1. Scope
This privacy policy («Policy») explains how we process the personal data of customers, contest participants, visitors to our websites («Sites») and users of our services («Services») as data controllers, in accordance with applicable privacy laws.
When we collect personal data as data processors, that is, on behalf of our business customers, we process such data in accordance with the terms of our contract with them. In these cases, that customer's privacy policy will apply.
Game On acts solely as a provider of technology solutions. Promotions, contests, sweepstakes and other activities are organized, administered and run by its clients (brands and agencies), who act as data controllers and assume, on a sole and exclusive basis, responsibility for their legality, their terms and conditions, the awarding and delivery of prizes, the age and eligibility requirements of participants, and compliance with the regulations applicable in each jurisdiction. Accordingly, Game On is released from any liability, whether direct or indirect, arising from the content, administration, execution or outcomes of such activities, which rests exclusively with the organizing client. Game On shall be liable solely for the provision of its technology services, in accordance with the contractual terms agreed with each client.
We will provide additional notices when necessary to clarify our privacy practices in specific circumstances, such as in the context of contests and promotions, where your data may be used to manage your participation and related contact.
2. Personal data we collect
Data we collect directly from you
- Customer care and technical support: name, country, email, company, role, industry and the nature of your request.
- Communications: contact information and records of our communications.
- Transactions and billing: data when you purchase products or services.
- Surveys: responses and contact information.
- Events: data related to your registration and participation.
- Sweepstakes and promotions: name, age, country, email and other registration data.
- Other information: based on your consent or reasonable circumstances.
Data collected by third parties
Sources: public databases, advisors, internet service providers, social networks, business partners, among others.
Data collected automatically
- Device and browsing information: IP, browser, operating system, language, URL, etc.
- Activity and usage: links, features used, interactions, log files, etc.
- Location information: derived from the IP or other sources.
For more information, see section 7: Cookies and other tracking mechanisms.
3. How we use personal data
In general, we use personal data for the following purposes:
- Customer care and technical support: to provide our Services and operate the Site, share useful information about your usage, troubleshoot issues, answer inquiries and fulfill your orders and requests.
- Communications: to answer your questions, send communications you have requested or that may interest you, and notify you of changes to our Services.
- Analytics and improvements: to understand how the Site and Services are used in order to evaluate and improve them, develop new functionality, and for internal quality control and training.
- Personalization: to tailor the content we present, offer location-based personalization and personalized help.
- Marketing and advertising: to send you offers, promotions and newsletters you agree to receive, and to manage, measure and improve our campaigns.
- Events: planning, registration, attendance and contact with other attendees.
- Research and surveys: to run surveys and questionnaires for market research or customer satisfaction.
- Sweepstakes, contests and promotions: to facilitate your participation and communicate with you about it.
- Security and protection of rights: to protect the Site and our operations, and to prevent and detect fraud, unauthorized access and other misuse.
- Legal actions and obligations: to comply with the law and respond in the context of legal processes.
- Administration and operations: accounting, auditing, compliance and record-keeping tasks.
4. Disclosure of personal data
In general, we disclose and allow third parties to access personal data in the following ways:
- Corporate affiliates: as part of our global business operations, respecting this Policy.
- Processors and service providers: to providers that deliver services on our behalf.
- Third parties, platforms and services: to external platforms and providers we use.
- Marketing and advertising networks: advertising networks, search engines and social platforms.
- External analytics providers: analytics companies engaged to improve our services.
- Compliance and legal requirements: in response to legal obligations or legal actions.
- Corporate transactions: in connection with mergers, acquisitions or similar transactions.
- Business partners: partners who co-organize events with Game On.
- Other cases: for other purposes, notifying you and requesting consent where applicable.
- Aggregated or anonymized data: for analysis and improvement purposes.
5. International data transfers
Your personal data may be processed inside and outside the European Economic Area (EEA), respecting confidentiality and data protection regulations. It will not be shared with unauthorized entities.
Some providers are located outside the EEA or share data with entities outside the EEA for service efficiency.
Transfers are carried out in accordance with Regulation (EU) 2016/679 and other applicable regulations, including appropriate safeguards.
6. Legal bases
We are entitled to use your personal data based on:
- Legitimate interest: for example, research and development, promotion of services and protection of our rights.
- Your consent: when required for a specific purpose.
- Legal obligation: when necessary to comply with applicable laws.
8. Security
We cannot guarantee total security on the Internet. We take reasonable measures to protect your data; even so, you use the Site at your own risk.
9. How long we retain your personal data
We retain your personal data until it is no longer necessary for the stated purposes. We may also retain it to comply with legal obligations or resolve disputes.
