OUR PRIVACY POLICY - Division 6ix

YOUR DATA

PRIVACY POLICY - Division 6ix www.division6ix.gg Effective date: 8th June 2021

1. INTRODUCTION 

At Division 6ix, we are committed to protecting your privacy. We will only use the information that we collect about you in accordance with all applicable data protection and privacy legislation, regulations and guidance.

In this privacy notice we explain how we collect and processes your personal data including when you buy tickets for and attend our events and submit forms via our websites. We also explain your data privacy rights and how the law protects you. It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing your personal data. This privacy policy is in addition to the other notices and is not intended to override them.

Our Websites and any of our online services are not intended for children and we would not knowingly collect data relating to children without parental consent.

2. ABOUT US

Division 6ix is the controller responsible for your personal data (collectively referred to as the “Company”, “we”, “us” or “our” in this privacy policy).

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions, including any requests to exercise your legal rights, please contact the DPO using the details set out below:

Email: info@division6ix.co.uk

Postal address: 25 Cabot Square, Canary Wharf, London, E14 4QA

Telephone number: +44 020 4511 8188

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

3. CHANGES 

This policy was last updated on the date shown at the top of the document. We reserve the right to make further changes to this policy from time to time. We will always notify you in advance of any changes that involve a new use of your data that may not be compatible with the purpose for which we originally collected them. See Change of Purpose for more details.

It is important that the personal data we hold about you is accurate and current so please keep us informed if your personal data changes during your relationship with us.

4. THIRD-PARTY LINKS

Our Website www.division6ix.gg and other Sites we may operate from time to time may include links to third-party websites, plug-ins and applications (”Our Websites”). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave Our Websites, we encourage you to read the privacy notice of every website you visit.

5. THE TYPE OF DATA WE COLLECT ABOUT YOU

We may collect, use, store and transfer different kinds of personal data about you which we have together follows:

  • Information provided by you. Information provided by you when you create or update your account(s); when you are an esports player; while you use our social features and channels to communicate with others; when you use any of our services for purchases or financial transactions such as store purchases, in-game purchases, and/or prize processing; and while you are receiving customer service support.
  • Information we get or generate from your use of our games or services. We collect data related to: your game play and in-game activity, the services that you use and how you use them, and your devices and activities when you install or access our services.
  • Information collected from external sources. We may receive information about you and your activities from third parties when you link to external accounts (such as Facebook, PlayStation, XBOX or Twitch) and from advertisers or service providers about your experiences or interactions with them. We might also obtain information from public sites on the internet, such as Twitch, Instagram and YouTube, to mention a few. For example, if you login to a site or app using Facebook Connect you may be asked if you wish to share information from your Facebook account with us. If you participate in a game or other feature where your score is posted on social media content, or if you use a “like” or a “share” button for a feature on our sites or apps, then the third party may share information with us.
  • We treat all information associated with your account as personal information. Division 6ix collects the following categories of data depending on which product(s) or service(s) you are interested in or interacting with. We usually retain data for only as long as necessary to provide you with products, services and an immersive entertainment experience.

 

Identity Data 

We collect your name and title, and age, gender (if you supply this information) when you buy a ticket for one of our events via our third-party ticketing agencies. We may capture photos and video images when you attend our events for marketing purposes. You may be asked to provide proof of identity (passport or driving licence) in order to access certain areas within our events such as Bring Your Own Computer, or if you try to purchase alcohol but we do not store copies of this data. We may ask you to submit a photo or video of yourself when you submit an event volunteer application form via one of our websites.

Contact Data

When you buy tickets for our events we receive your address, email and telephone number so we can send you service communications about the event in question.

Financial Data 

Your payment card data is processed by third party ticketing agencies

Transaction Data 

Details about tickets you have purchased from us.

Technical Data 

Internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, device ID, operating system and platform and other technology on the devices the data subject uses to access Our Websites.

Sensitive Data

We may require you to disclose any criminal convictions, in accordance with the law, if you apply to volunteer at one of our events and are likely to be working closely with children. We may also collect data about any health needs or disabilities that we should be aware of when you complete a volunteer application form.

Profile Data 

Includes your interests, preferences, feedback and survey responses, your experience if you are applying to volunteer at our events.

Usage Data 

Information about your use of Our Websites and attendance at our events.

Marketing and Communications Data 

Includes your acceptance or otherwise in receiving marketing communications from us and your communication preferences.

We also collect, use and share anonymised and aggregated data for statistical analysis purposes. For example, we may anonymise and aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

We do not require you to disclose any Sensitive Data to us other than when you apply for a volunteering opportunity at one of our events and this information is necessary to assess your capacity to work and to ensure your health, safety and well-being. We may ask you to disclose any criminal convictions or to undergo a criminal record check, in accordance with the law, if you are likely to be working closely with children.

Device Data

We may collect information about the devices used to access our services.

Examples: Hardware models, operating systems and versions, unique device identifiers.

Who has access to this type of data? Operations, Game Teams and Security.

Game Data

Game data are generated while a player plays our games. We keep records of players’ game licenses, progress, history, stats, in-game purchases and interactions with other players.

ESPORTS PLAYER RECORDS/TOURNAMENT DATA

We gather information related to personal details, rankings, performance stats and team details to follow up on the career and performance of our competitors. We also collect information related to Tournaments that we keep for up to 2 years for administrative purposes.

Examples: Contact method, legal guardian details, experience, rate history, rankings, performance stats, team details and player handle, tournament details.

