Last updated: August 1, 2021
1.1 ggCircuit LLC (“ggCircuit,” “us,” “we,” or “our”) operates www.ggCircuit.com, www.ggLeap.com, ggCrypto through ggLeap module, ggLeap@Home, and related software applications and any other features, tools, online and downloadable products, materials, or other services (including co-branded or affiliated services) offered from time to time by ggCircuit or its parent or affiliate companies Genji, Helix esports, EGL and EEG ( together the “Service”), we also recognize that people who use ggCircuit’s Service (“you” or “Users”) value their privacy.
1.4 Any questions, comments or complaints that you might have should be emailed to email@example.com.
2. Information Collection and Use
2.2 We collect this information for the purpose of creating and managing your accounts with us and our commercial partners (if and as applicable to you), our parent and affiliate companies and for identifying and communicating with you, providing the activities and features available on the Service (such as game stats, game sessions, coins, and rewards), and improving the Service. The personal information we collect from you generally may include data:
a) For access to the Service, you must create an account and profile. You will need to provide information, some of which is personally identifiable including name, email address, login username, password, date of birth and other optional information such as game aliases, public profile details, address and phone number.
b) When you use the Service and the activities available through the Service you may be asked to provide additional information as necessary for us to provide the Service.
c) We track game play data and statistics including scores, game stats, game play sessions, coins and rewards, some of which will be publicly available.
d) If you participate in an event managed and administered by a third-party organizer, your personal information will be provided to such organizer only in order to operate the event and publicly report the results. If you don't want your personal information provided to an organizer, then do not participate in such third-party events.
e) We may collect information that our software or your browser sends whenever you use the Service (“Log Data”). This Log Data may include information such as your computer’s IP address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, cookies, hardware you use to access our software or webpages, and other statistics. Log Data does not contain message content and is not routinely deleted.
f) When signing in through the Steam OpenID provider, users will be authenticated using their but not limited to 64-bit SteamID, SSO provider or Facebook. Information available from this SteamID may also be collected, including, but not limited to, user’s purchased games and other behaviors, game lists, lists, playtime, badges, wish lists, achievements, friends, online status and groups.
g) When you opt in to receive the ggCircuit newsletter, you will receive marketing communications and other marketing materials based on user activities in any of our LAN centers. You may unsubscribe at any time by clicking unsubscribe at the bottom of the email or by updating your preferences on your account profile.
2.2 In addition to the above, we may need to verify your identity in order for you to use some aspects of the Service. For purposes of verification, we may also collect the following personal information from you (for regulatory compliance obligations around know your customer and anti-money laundering requirements, provision of this information, when requested, is a mandatory condition of using our Service):
2.2.1 Full name
2.2.2 Residential address
2.2.3 Contact details (telephone number, email address)
2.24 Date and place of birth, gender, place of citizenship
2.25 Bank account information and/or credit card details
2.26 Your status as a politically exposed person
2.27 Source of funds & proof of address
2.28 Passport information and/or driver’s license information or government issued identification card to verify your identity
2.2.9 Permanent and temporary address
2.2.10 Transaction history and account balances in connection with your use of certain Services
2.2.11 tax-related information; and
2.2.12 other information as may be required to verify you in accordance with applicable laws and regulations.
2.3 Mobile Applications. Certain Mobile products and services (“Products”) are currently supported by third party advertising partners that serve advertisements (“Third Party Advertisers”), including behavioral, location or interest-based advertising (“Interest Based Advertising”) within our Services. These Third-Party Advertisers use technology to serve the advertisements and may link to them directly into our Products. They may automatically receive your device ID, IP address or geo-location data (limited to country/region) when this happens.
When you use our mobile app, we also may collect mobile device information like operating system and hardware type, numbers or codes that are unique to your particular device (such as IDFA or an Android Ad ID), device information, default device language, the location of your device (at a GPS level), and app usage information. This data also may be linked to your other information, including your location data.
Upon request we can provide you with our Third-Party Advertisers and Partners used within certain Products, and their respective privacy policies for information regarding their privacy practices.