10. Rights you can exercise
You can exercise the rights of access, rectification, erasure, portability, restriction of processing and objection. Send an email to [email protected], with a copy of your identification document if necessary.
You may also lodge a complaint with the competent supervisory authority, although we recommend contacting us first.
11. Your privacy preferences
- Marketing communications: you can unsubscribe at any time from the emails you receive.
- Targeted advertising: to opt out of personalized ads visit aboutads.info/choices.
- Cookie settings: you can adjust them from the site footer («Cookie preferences»).
- Browser signals: we honor opt-out signals such as Global Privacy Control (GPC) where required by law.
12. Personal data of minors
Game On promotions, contests and experiences are intended for audiences aged 18 and over. As a general rule, the Site and Services are not designed for minors, and we do not knowingly collect personal data from minors.
The only exception is Game On Kids, our offering specifically for children, which runs in safe, protected environments and respects all applicable rules and regulations for minors in force in each country.
Within Game On Kids we take the necessary measures to comply with the children's data protection regulations applicable in each jurisdiction, such as the Children's Online Privacy Protection Act (COPPA) in the United States, the GDPR's specific provisions for minors and the corresponding age-appropriate design codes (such as the UK Children's Code), the LGPD in Brazil and other local laws in force.
13. External links
Our Sites and Services may contain links to third-party websites or features. This Policy does not govern access to or use of such sites or functionalities, which are subject to the privacy policies of those third parties.
We are not responsible for the information practices of such third parties, including the collection of your personal data. We recommend reviewing the privacy policies and terms of any third-party site before accessing it.
14. Notice at collection and California privacy rights
This section (the «California Privacy Notice») provides additional information for California residents and describes our information-handling practices in compliance with applicable California privacy laws, including the California Consumer Privacy Act and its amendments (the «CCPA»).
In this section, «Personal information» means information that identifies, relates to, describes or could reasonably be linked, directly or indirectly, with a particular California resident or household.
- Information collected: name, email, IP address, general location, browsing history, among others.
- Disclosure to third parties: advertising networks, analytics, social networks, service providers and legal authorities.
- Sale of data: we do not sell sensitive personal information or information of minors under 16.
- Sources: you, social networks, providers, platforms and affiliated entities.
- Retention: only for as long as reasonably necessary to fulfill legal, contractual or administrative purposes.
Rights under the CCPA:
- Right to know: what information we collect and how we use it.
- Right to delete: request that we delete your personal data.
- Right to correct: request the correction of inaccurate data.
- Right to opt out: opt out of the sale or disclosure of your information.
- Right to non-discrimination: you will not be discriminated against for exercising your rights.
To exercise these rights you can call us at +54 9 261 533 5667 or email us at [email protected].
15. Privacy statement for Brazil
Data collected or processed in Brazil, or any information related to individuals or Services located in Brazil, is subject to Brazil's General Data Protection Law (Law No. 13.709/2018, Lei Geral de Proteção de Dados Pessoais or LGPD). All requests regarding data protection in Brazil must be sent to [email protected].
16. Compliance with local regulations and labeling requirements
In developing its technology solutions, Game On provides its clients with the tools and functionalities necessary to adapt promotions, contests, sweepstakes, digital experiences and the distribution of physical prizes to the laws, regulations and case law applicable in each country. However, the determination, adaptation and implementation of the required information —including labels, terms and conditions, legal notices and promotional materials—, as well as the ultimate responsibility for regulatory compliance in each jurisdiction, rest exclusively with the client organizing the activity.
17. Changes to this Policy
If we change or update our Policy, we will post those changes on this page. Your continued use of the Site and Services is subject to the most recent Policy published here. If we make significant changes, we may post a notice on our Site.
18. Limitation of liability
To the maximum extent permitted by applicable law, Game On shall not be liable for any indirect, incidental, special, punitive or consequential damages, nor for loss of profits, data, business opportunities or reputation, arising from the use of or inability to use the Site, the Services or the activities run by its clients, even if Game On had been advised of the possibility of such damages.
The Site and the Services are provided «as is» and «as available», without warranties of any kind beyond those expressly agreed in the contract with each client. Game On does not warrant that the Site or the Services will be error-free or uninterrupted.
Without prejudice to section 1, responsibility for the organization, legality, administration, prize awarding and regulatory compliance of promotions, contests and sweepstakes rests exclusively with the organizing client, who undertakes to hold Game On harmless against any third-party claim, action or demand arising from such activities.
In those jurisdictions that do not allow the exclusion or limitation of certain liabilities, Game On's liability shall be limited to the minimum permitted by applicable law.
19. Contact
If you have any questions or concerns about how we process your personal data or about this Policy, email us at [email protected].
