Privacy Policy

PRIVACY AND DATA POLICY

Last Modified: 2023-06-01

This Privacy and Data Policy ("Privacy Policy") describes how ESA Bilişim Elektronik Spor A.Ş. ("Company", "we", "us" or "our"), a Turkish corporation registered with the Istanbul Trade Registry with trade number 150899/5 and Mersis number 0377072181100001, and with a registered address at Maslak Mahallesi Ahi Evren Caddesi 42 Maslak Sitesi No:6/70 Sarıyer Istanbul Turkey, collects, uses, and processes your personal data.

This Privacy Policy applies and has effect in respect of services offered on ready2.gg (the "Platform") and any other software and products made available by us, as well as any other online features relating to our business, including our website at https://ready2.gg, any mailing lists we operate (the “Mailing List”), our online chat forums (the “Chats”), and the ticket system available at the Platform (the “Ticket System"). The Platform, Mailing List, Chats, and Ticket System are referred to as the “Services”.

The purpose of this Privacy Policy is to inform you about the processing of your personal data collected when using the Services. Where we decide the purpose or means for which personal data you supply through these Services is processed, we are the “data controller”. We will comply with the applicable data protection laws, including Law on the Protection of Personal Data numbered 6698 (the “Law”).

Please note that while using the Platform, you might be redirected to websites or services offered by third-party providers. Your personal data will be processed by these third-party providers and will be governed by their own privacy policies.

This Privacy Policy should be read in conjunction with our Platform's terms of use, as well as any other applicable terms for specific Services.

Company may, at any time and for any reason, amend this Policy by publishing the amended terms on the Platform. All amended terms shall automatically be effective seven (7) days after they are initially published or otherwise accepted by you. By accessing or using the Platform or the Services, you acknowledge that such modifications may occur and that you are responsible for staying up to date with any changes. Additional terms may apply to your use of a particular Service. If there is a conflict between these Terms and any additional terms that apply to a particular Service, the additional terms shall prevail.

This Policy was last updated and became effective on 2023-06-01.

SCOPE

This Privacy Policy provides information on the methods and legal grounds for collecting personal data, the categories of personal data being processed, the business processes for which the personal data is being used and the purposes of such usage, the technical and administrative measures taken to ensure the security of personal data, to whom and for what purpose personal data may be transferred, the retention periods for personal data, your legal rights, and how you can change your preferences regarding receiving electronic commercial messages and cookies.

PRINCIPLES IN DATA PROCESSING

We act in accordance with the following principles when processing your personal data:

In compliance with the law and principles of honesty,
Processing data for specific, clear and legitimate purposes,
Processing only relevant data that is limited and proportionate to the purpose for which it is processed,
Storing the data for the period prescribed by the relevant legislation or for the time necessary for the purpose for which it is processed.

INFORMATION WE MAY COLLECT

We collect and process the following information which may include your personal data:

Information provided when you register with our Services (“Signup Information”)

Required & Generated Information:

Username & URL
Nickname
Email;
Password;
First Name; and
Last Name.
Approval of Binding Terms and Conditions and Privacy Policy (I have read, understood and I approve! (Button))
Permission for communication, advertising and marketing messages to be sent via email via ready2.gg. (I allow messages (Button)).

SSO:

Discord
Twitch
Google
Facebook

Information provided in account and profile settings (“Account Information”)

Settings

Email Confirmation Code
Profile photo
Profile Background
Phone number
Nationality and Language
Date of birth
Social Settings Receive Message & Receive Invite
Notification Settings Allow Tournaments & Allow Updates

Social Media Notification Settings – Allow ready2.gg to collect A, B and C

Instagram
Twitter
Discord
Twitch
Facebook

Game Accounts

Riot Account (League of Legends, Valorant, tracker.gg (Valorant), tracker.gg (League of Legends)=
Steam Account (CS:GO PUBG – Steam Approval, pubglookup.com/)

Information collected from the signed up users of the Platform:

Hardware: screen, mouse, keyboard and other hardware information
Software: operating system, browser
Location: IP, country, city, GPS coordinate
Activity and Preferences: game stats, all time stats, friends, tournament history, teams, hubs
Chat History: parties and games informed

In game statistics collected from game producers through the user's linked game ("In Game Data"). Sample In Game Data collected for Valorant game is as follows:

In Game level ("Rank")

Current Level
Past Level

In Game killing and dying ("Frag")

Number of Kills
Number of Deaths
Number of Assists
Total Damage (dmg)
Score (in points)
First Damage
First Kill
Zero Death Completion
Five Kills in a Row