Your mobile device may provide you with the ability to limit this functionality.
iOS (versions 10-13) – On your iOS device (iPhone or iPad), open “Settings > Privacy > Advertising” and turn on “Limit Ad Tracking” to opt-out of interest-based ads. Please see additional information from Apple here: https://support.apple.com/en-us/HT202074
iOS (version 14.5+) – On your iOS device (iPhone or iPad) open “Settings > Privacy > Tracking” and turn off “Allow Apps to Request to Track”
Android – Open the Settings app on your Android phone, tap Ads and enable “Opt out of interest-based ads”.
Please note that if you opt out of certain Interest Based Advertising, you may continue to receive contextual ads based on other non-personal information, such as ads related to the content of the Product you are using.
Opt-Out for Location Data
Certain Third-Party Advertisers in Products may collect (with your permission) precise location data, or street-level location information, about you (“Precise Location Data”). Your mobile device may allow you to opt out of the collection of Precise Location Data by the Third-Party Advertiser in the Product, as further described below. Please note that your mobile device will not share location information without your permission.
iOS – In order to disable the collection of Precise Location Data on iOS, you may turn Location Services off for the applicable Product via the menu “Settings > Privacy > Location Services”. Then select the applicable Product and set the “Share My Location” status to “Never”. Please see additional information from Apple here: https://support.apple.com/en-us/HT203033.
Android (6.0 / Marshmallow and higher) - In order to disable the collection of Precise Location Data on Android, you may turn Location off for the applicable Product via the menu “Settings > Apps > [applicable Product] > Permissions > Location”. Then turn off the “Location” button.
2.4 Social Media. In addition, if you choose to log in, access or otherwise connect to ggCircuit, or contact ggCircuit, through a social networking service (such as Facebook), we may collect your user ID and username associated with that social networking service, as well as any information you make public using that social networking service. We may also collect information you have authorized the social networking service to share with us (such as your user ID, public profile information, email address, birthday, friends list, and pages you have "liked").
2.6 Log File Information: When you use our Service, our servers may automatically record certain information that your device sends whenever you visit any website and use certain apps. These server logs may include information such as your web or app request, Internet Protocol ("IP") address, browser type, browser language, referring/exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and one or more cookies that may uniquely identify your browser.
2.7 Clear GIFs Information: When you use our Service, we may employ technology such as "clear GIFs" (a.k.a. Web Beacons) which are used to track the online usage patterns of our users. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by specific users.
3. The Way ggCircuit Uses Your Personal Information
3.1 We use your personal information to operate, maintain, and provide to you the features and functionality of the Service, including but not limited to the following:
3.1.1 providing you with our products and services, including our games;
3.1.2 processing and responding to enquiries;
3.1.3 personalizing your use of the Service,
3.1.4 alerting you to new features, special events, products and services, or certain third-party products or services in which we think you will be interested;
3.1.5 enforcing the legal terms that govern your use of the Service; and
3.1.6 identity verification services, anti-fraud services and other service providers.
3.1.7 integrity and match verification activities related to ggCircuit’s affiliates such as LANduel platform.
3.2 We may use your information (both personal and non-personal information) to send you marketing and advertising content, including sending you advertising through multiple channels, such as direct mail, email, push notifications and display media. We may send you advertising or content regarding our products and services, or products and services that we market on behalf of another company, such as a sports team, a sports venue, or other entity.
3.3 We may use your information to communicate with you about:
3.3.1 our products and services in which you may be interested provided that you have not requested otherwise;
3.3.2 newsletters and information for which you have signed up; and
3.3.3 non-marketing or administrative purposes (such as notifying you of major changes to the Service or for customer service purposes).
3.3 We use your information to improve the quality and design of our Service and to create new features, promotions, functionality, and services such as by storing, tracking, and analyzing user preferences and trends.
3.5 We may anonymize, de-identify, or aggregate your information for any legitimate business purposes, including for reporting and research, or advertising. Such anonymized and/or aggregated data does not personally identify you. Sometimes, this information may be used to target more relevant content or offers to you across different devices – for instance, we may provide you with offers and content on your mobile device, based on your web-based activity.
