Privacy Policy

Last Updated: June 20th, 2022

Your privacy is important to START.GG. This Privacy Policy describes practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you visit our website, use any and all services available on or through our website, domains, and applications, or use our other digital properties, communications, or forms that link or refer to this Privacy Policy. These websites, domains, applications, and other entry points to the Privacy Policy may collectively be referred to herein as "our Services" and "the Services". This Privacy Policy applies to all users of our Services, including registered users who are tournament organizers ("Tournament Organizers") and other users ("General Users").

Please read this notice carefully to understand our policies and practices for processing and storing your personal data. This Privacy Policy may change from time to time (see Changes to This Privacy Policy), so please check periodically for updates.

Personal Data We Collect:

We may collect personal data from you, as further described below:

• Registration, Contact, and Event Information. Data you provide to create an account and to set up or attend an event, such as your name, birthdate, country, postal address, email address, telephone number, username, gamertag or other similar identifier, financial transactions, and survey responses.
• User contributions. Data you provide for us to publish or display on the Services, such as screenshots, comments, and other content ("User Contributions").
• Technical Data. Data including the Internet protocol (IP) address used to connect your computer to the Internet, your approximate geographic location, your login information, demographic data, browser type and version, other characteristics of your device and software, domain names of your Internet Service Provider, a record of your usage of the Services, the time of your usage time zone setting, browser plug-in types and versions, or operating system and platform.
• Interaction data. Data about your interactions with the Services, including the full Uniform Resource Locators (URLs), clickstream to, through, and from our Services (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, or any phone number used to call our customer service number.
• Non-personal data. Data that does not directly or indirectly identify you such as statistical or aggregated information. We may derive non-personal statistical or aggregated data from your personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific feature of our Services.

How We Collect Personal Data:

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us data about you by filling in forms or by corresponding with us by phone, e-mail or otherwise. This includes data you provide when you register or create an account, organize or attend an event, participate in a donation drive, purchase or sell tickets or products, participate in discussion boards or other social media functions on our Services, respond to a survey, and when you report a problem with or ask a question about our Services.
• Automated technologies or interactions. As you interact with our Services, we may automatically collect technical data about your equipment, browsing actions and patterns as specified above. We collect this information by using cookies, server logs, and other similar technologies.
• Third parties or publicly available sources. We may receive data about you from third-parties including, for example, business partners, sub-contractors in technical, payment and delivery services, search information providers, data brokers, or aggregators.
• User contributions. You may submit User Contributions for posting and transmission to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of any Services users with whom you choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.
• Tournament Organizers. We receive data that you provide to from Tournament Organizers. You may provide that data directly to the Tournament Organizer or through the Services. Tournament Organizers may establish their own privacy policies and they are not bound to treat your data in accordance with this Privacy Policy. We are not responsible for the actions of Tournament Organizers with respect to data you submit to them.

How We Use Personal Data:

We may use your data as follows:

• Specific reason. If you provide data for a certain reason, we may use your data in connection with the reason for which it was provided or the reason that was stated when it was collected. For instance, if you contact us by e-mail, we will use the data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.
• Access and use. If you provide data in order to obtain access to or use of the Services or any functionality thereof, we will use your data to provide you with access to or use of the Services or functionality, enable your participation in the Services and features, notify you about changes to our Services, and to monitor your use of such Services or functionality. For instance, if you supply data for the purpose of purchasing products associated with an event, we will use that information to facilitate fulfillment of such purchase.
• Internal business purposes. We may use your data for internal business purposes including to help us deliver the Services, improve the content and functionality of the Services, to better understand our users, to protect against, identify or address wrongdoing, to enforce our Terms of Service or other agreements, to comply with applicable laws, to protect the Services and business operations, to manage your account and provide you with customer service, and to generally manage the Services and our business.
• Marketing. We may use your data to contact you in the future for our marketing and advertising purposes, including to inform you about services or events we believe might be of interest to you, and to develop promotional or marketing materials and provide those materials to you, and to display content and advertising on the Services that we believe might relevant to you.
• Tournament Organizers. When a General User registers for or attends an event, we share data about the General User, including email addresses, with the applicable Tournament Organizer.

