LAST REVISED: OCTOBER 3, 2018
Enthusiast Gaming Inc. (“us”, “our” and “we”) thanks you for your interest in our website, www.enthusiastgaming.com and the activities, products, services and content that we may offer from time to time (collectively, the “Services”).
We value the privacy of those who visit and/or use the Services (individually, “you” or collectively, “Users”). We take your privacy seriously and make it a priority to protect personal information that we obtain from and about our Users.
- what personal information we gather from you;
- how and why we use your personal information;
- to whom your personal information may be disclosed;
- how we protect your personal information;
- updating, accessing, deleting and retaining your personal information, and
- providing or withdrawing your consent to our collection, use or disclosure of your personal information.
1. WHAT PERSONAL INFORMATION WE COLLECT
- Session cookies: Session cookies store information only for the length of time that you are connected to a website – they are not written onto your hard drive. Once you leave the website, they expire and are no longer active. We use session cookies to record certain information from your browser including your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, operating system and the dates and times that you use our website. Additionally, we may record certain information regarding your browsing of our website. Session cookies allow us to gather statistical data which provides insight into how we may improve our Services and to identify your current session to our web server.
- Persistent cookies: Persistent cookies store information on your hard drive and can be re-read when you return to the site that placed them on your hard drive. We use persistent cookies to remember your preferences and to help block unauthorized attempts to access your Personal Information.
- Location information. We may collect and store information about your location if you enable your computer or mobile device to send us location information. You may be able to change the settings on your computer or mobile device to prevent it from providing us with such information.
c. Third-Party Web Beacons. We may also implement third-party content on our website that uses “clear gifs”, “web beacons” or other similar techniques, which allow third-party content providers to read and write cookies to your browser, or implement similar tracking mechanisms, in connection with your viewing of that third-party content displayed on our website. This information is collected directly by the third-party, and we do not participate in that data transmission. Information collected by third parties in this manner is subject to that third-party’s own data collection, use, and disclosure policies.
d. Your relationship with us. We will collect information arising from your relationship with and through us and your use of the Services. For example, we maintain a record of your name and email address and when you send us an e-mail, speak with one of our telephone service representatives, or communicate with us through any other means, we may monitor, record and retain those communications for our mutual protection and in order to process your inquiries, respond to your requests and improve our Services.
2. HOW AND WHY YOUR PERSONAL INFORMATION IS USED
a. To Serve you. We use the Personal Information that you provide or that we collect for legal and regulatory purposes, to manage business risks, to provide our Services to you and to establish and enhance our relationship with you. We generally use the Personal Information you provide or that we collect to operate, maintain, enhance, and provide our Services. For example, we may use your Personal Information to: respond to specific requests from you; to help us better understand your use of the Services; and to administer the Services and protect the security of the Services when necessary. The Services may allow you to submit feedback. Should you choose to submit feedback, you consent to us contacting you by way of follow-up e-mail or phone call to discuss your feedback.
b. Aggregate Information. We may generate non-identifying and aggregate profiles from the information you provide during registration for our Services and through your use of our Services. Non-identifying and aggregate profiles are used to improve the quality of our Services and to develop new Services. Aggregated non-personally identifying information may be shared with third parties.
c. Marketing and Experience. We may use your Personal Information to provide you with information about our features, services and other offerings that may be of interest to you and facilitate your participation in sweepstakes or contests and to fulfill prizes. This information may be provided to you by mail or phone and/or, with your prior consent, by email. We may also send information or offers to groups of Users on behalf of other businesses. We may share your Personal Information with certain other websites that we link to, to the extent that you click on such links, in order to enhance your experience in connection with our website.
3. TO WHOM YOUR PERSONAL INFORMATION MAY BE DISCLOSED
a. Our subsidiaries or affiliates. We may share your Personal Information with our subsidiaries or affiliates (the “Group”) for: fraud or crime prevention, suppression or detection; for legal and regulatory purposes and to meet regulatory, legal or reporting requirements; to manage business risks; to perform analytics; to ensure that we have correct and up to date information about you; and to the extent necessary if you have requested a Service that is jointly offered by more than one member of the Group. We may also share your Personal Information to better manage your total relationship with the Group and enable other members of the Group to bring suitable Services to your attention. We may share your Personal Information within the Group for these purposes unless prohibited by law or you tell us not to.
b. Suppliers. We may use other companies, to provide certain Services on our behalf. We may share your Personal Information with our suppliers, agents and other organizations that perform Services for us or on our behalf to the extent necessary to provide and administer the Services that you have requested from us. These companies will only be given the information needed to perform those Services. Our suppliers may perform activities outside of your jurisdiction. As a result, your Personal Information may be used, stored or accessed in other countries and may be subject to the laws of those jurisdictions. These companies may be required to disclose your Personal Information in response to valid demands or requests from governments, regulators, courts and law enforcement authorities in those jurisdictions or countries.
c. Merger or sale. In the event that we are acquired by or merged with a third-party entity, or if we sell a part of our business, we reserve the right to transfer or assign the Personal Information that we have collected from you as part of such merger, sale or other change of control and you hereby consent to the transfer or assignment of such Personal Information.
