU representative: Telegram UK Holdings Ltd, 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ; https://telegram.org/privacy.
- Instagram: Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, https://help.instagram.com/519522125107875.
- Twitch: Twitch Interactive, Inc. mit Sitz in 350 Bush Street, 2nd Floor, San Francisco, CA 94104, https://www.twitch.tv/p/legal/privacy-notice/.
- YouTube: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, https://policies.google.com/?hl=en&gl=en.
- Discord: Discord, Inc., 444 De Haro St, Suite 200, San Francisco, California 94107, https://discordapp.com/privacy
XIII. Data Subjects’ rights
As a data subject, you have the following rights pursuant to the GDPR:
- Your right of access – You have the right to ask us for copies of your personal information.
- Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
- Your right to notification – If you have exercised your right to have the Controller rectify, erase or limit the processing, the Controller shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data concerning you have been disclosed, unless this proves impossible or involves disproportionate effort. You have the right to be informed about those recipients.
- Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances. Please find further details in the box below this section.
- Your right to withdraw consent – You have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
- Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
- You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
- Please reach out for us at the contact details indicated on the Website if you wish to make a request.
- Your right to file a complaint
- You can also complain to a data protection authority if you do not agree on how we have used your data.
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions. The Controller shall no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time without giving reasons to the processing of the personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
XI. Amendments to this privacy notice
Due to the dynamic development of the Internet, new technologies and possibilities are constantly developing. To enable us to offer you these possibilities and technologies, we reserve the right to change this privacy notice for the future when introducing new, additional or when changing or extending existing services or service elements.
If the change to the privacy notice only affects the use of data in a general form and do not affect the use of data within the scope of a user account, the new privacy notice shall apply from the date of its update on the Website.
A change of the privacy notice, which refers to the use of the data already collected and stored in your User account shall only take place if this is reasonably acceptable for you. If and to the extent that changes to the privacy notice reflect on the use of data already collected and stored in your user account, we will notify you in good time via e-mail, on our Website, or in any other suitable way. You have the right to object to the new privacy notice within six weeks of receiving the notification. In the event of an objection, we reserve the right to delete your user account. If no objection is raised, the amended privacy notice shall become effective for you. We will inform about your right to object and about the consequences thereof in the amendment notice.