How We Share Personal Data:

We are not in the business of selling your data. We consider this information to be a vital part of our relationship with you. Therefore, we will not sell your personal data to third parties, including third party advertisers. There are, however, certain circumstances in which we may disclose, transfer or share your data with certain third parties without further notice to you, as set forth below:

• Business transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, your data may be part of the transferred assets. Any successor to or acquirer of START.GG or the assets associated with the Services will continue to have the right to use your data and other information in accordance with the terms of this Privacy Policy.
• Subsidiaries and affiliates. We may also share your data with our subsidiaries and/or affiliates for purposes consistent with this Privacy Policy. Our subsidiaries and affiliates will use that data in accordance with this Privacy Policy.
• Agents, Consultants and Related Third Parties. We, like many businesses, sometimes engage other companies to perform certain business-related functions. Examples of such functions include mailing information, order fulfillment, fraud prevention, maintaining databases and processing payments. When we engage another company to perform such functions, we may provide them with information, including your data, in connection with their performance of such functions.
• Tournament Organizers. When you register for or donate to an event or related fundraising page on the Services, we provide data to the Tournament Organizers of such event or related fundraising page, if applicable. Tournament Organizers may establish their own privacy policies and they are not bound to treat your personal data in accordance with this Privacy Policy. It is important that you review the applicable policies of the Tournament Organizers of an event (and the related fundraising page, if applicable) before providing you data or other information in connection with that event or related fundraising page.
• Third party connections. You can connect your START.GG account to your accounts on third party services like Twitter and Twitch, in which case we will collect, use, disclose, transfer and store data relating to your account with such third-party services in accordance with this Privacy Policy. For example, if you connect your START.GG account with a social media account, we may use your data to do that and to provide certain functionality on the Services, like recommending events that your friends on social media are interested in and sharing the events you are interested in with certain groups of people like your social media friends.
• Legal requirements. We may disclose your data if required to do so by law (including, without limitation responding to a subpoena or request from law enforcement, court or government agency) or in the good faith belief that such action is necessary (i) to comply with a legal obligation, (ii) to protect or defend our rights, interests or property or that of third parties, (iii) to prevent, investigate, or identify possible wrongdoing in connection with the Services, (iv) to act in urgent circumstances to protect the personal safety of users of the Services or the public, or (v) to protect against legal liability.
• For the purpose disclosed: We may disclose your data for the purpose for which you provide it and for the purpose that we disclose in writing when you provide it. For example, if you provide your email address to register for an event, we will share your email address with the event’s Tournament Organizer.
• Permission. Where not otherwise explained in this Privacy Policy, we may disclose your data with your permission.
• Enforce our Rights: We may disclose your personal data to enforce or apply our Terms of Service and other agreements.
• Protect our Business: We may disclose your personal data to protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.

Cookies and similar technologies

Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie. This data often consists of a string of numbers and letters that uniquely identifies your computer, but it can contain other information as well. Some cookies are placed by third parties acting on our behalf. We use cookies and similar technologies to store and honor your preferences and settings, enable you to sign-in, provide interest-based advertising, combat fraud, analyze how our products perform, and fulfill other legitimate purposes described below. START.GG uses additional identifiers for similar purposes, and many of our websites and applications also contain web beacons or other similar technologies, as described below.