Accuracy

Headshot Accuracy
Bodyshot Accuracy
Legshot Accuracy

Behaviours

Most favorite maps
Most favorite weapons
Most favorite characters

History

Number of matches played
Number of matches won
Number of matches lost
Number of rounds played
Number of rounds won
Number of rounds lost
Number of times "1st 2nd 3rd "
Number of times playing "A" character ( Win rate with "A" character and variations)
Number of times playing "B" map (Number of times won on "B" map and variations)
Number of times picking "C" weapon (Number of kills with "C" weapon and variations)
Number of times using "D" ability (Amount of damage dealt with "D" ability and variations)
Information for each input displayed at the top of the game "X" (date, time, and duration of "X" game, Teammates and Rivals in "X" game, information for each input above

Encounter

In-game lobby code, if any
In-game nicknames of teammates and opponents
Game result
Game stats displayed on screen for "X" game
End of game result screen image
In-game pause duration
In-game chat messages

Additional information obtained from the users in order to give the reward to the users who earn platform currency or real money at certain points on the platform ("Transactional Information")

Payment Info

Credit card 16-digit number
Credit card expiration date
Credit card CVC

Billing Info

Bank Account IBAN
Bank Account Number
Bank Account Branch Name/Number
Bank Account Owner
Company Information

Sensitive Info

Turkish ID number / citizen ID number
Gmail, Meta or Twitter SSO

Guardian Info

Name, Surname
Relationship
National ID number
Email
Phone number
Bank account information

Information obtained by our third party anti-cheat service provider’s (Anybrain.gg SDK) software kit integrated into the Platform used by Users. It consists of a software library downloaded from the customer's computer terminals in order to be implemented in an application or software in order to allow to monitor users, namely the use of keyboards and mouse and all interactions with the computer during the usage of the Platform.

WHY DO WE COLLECT YOUR INFORMATION

Depending on which Services you use, we may collect your personal information for legal purposes such as:

Providing you with our Services, including recording the outcome of competitions, your ranking, and performance, so that you have the best experience possible.
Improving our Services and user experience, by analyzing and processing your information.
Responding to your enquiries and support requests, and enabling you to use the Chats and Ticket System, as outlined in the terms of use agreed between us.
Serving you with more relevant ads, marketing, and promotions using Google Ads Manager.
Acquiring new users and engaging current users by processing Mailing List Information, to provide suggestions and recommendations about competitions and services that may interest you, and to notify you about changes to our Services.
Responding to information requests from administrative and judicial authorities, and complying with legal processes and regulations.
Processing payments, in accordance with the terms of the contract entered with you.
Preventing cheating, fraud, and illegal activity, including the processing of personal data and AntiCheat Logs, to enforce our legal rights, comply with our legal obligations, and ensure that any use of our Online Services is lawful and non-fraudulent, and does not disrupt the operation of our services or harass our staff or other individuals.

COOKIES

Cookies are small text files that are placed on your device when you use our Services. We use cookies and other tracking technologies, such as web beacons and flash object storage, to enhance, improve, and monitor our Platform. The following types of cookies are used:

Required cookies are essential for the website to function and cannot be disabled in our systems. These cookies are usually activated when you request for our services, such as logging in, filling in forms, and setting your privacy preferences. You can set your browser to block or alert you about these cookies, but some parts of the site may not work correctly. Required cookies do not store any personally identifiable information.

Performance cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. These cookies help us understand which pages are popular and which are not, and how users navigate our site. The information collected by these cookies is anonymous, and we cannot identify individual users. If you do not allow these cookies, we will not be able to monitor our site's performance.

Functional cookies enable our website to provide enhanced functionality and personalization. These cookies may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies, some or all of these services may not function correctly.

Targeting cookies may be set by our advertising partners to create a profile of your interests and display personalized advertisements on other sites. These cookies do not store personal information but identify your browser and internet device uniquely. We may use this type of cookies by getting your explicit consent. If you do not allow these cookies, you will experience less personalized advertising.

We may store or access cookies, device identifiers, or other information on your device for the purposes presented to you.

We may use market research to gain insights into our audience's preferences and behaviors.

We may combine offline data sources with your online activity to support one or more purposes.

Ads may be shown to you based on the content you are viewing, the app you are using, your approximate location, or your device type. We may create a profile about you and your interests to display personalized ads that are relevant to you. The performance and effectiveness of ads that you interact with can be measured, and your device can send and receive information to display ads and content.

We may create a profile about you and your interests to show you personalized content that is relevant to you. The performance and effectiveness of content that you interact with can be measured.

During the use of these cookies, our data processing activities are based on "your explicit consent" as a data processing condition within the scope of Article 5 of the Law.

TECHNICAL AND ADMINISTRATIVE MEASURES TO PROTECT YOUR PERSONAL DATA

We undertake to take all necessary technical and administrative measures and exercise due diligence to ensure the security of your personal data. For this purpose, we take necessary precautions to prevent unauthorized access, misuse, unlawful processing, disclosure, alteration, or destruction of personal data. When processing personal data, we follow generally accepted security technology standards such as firewalls and encryption.