3.6 We will retain personal information as long as necessary to fulfill these purposes unless the law requires us to keep it for a longer period of time. To provide security and business continuity for the activities described here, we make backups of certain data, which we may retain for longer than the original data.
4. When ggCircuit Discloses Information
4.1 We may disclose the information we collect or receive from you to our subsidiaries, affiliated companies, agents, or other businesses, or service providers who process your information on our behalf in order to provide or operate the Service. For instance, these entities may have access to your information for purposes including (but not limited to) billing and accounting, hosting, marketing, promotional and email services, customer and technical support, and for the purpose of accepting deposits and paying withdrawals and processing such information on our behalf, and in each case, may use the information to make improvements to the services they provide to us. Our agreements with these service providers limit the kinds of information they can use or process and require them to use reasonable efforts to keep your personal information secure.
4.2 When you choose to share information with social media services about your activities on ggCircuit by, for example, connecting your social media account to our Service, then ggCircuit may share your personal information and information about your use of the Service with such social media sites. Please make sure to read the terms and privacy statements of such sites prior to connecting to our Service in this way. The Service offers publicly accessible information sharing such as usernames/aliases, linked game accounts, game scores and stats games played, prizes redeemed, membership level, join date, rankings and coins earned. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
4.5 Where you have provided your consent, we may share your personal information with selected third parties for their commercial or marketing use in conjunction with your relationship with ggCircuit or as part of a specific program or feature.
4.6 In addition, we may disclose to third parties various types of your information for targeted online or mobile advertising, as further described in the Section titled “Third Party Advertising and Analytics” to help us with our business activities such as an email service provider, Google Analytics or an event management company. These companies are authorized to use your personal information only as necessary to provide these services to us. Examples are:
• When we send you an email via our service provider, they are provided your email address.
• When you participate in an event, your personal information may be provided to an event management contractor to contact you about the event.
• Services such as Google Analytics collect, monitor and analyze our aggregated user information in order to improve our Service or make the information collected more useful.
We may also disclose your information, both personal and non-personal:
• As required by law such as to comply with a subpoena, or similar legal process.
• When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
• To any other third party with your prior consent to do so.
• We may provide services jointly with other companies such as @Home or which are sponsored by other companies. Their use of your information is subject to their own privacy policies. When you use these joint services, you are giving us permission to disclose your personal information to such other companies and to be contacted by them so that they can inform you about those services. You will be notified when another company is involved in a service provided. If you do not want your personal information shared, do not participate in such services.
4.7 We also may share personal information in other situations with your consent.
4.9 In the event that ggCircuit is involved in a merger, acquisition, sale, bankruptcy, insolvency, reorganization, receivership, assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, or other change of control, there may be a disclosure of your personal information to another entity related to such event.
5. Legal Bases for Processing Personal Data
5.1 Some laws require companies to tell you about the legal grounds they rely on to process your personal information. To the extent those laws apply, we process your personal information:
5.1.1 Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests’ in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
(a) Customer service
(c) Protecting our players, personnel and property
(d) Analyzing and improving our business
(e) Processing job applications
(f) Managing legal issues
5.1.2 We may also process personal data for the legitimate interests of our affiliates or business partners, such as to offer special events or contests or assist with marketing.
5.1.3 Processing for the contract: Some Personal Data we process about you is for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract with us and to meet our contractual obligations with our players.
5.1.4 Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent.
5.1.5 Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations. In some cases, we have to process your Personal Data to comply with legal obligations, including those applicable to financial services institutions, such as under the Bank Secrecy Act and other anti-money laundering laws. You may not be eligible for certain Services if we cannot collect the Personal Data necessary to meet our legal obligations.
6. Your Choices
6.2 You can access and update certain personal information ggCircuit holds about you at any time by logging into your account via the Service and change information about yourself and the account itself. You can also unsubscribe to marketing emails and newsletters by using the 'unsubscribe' feature in the communication.