• Performance. START.GG uses cookies to understand and improve how our products perform. For example, we use cookies to gather data that helps with load balancing; this helps us keep our websites remain up and running. In addition, we may use cookies to determine where to route your traffic to effectively distribute the Site workload across numerous servers.
• Analytics. We use first- and third-party cookies and other identifiers to gather usage and performance data. For example, we use cookies to count the number of unique visitors to a web page or service and to develop other statistics about the operations of our products. We also use these technologies and allow third parties to monitor our Services and to analyze how you use our Services. For example, we may place cookies that allow us (a) to measure the time of your requests to our servers and our responses; (b) to A/B test new features; (c) to record statistics about site usage; (d) to track your activities on the Services; and (e) to track the places from which you come to the Services. We may also use third party cookies to collect information about visitor behavior on our Services for these Performance/Analytics purposes.
• Storing your preferences and settings. We use these technologies and allow third parties to use these technologies to store your preferences and settings on your device, and to enhance your experiences. For example, to provide a quick link to recently-visited Tournaments in the left side navigation, we store the most recent Tournaments you’ve visited in a cookie. Saving your preferences with cookies, such as your preferred language, prevents you from having to set your preferences repeatedly. Similarly, in scenarios where we obtain your consent to place cookies on your device, we store your choice in a cookie.
• Social media. START.GG uses social media cookies, including those that enable users who are signed in to the social media service to share content via that service.
• Storing information you provide to a website. We use cookies to remember information you shared. When you provide information to START.GG, such as when you add products to a shopping cart on START.GG websites, we store the data in a cookie for the purpose of remembering the information.
• Security. We use cookies to process information that helps us secure our products, as well as detect fraud and abuse.

You can manage cookies through your web browser's option settings and through those settings you may be able (a) to receive notifications when you are receiving new cookies; (b) to disable cookies; or (c) to delete cookies. Please refer to your web browser's help section for information on how to do this.

• Pixel tags (also known as clear GIFs or web beacons). A pixel tag is a tiny invisible tag or graphic placed on certain parts of the Services or other websites, in emails or in certain other downloadable content, but not on your computer, mobile device or browser, except to the extent that you download the content that contains such tags. Pixel tags do not store data on your computer, mobile device or browser (although they are occasionally downloaded to your computer if contained in an email or other downloadable content) so cannot be managed by you except by deleting the content in which the tag is contained.
• Local shared objects (also known as flash cookies). A local shared object is similar to a cookie, except it is stored on your computer or mobile device, instead of your browser, and it can store more than just text. Local shared objects are stored on your computer or mobile device. To learn how to manage privacy and storage settings for local shared objects, click here.

Your Choices:

You have several choices available when it comes to your data:

• Limit the personal data you provide. You can limit the data you provide when using the Services. If you choose not to limit the data you provide, you may not be able to use certain functionality of the Services. For instance, in order to register for an event, your name and email address will be required.
• Communication preferences. You can choose whether you wish to receive promotional communications from START.gg. If you receive promotional email from us and would like to opt out, you can do so by following the directions in that message. You can also make choices about the receipt of promotional email by signing in with your START.GG account, and viewing your Notification Settings where you can manage START.GG-wide contact preferences, and opt out of email subscriptions and newsletters. You may modify your choices at any time. Additionally, you may update your contact information by viewing your Account Settings Page. You can unsubscribe from emails sent by START.GG and Tournament Organizers, but to do so you must unsubscribe separately for START.GG and for Tournament Organizers. You can also unsubscribe from receiving all Tournament Organizer emails sent through our system. You may still receive emails sent by Tournament Organizers through means other than our system. Tournament Organizers who have received your personal data in accordance with this Privacy Policy may still use that personal data to contact you in accordance with their own privacy policies, but they may not use our Services to do so. You may have to unsubscribe from multiple emails before you stop receiving communications associated with the Services. It may take up to 72 hours for us to process an unsubscribe request. Even after you opt out of all promotional communications, we will retain your personal data and non-personal data in accordance with this Privacy Policy, however, we will no longer use it to contact you for promotional purposes. These choices do not apply to mandatory service communications that are part of certain START.gg products, programs, or activities. Note that if you unsubscribe from all emails as described above, you cannot unsubscribe from communications about updates to the Services without contacting us and closing your account.
• Do Not Track. We currently do not participate in any "Do Not Track" frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your data.

Exclusions:

This Privacy Policy does not apply to any data collected by us other than personal data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to us or another user or visitor through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as bulletin boards, any ideas for new products or modifications to existing products, claim or demand letters, Digital Millennium Copyright Act notices, and other unsolicited submissions (collectively, "Unsolicited Information"). All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, distribute and exploit such Unsolicited Information without limitation or attribution.