To prevent unlawful access to the processed personal data, prevent unlawful processing of such data, and ensure the preservation of personal data, we take the following steps: (i) we secure all areas of the website where personal data is collected with SSL, (ii) we establish and implement access authorization and control matrices for our employees, (iii) we ensure that personal data in paper format is kept in locked cabinets and accessed only by authorized personnel, (iv) we delete or anonymize personal data processed through cookies belonging to third parties when the membership is terminated.

In the event of personal data being compromised or accessed by unauthorized third parties due to attacks on our platforms or systems, despite taking appropriate information security measures, we shall promptly inform affected parties and the Personal Data Protection Board and implement necessary measures.

OPTOUT OPTIONS

If you do not wish to receive promotional or other marketing material from us or third parties, you can opt out by clicking 'unsubscribe' in any of our communications or by changing your account settings in the Services at any time.

DURATION OF STORAGE OF PERSONAL DATA

We store personal data processed through its website and platform for the periods required by the relevant laws prescribed by Article 7 and 17 of the Law and Turkish Penal Code Article 138, and/or for the periods required by the processing purpose (i.e. as long as you have an active user account.).

TRANSFER OF PERSONAL DATA

Your personal data may be transferred to various third parties for the purposes specified in the above statement, subject to the provisions of Articles 8 and 9 of the Law. These transfers include:

Service companies, such as cloud computing providers, hosting service providers, and data security, backup, anti-cheat service providers and access control systems providers, as required for the processing of data for our legitimate interests, provided that they do not harm your fundamental rights and freedoms, in accordance with the mandatory legitimate interests of the data controller under Article 5/2-f of the Law, subject to not causing harm to your fundamental rights and freedoms;
Our lawyers, advisors, and administrative or judicial authorities, based on the legal grounds that data processing is mandatory for the establishment, use, or protection of our rights, within the scope of the condition that data processing is mandatory for the establishment, use or protection of a right under Article 5/2-e of the Law;
Authorized public institutions and organizations, and private individuals, if it is mandatory for us to fulfill our legal obligations, within the scope of the condition that it is mandatory for the data controller to fulfill his/her legal obligations under Article 5/2-c of the Law;
Press, social media, advertising and PR companies for our promotional activities, with your explicit consent obtained separately, as the servers of the relevant social media companies may be located abroad.
Your personal data may be shared with information technology companies, data hosting service providers we receive services from, whose servers are located abroad, and with our company's affiliated companies, for the purposes of carrying out our business activities, fulfilling operational procedures, providing management reporting activities and technical infrastructure purposes, provided that your data security is ensured, and the necessary measures are taken by our company. Your personal data may also be shared with our anti-cheat service provider. By accepting this Privacy Policy, you give your explicit consent for us to process your personal data for the reasons stated herein, including the transfer of your personal data to companies listed in this clause.
In addition, we use Google Analytics at the Platform, a commonly used tool provided by Google Inc., to analyze visitors' use of websites. This is necessary for us to provide Services to you. Google Analytics uses cookies to generate information that will be processed and stored by Google on servers in the United States, including your IP address, to evaluate the use of the platform and provide internet services related to the platform. By accepting this Privacy Policy, you give your explicit consent for us to process your personal data for the reasons stated herein, including the transfer of your personal data to Google's servers in the United States.

YOUR RIGHTS

You have the following rights with respect to your personal data processed by us, as per Article 11 of the Law:

To learn whether personal data is being processed or not,
To request information if personal data have been processed,
To learn the purpose of processing personal data and whether they are being used in accordance with this purpose,
To know the third parties to whom personal data are transferred within or outside the country,
To request correction of personal data in case they are processed incompletely or inaccurately,
To request deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the Law,
To request that the operations carried out under subparagraphs (d) and (e) be notified to the third parties to whom the personal data are transferred,
To object to the occurrence of a result against the person by exclusively analyzing the processed data through automatic systems,
To demand compensation in case of suffering damage due to the unlawful processing of personal data.

In order to exercise your rights regarding your personal data, you can apply and exercise your rights through the "Ticket System" arranged in accordance with Article 13 of the Law on the Platform. Requests you make to exercise your rights regarding your personal data will be concluded and notified to you within a maximum of thirty (30) days.

As the Data Subject, you are responsible for ensuring that your personal data within the scope of this Policy is complete, accurate, and up-to-date, and for updating it in case of any changes. Otherwise, the Company will not be liable for any responsibility.

OUR CONTACT INFORMATION

If you have any questions regarding this Privacy Policy or wish to exercise any of your rights, you can contact us through Ticket System on the Platform or at:

Data Controller:

ESA Bilişim Elektronik Spor Anonim Şirketi

Address: Maslak Mahallesi Ahi Evren Caddesi 42 Maslak Sitesi No:6/70 Sarıyer Istanbul Turkey

Istanbul Trade Registry No: 130499-0

Tel: +90 850 217 10 80

Fax: +90 212 401 09 93

Email: [email protected]

Website: https://ready2.gg

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