6.3 We may occasionally send display media to you, in a targeted way, whether through web or mobile browsers or mobile applications. You may opt out of many third parties that support and send this type of targeting advertising by going to www.aboutads.info, and you may learn more about this type of advertising in the below Section titled “Third Party Advertising and Analytics.” You may opt out of tracking for mobile advertising through the settings on most smartphones, and you may learn more about these settings through those mobile device platforms, i.e., Google (here) and Apple (here). (Please note that these companies may change either the way these settings operate, the content or the availability of these pages.)
6.4 We may occasionally send you push notifications to your mobile device. You can turn off certain push notifications in the account settings of any mobile app by ggCircuit or any of its affiliates. You can also turn off push notifications specific to our Service in the settings on your iOS device, or through the application manager in your Android device.
6.5 Subject to some important legal limitations, users in Canada can contact us as described below to make additional requests, such as to request access to, correction or deletion of certain personal information we store; to receive a copy of certain personal information they provided to us in portable form or to request that we share it with a third party; to request restrictions on the use of their personal information; to object to our use of their personal information; or to withdraw consent to use their personal information (which will not affect the legality of any processing that happened before the request takes effect). Please note that we may reject requests which risk the privacy of others or are unreasonable or repetitive, frivolous, would require disproportionate effort or for which access is not otherwise required by local law.
6.6 For example, Canadian users can contact us to opt out of all processing of their personal information for direct marketing purposes (in addition to the unsubscribe option described here).
6.7 Can reach us as described below with any other concerns, requests or complaints regarding our data collection, data use or data transfer. You also have a right to file a privacy complaint with the relevant privacy regulator, but we respectfully invite you to allow us to try to resolve the matter directly. We will attempt to answer your questions and satisfy your concerns in a timely and complete manner.
7. How do we safeguard and transfer your information?
7.1 We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure.
7.2 While neither we, nor any other organization, can guarantee the security of information processed online, we do have appropriate security measures in place to protect your personal information. For example, we store the personal information you provide on computer systems with limited access that are located in facilities to which access is limited.
7.3 To further protect your privacy and security, we reserve the right to take reasonable steps (such as requesting your password) to verify your identity before granting you profile access or making corrections.
7.4 Additionally, you should ensure your password is kept secret at all times. You will be responsible for maintaining the secrecy of your password and account information.
8. Children’s information
8.1 Protecting the privacy of young children is especially important to ggCircuit. For that reason, ggCircuit does not knowingly collect or maintain personal data or non-personally identifiable information from underage users other than as permitted by law in support of our internal operations.
Croatia, Germany, Hungary, Ireland, Luxembourg, Malta, Netherlands, Poland, Romania, Slovakia - 16 or under
Czech Republic, France, Greece, Slovenia - 15 or under
Austria, Bulgaria, Cyprus, Italy, Lithuania, Spain - 14 or under
United States, United Kingdom and any EU countries not listed above - 13 or under
9. California Residents
The California Consumer Privacy Act 2018 (the “CCPA”), Privacy Rights for California Minors in a Digital World and the California Shine the Light law provide California residents with certain rights regarding the processing of their personal data.
10. Nevada Residents
Nevada law provides Nevada residents with certain rights regarding the processing of their personal data.
11. EEA, UK and Switzerland only
With respect to personal data of individuals from the European Economic Area (“EEA”), the United Kingdom (“UK”) or Switzerland, our legal basis for collecting and using the personal data will depend on the personal data concerned and the specific context in which we collect it. ggCircuit will generally collect personal data from you or a third party only where: (a) we have your consent to do so, (b) where we need the personal data to perform a contract with you (e.g. to deliver the services you have requested), or (c) where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms).
12. International Transfers of your Personal data
We are a global company. Information about you may be stored and processed in the European Economic Area, the United States or any other country in which ggCircuit or agents or contractors maintain facilities, and by accessing our websites and using our mobile apps, software and services, you consent to the transfer of your information outside of your country. Such countries may have laws which are different, and potentially not as protective as the laws of your own country.