Children's Privacy:

We do not direct our Services to children and we do not knowingly collect or maintain personal information from children when parental consent is required based on local applicable law. If we learn we have mistakenly or unintentionally collected or received personal data from a child, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us at hello@start.gg.

Links to Other Web Sites:

This Privacy Policy applies only to the Services. The Services may contain links to other websites or services not operated or controlled by us (the "Third Party Sites"). Clicking on those links or enabling those connections may allow the third party to collect or share data about you, and the policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that we endorse or have reviewed the Third Party Sites. We recommend contacting those sites directly to confirm their privacy policies.

Storage and Security:

We may store your data itself or such information may be included in databases owned and maintained by our affiliates, agents or service providers. We take what we believe to be reasonable physical, electronic and administrative steps to protect your data from loss, misuse, unauthorized access, inadvertent disclosure, alteration, and destruction. However, no Internet or e-mail transmission is ever fully secure. Although we do our best to protect your data, we cannot guarantee the security of your data transmitted to or on our Services. Any transmission of data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Services. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Where Information is Processed:

START.GG and its affiliates are based in the United States. No matter where you are located your data will be processed, stored, and transferred in and to the U.S. where our servers are located.

Changes to This Privacy Policy:

This Privacy Policy was last updated on the date indicated above. We reserve the right, in our sole discretion, to update or modify this Privacy Policy at any time. Modifications to this Privacy Policy will be posted to the start.gg website with a change to the "Last Updated" date at the top of this Privacy Policy. Please review this policy periodically, and especially before you provide any personal data. Your continued use of the Services following the effectiveness of any modifications to this Privacy Policy constitutes acceptance of those modifications. If any modification to this Privacy Policy is not acceptable to you, your sole remedy is to cease accessing, browsing and otherwise using the Services.

Access to Information:

Tournament Organizers may access and update their data being stored by us by logging in and visiting their account management page. Tournament Organizers may also contact us directly at the address specified below with respect to data that is not accessible through the Services. General Users who do not have a formal account with START.GG can create an account by signing up. After signing up, you can update and access your data on the My Account page. General Users can also contact us directly with requests to update their data at the address specified below. We will take reasonable steps to respond to requests relating to Personal Data promptly.

Access, Retention and Deletion of Personal Data:

If you would like to access, review or change your data, please send an email to hello@start.gg with the subject line "Access to Personal Data". If you would like to close your account and delete your profile information on www.start.gg you may do so on the Account Settings Page. If you close your account, START.GG may retain other information about you for the activities described in this Privacy Policy, or as permitted or required by applicable law. Also, if you delete your User Contributions from the Services, copies of your User Contributions may remain viewable in cached and archived pages or because other Services users may have copied or stored them. Tournament Organizers agree to comply with any deletion requests from START.GG for data directly or indirectly obtained from START.GG and are solely responsible for ensuring data deletion requests are completed with due diligence and in a timely manner. We generally retain data for so long as it may be relevant to the purposes identified herein. To dispose of data, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time. We may not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or negatively affect the information's accuracy.

Contacting START.GG:

Please also feel free to contact us if you have any questions about this Privacy Policy or our information practices. You may contact us by writing to hello@start.gg.

California Consumer Privacy Act

If you are a California resident, we process your personal data in accordance with the California Consumer Privacy Act (CCPA). This CCPA section of our Privacy Statement contains information required by the CCPA and supplements our Privacy Statement.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

We obtain the categories of personal information listed above from the following categories of sources as described above (see How We Collect Personal Data).

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the purposes described above (see How We Use Personal Data). We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We do not sell personal information.

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, START.GG has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

Your Rights and Choices

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). You also have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We will delete or deidentify personal information not subject to an exception under the CCPA and will direct our service providers to take similar action.

To exercise your rights to know or delete, please submit a request by either:

• Emailing us at hello@start.gg
• Visiting us at www.start.gg

You may only submit a request to know twice within a 12-month period. Your request to know or delete must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. You do not need to create an account with us to submit a request to know or delete. We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email hello@start.gg. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. We will not discriminate against you for exercising any of your CCPA rights.