Who has access to this type of data? Esports and Operations.

6. IF YOU DO NOT PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to sell you tickets for an event). In this case, we may have to cancel your order but we will notify you if this is the case at the time.

7. WHO DO WE SHARE YOUR DATA WITH?

We routinely share personal information with:

  • Companies within our group;
  • Third parties we use to help deliver our products and services to you;
  • Other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
  • Third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information.

We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.

8. OUR PURPOSES AND LAWFUL BASES FOR PROCESSING YOUR DATA

We will only use your personal data when the law allows us to. Most commonly, we rely on the following lawful bases when processing your data. You can expand each section below to find out more about the purposes for which we rely on each of these bases.

  • Where it is necessary for the performance of a contract we are about to enter into- or have entered into with you.
  • To administer ticket sales for events where DIVISION 6IX
  • To enable you to take part in a competition.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • We collect your marketing and communication preferences when you buy tickets via our third-party ticketing agencies. We conduct marketing activities to promote our events and drive ticket sales;
  • To process parental consent forms for a child or young person under the age of 18 to attend our Bring Your Own Computer (BYOC) zone. This is so we can ensure the safety and security of young people attending our events;
  • To sign you up for our mailing list so we can keep you informed about future events from DIVISION 6IX;
  • To process your registration for a volunteering opportunity at one of our events;
  • To process your registration to join our “Insomniac” promoter network, to help us market and sell tickets to our events;
  • To handle your enquiry, compliment or complaint so that we can understand your feedback and experiences and improve the quality of our service;
  • To ask you to leave a survey so that we can identify ways to improve our service;
  • To administer and protect our business and Our Websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
  • We use data analytics to improve Our Website, services, marketing, customer relationships and experiences;
  • For insight and analysis that we use to tailor our marketing messages to you;
  • For data mining and analysis to understand business performance and for the prevention and detection of crime and fraud;
  • For audit and compliance purposes.
  • Where we need to comply with a legal or regulatory obligation.

In a limited number of scenarios and where required by law, we rely on consent as a legal basis for processing your personal data:

  • We may place cookies on your personal device designed to capture Technical Data about the type of device and browser you’re using, your browsing actions and patterns;
  • When we send direct marketing by email or text message and the law requires your consent;
  • To take photo and video images of you at our events for advertising and marketing purposes.

In relation to the Sensitive Data we may collect about you, we rely on the additional lawful basis for processing your data;

The processing is necessary for the purposes of carrying out obligations and exercising specific rights in the field of employment;

The processing is necessary for the assessment of the working capacity of the employee.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We hope that you will be happy for us to send you news and promotional offers but you are free to change your mind at any time. We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. You may receive marketing communications from us if you have given us your contact details when buying a ticket to our events and have not opted out. If you sign up to our mailing list, we will ask for your consent to receive marketing from us.

THIRD-PARTY MARKETING

We may share your data from time to time with carefully selected third parties where it is in our legitimate interest and theirs to do so. However, these third parties will have no right to send your direct marketing communications by email or text message without your consent.

OPTING OUT

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting info@division6ix.co.uk at any time.

OTHER DISCLOSURES OF YOUR PERSONAL DATA

We may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

COOKIES

Cookies are small files that are stored on a user’s device. They are designed to contain a limited amount of data specific to a particular user and website and can be called up either from the web server or the client device. This allows the server to deliver a page which is tailored to a specific user, or the website itself may contain a script that understands the information in the cookie and is thus able to transfer information from one visit to the website (or a related website) to the next.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of Our Websites may become inaccessible or not function properly. 

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the DPO.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

INTERNATIONAL TRANSFERS

From time to time we may use data processors who process your personal data outside of the European Economic Area (EEA). In these cases, we will always ensure a similar degree of protection is afforded to your data by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact the DPO if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

PROTECTING YOUR DATA

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. If you are concerned about a potential breach of your data, please contact the DPO.

 DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:

  • Request access to your personal data (commonly known as a “data subject access request”).
  • This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of your personal data
  • This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data

This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data

Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data

This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Withdraw consent at any time

Where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Object to automated decision-making or profiling

You can ask us not to subject you to automated decision-making or profiling with legal or similar significant effects.

If you wish to exercise any of the rights above, please contact the Data Protection Officer (see About Us for contact details).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We will to respond to all legitimate requests within one month unless your request is particularly complex or you have made a number of requests. In this case, it may take us longer to respond but we will notify you and keep you updated.

LEGAL BASIS

The data processing for the purpose of providing giveaway and contest functionalities is based on your consent, which you gave when you signed up for the newsletter on the Website. Pursuant to Art. 6 para. 1 lit. a GDPR, data processing is permitted if you have given your consent for data processing for one or more specific purposes. Within the scope of the sign up you have given a declaration of consent with which you have agreed to evaluation of your use of the giveaway and contest functionalities. A revocation is possible at any time through getting in contact with us in the way provided above.

PRIVACY POLICY COMPLAINTS AND ENQUIRIES

If you have any queries or complaints about our Privacy Policy please contact us at:

info@division6ix.co.uk

Each EU Member State shall provide one or more independent public authority (ies) to be responsible for monitoring the application of the GDPR in order to protect the fundamental rights and freedoms of natural persons in relation to processing and to facilitate the free flow of personal data within the Union (‘supervisory authority’). If you feel that Division 6ix has violated your rights, or if you wish to raise a concern with the data protection authorities, please contact the supervisory authority in the country where you live, work, or where you believe a breach of data protection law has occurred.