Whenever we share personal data originating in the EEA, the UK or Switzerland, we will rely on lawful measures to transfer that data, such as the Privacy Shield or the EU standard contractual clauses. If you reside in the EEA, UK or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal data to the United States and other jurisdictions in which we operate. By providing your personal data, you consent to any transfer and processing in accordance with this Policy.
13. Links to Other Sites
15. Contact Us
By email at: email@example.com
If you are located in the United Kingdom (UK) you can contact representative at: firstname.lastname@example.org.
Your California Privacy Rights
California Civil Code Section 1798.83 (“Shine the Light”) permits our customers who are California residents to request, once per calendar year, the following information from us:
(i) a list of the kinds of personal information that we have disclosed to third parties for direct marketing purposes during the preceding calendar year; and
(ii) the names and addresses of all of the third parties that received personal information from us for direct marketing purposes during the preceding calendar year.
For inquiries regarding our disclosure policy, please contact us as described above. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.
California Business and Professions Code Section 22581 (“California Privacy Rights for Minor Users”) permits you, if you are a California resident under the age of 18 to view, correct or remove information provided by you or publicly posted by you. For inquiries regarding our disclosure policy, please contact us as described below in Section 10 “Your questions and how to contact us”. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Any enquiries from underage users will be deleted upon completion.
Your Rights under the California Consumer Privacy Act (the “CCPA”)
Our customers who are California residents have the following rights under the CCPA:
Do Not Sell My Personal Information
To exercise any of your rights under the CCPA, please contact us via email and be ready to provide your name, address, and email. We may ask for other information in order to confirm your identity. Any information we receive from you in order to confirm your identity will solely be used for such verification purposes.
You may also designate an authorized agent to make a request on your behalf. If you choose to designate an agent, please be sure the agent can
(i) provide written permission from you for the agent to make the request on your behalf, and
(ii) provide proof of his or her own identity.
Further Disclosures Under the CCPA
During the past twelve (12) months, we have collected the following categories of personal information from the following sources, for the following purposes, and have shared them with the following third party service providers:
Personal Identifiers & contact information: Information you give us when you sign up to access our Services, or other information you choose to give us. Our purposes for collecting this information are:
Commercial Information: Information provided by you and/or third party stores. Our purposes for collecting this information are:
Technical and Device Information/Internet Activity: Information from your mobile or computer device when you use our Services. Our purposes for collecting this information are:
Feedback: Your questions, suggestions or views on the Services. Our purposes for collecting this information are:
Third Party Information: Information about your use of our Services that is shared with third party platforms and services connected with our Services. Our purposes for collecting this information are:
The Categories of Parties With Whom We Share Personal Information
We do not “sell” consumer data as most people would understand the term “sell”. However, the CCPA defines the “sale” of information broadly to include activities we believe most people would understand as “information sharing”. For example, the CCPA defines “sell,” “selling,” “sale,” or “sold,” as selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration. The term “other valuable consideration” is not defined in the CCPA. Notwithstanding that, we do not believe we “sell” consumer data as the term “sell” is defined under the CCPA. However, we do share consumer data with our affiliates, third party service providers, advertising partners and marketing partners as explained above in this Further Disclosures Under the CCPA section. To the extent those activities may constitute a “sale”, we have shared such data with such parties the past twelve (12) months and anticipate continuing to share such data with the same parties in the next twelve (12) months. If our data sharing practices change, we will update this policy to reflect that change.
Our customers who are Nevada residents have the right at any time to request that we do not sell the following information regarding them to third parties:
(1) the customer’s first and last name;
(2) the customer’s physical address which includes the name of a street and the name of a city or town;
(3) the customer’s e-mail address;
(4) the customer’s telephone number;
(5) the customer’s social security number;
(6) the customer’s identifier that allows a specific person to be contacted; or
(7) any other information concerning a customer collected from the customer through our Internet website or online service and maintained in combination with an identifier in a form that makes the information personally identifiable.
To exercise your right to opt out of the sale of Covered Information under Nevada law, please contact us and be ready to provide your name, address, and email. We may ask for other information in order to confirm your identity. Any information we receive from you in order to confirm your identity will solely be used for such verification purposes.
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