d. Where required by law. We may disclose your Personal Information if we have a good faith belief that access, use, preservation or disclosure of such Personal Information is reasonably necessary to satisfy any applicable law, regulation, self-regulation, legal process or enforceable governmental request. When we provide Personal Information in response to a legal inquiry or order that we believe to be valid, we disclose only the Personal Information that is legally required. Note that we may store or process your Personal Information outside of your jurisdiction which physical storage of your Personal Information may span multiple jurisdictions or countries and we may disclose your Personal Information in response to valid demands or requests from governments, regulators, courts or law enforcement authorities in those jurisdictions or countries.
e. Protection of our interests. We may also disclose your Personal Information if we believe, in good faith, that it is appropriate or necessary to take precautions against liability; to help us collect a debt or enforce an obligation owed to us by you; to protect against fraudulent, abusive, or unlawful uses; to investigate and defend ourselves against any third-party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of our Services; or to protect the rights, property, or personal safety of our Users, employees or others.
f. Consent. We may disclose your Personal Information where you have authorized us to do so. For example, if you have given us consent, we may share your Personal Information with business partners and other entities that are not affiliated with us who would like to send you information about their products and services. We do not share Personal Information with other third-party organizations for their marketing or promotional use without your consent or except as part of a specific program or feature for which you will have the ability to opt-in.
4. HOW WE PROTECT YOUR PERSONAL INFORMATION
a. Security processes. We make commercially reasonable efforts to safeguard your Personal Information from loss or theft, unauthorized access, disclosure, duplication, use or modification through security measures appropriate to the sensitivity of the information. These measures include internal reviews of our data collection, storage and processing practices and security measures which include appropriate encryption and physical security measures to guard against unauthorized access to systems where we store Personal Information.
5. UPDATING, ACCESSING, DELETING AND RETAINING YOUR PERSONAL INFORMATION
a. Accessing and deleting your Personal Information. We make good faith efforts to provide you with access to your Personal Information and to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual Users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. We will advise you of any applicable fee prior to proceeding with your request. Upon your request, we will make reasonable efforts to delete your Personal Information from our database, however, it may be impossible to delete your information without retaining some residual information for a period of time due to backups and records of deletion.
b. Retention of your Personal Information. We retain your Personal Information only as long as it is required for the reason(s) that it was collected. This length of time will vary depending on the Service and the nature of the information and may extend beyond the end of your relationship with us.
6. PROVIDING OR WITHDRAWING YOUR CONSENT
You may withdraw your consent provided that: you provide reasonable notice; we are not legally required to collect, use or disclose your Personal Information; and withdrawing your consent does not impede our ability to fulfill our obligations to you. You may withdraw your consent by contacting Jason Lepine, Manager, Operations at Jason@enthusiastgaming.com or by calling us at 416.623.9360. Our staff will be pleased to explain your options and any consequences of refusing or withdrawing your consent, and record your choices.
Several of the privacy preferences available to you, subject to legal, business or contractual requirements, are outlined below.
a. Direct marketing. The Services may provide an option for you to consent to receive information that may be of interest to you such us our newsletters and updates on our new services through various channels including direct mail, telephone, electronic or other means. You may opt-out of receiving such communications from us at any time by clicking on the “unsubscribe” link in any such electronic messages or by contacting Jason Lepine, Manager, Operations at Jason@enthusiastgaming.com or by calling us at 416.623.9360. We will honor your opt-out instructions within 10 business days after we are informed of your request without any further action being required by you.
b. Sharing with our subsidiaries, affiliates or Suppliers. We may share your Personal Information with the Group or our suppliers, agents and other organizations that perform Services for us or on our behalf for the reasons outlined in paragraphs 3(a) and 3(b) above. If you withdraw your consent for this sharing, we may not be able to provide you with your requested Service.
8. THIRD-PARTY SITES
9. INTERNATIONAL USERS
Please note that we may store or process your Personal Information outside of your jurisdiction. The physical storage of your Personal Information may span multiple jurisdictions or countries and the governments, regulators, courts or law enforcement authorities in those jurisdictions or countries may be able to obtain disclosure of your information through applicable laws. Your use of the Services or your submission of any Personal Information to us will constitute your consent to the transfer of your Personal Information outside of your jurisdiction, which may provide for different data protection rules than those in your own jurisdiction.
10. OUR COMMITMENT TO CHILDREN’S PRIVACY
Protecting the privacy of young children is especially important to us. We do not knowingly collect any Personal Information of minors. If you are an individual, by accessing or using the Services you represent and warrant that you are of legal age to form a binding contract. If we learn that Personal Information of a minor has been inadvertently collected without parental or guardian consent, we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that a minor for which you are responsible has provided his or her Personal Information to us without your consent, then you may alert us by contacting Jason Lepine, Manager, Operations at Jason@enthusiastgaming.com or by calling us at 416.623.9360 and request that we delete such minor person’s Personal Information from our systems.
11. COMPLAINTS AND QUESTIONS