Privacy Policy

Updated August 30, 2021.

G-Loot Global Esports AB provides an esport platform with features allowing gamers to participate in competitions for monetary prizes in competitive, electronic games (the “Service”). The Service includes both G-Loot and GLL as further described on gloot.com and gll.gg is offered on both mobile and desktop devices. The Service is provided by G-Loot Global Esports AB, reg. no. 556981-0517, Birger Jarlsgatan 37 B, 111 45 Stockholm, Sweden(hereinafter “we”, “our”, “us”, the “Company” or “G-Loot”). This User Agreement and G-Loot’s Privacy Policy (this “Agreement”) applies to all Users of the Service (collectively or individually, “Users”, “User” or “you”). Each of G-Loot and the Users is referred to as a “Party” and together as the “Parties”. 

General information

This Privacy Policy applies when you use the Service, contact us, when we receive your personal data from one of our business partners or when you post messages at our public forums. This Privacy Policy does not cover any interaction you may have with G-Loot by telephone, postal mail, or other offline communications.

You should always be able to feel safe when we process your Personal Data. With this Privacy Policy, we want to explain how we ensure that your Personal Data is handled in accordance with Applicable Data Protection Regulations. Furthermore, this Privacy Policy is intended to provide you with information about how we collect your Personal Data, what Personal Data we Process and why, for how long we Process Personal Data, who can access your Personal Data, how we protect your Personal Data and your rights in relation to your Personal Data. We reserve the right to erase Personal Data.

G-Loot collects, and processes the following Personal Data about you as a user for the following purposes:

Purpose

To ensure that you can use the Service and that G-Loot can provide the Service. 

How the data is processed

  • Provide access to the Service

  • Login functionality

  • Onboarding communication

  • Transactional communication 

  • Service communication

  • Age block processes

  • Personalized content

Personal Data used for this purpose

  • Email address 

  • User ID

  • Password

  • Profile picture

  • IP-address

  • IP-login logs

  • Date of birth

  • Competition history

  • Personal service settings (such as followed players, stated games played and …. if these have been chosen by the player)

Lawful basis for processing

Legitimate interest. The information gathered is entered by the player and is needed to provide the Service to you as a user. All personal service settings are optional, added by the user, and can be removed at any time. 


Purpose

To send you important information regarding the Service.

How the data is processed

  • Communication based on actions needed in the Service

  • Communication triggered by the user within the Service

Personal Data used for this purpose

  • Email address

  • Username

  • Transactional data 

  • Competition participation

Lawful basis for processing

Legitimate interest. The communication sent, based on this purpose, is solely triggered by interaction from the user within the Service and is informative of the results and effects of this interaction. 


Purpose

To send you updates and information about your active games and competitions connected to them and similar activities.

How the data is processed

  • Communication concerning activities similar to those you as a user have shown interest in 

  • Communication concerning favorite games and similar games 

  • Up and downtime information for games

  • Competition 

  • Onboarding communication

  • Transactional communication and invitations

  • G-Loot offers and product information

Personal Data used for this purpose

  • Email address

  • Preferred games

  • Game logs

  • Game activity

  • Login logs

  • G-Loot Wallet balance

  • Marketing mail interactions

Lawful basis for processing

Legitimate interest. As a way to keep our players informed and up to date with what is happening with both game development and our competitions, G-Loot customizes the communication to the players based on their gaming profile to make the information useful for the specific player. A user can choose to opt out from the communication at any time through the unsubscribe functionality. 


Purpose

To enable participation in competitions within the Service.

How the data is processed

  • Anti-cheat processing

  • Game results, statics, and score tracking

  • Leaderboard presentations

  • Result broadcasting to followers/following

Personal Data used for this purpose

  • UserID

Depending on games played, any of the following

  • Username

  • Profile picture

  • External ID 

  • Game statistics

  • Game results

  • Game scores

Lawful basis for processing

Legitimate interest. The competition functionality is a core feature of the G-Loot Service, and is activated as soon as the user downloads and runs the app in combination with one of the G-Loot competition game applications. Participation in said competitions requires the gathering and processing of game data and enables the user to win money within the system.


Purpose

To ensure that you can use payment services from our payment providers.  

How the data is processed

  • Identity verification through KYC process

  • Payment supplier connection 

  • Background check concerning fraud & criminal activity

  • Identity validation

  • Duplicate account check

  • Age check

Personal Data used for this purpose

  • E-mail address

  • Username 

  • Full name

  • Date of birth

  • IP address

Through our KYC-process:

  • Full name

  • Age

  • Country

  • Tax payer number 

  • Photocopy of Proof of Address 

  • Background review 

  • Photocopy of identity document(s)

  • Portrait photo (personal characteristics)

Lawful basis for processing

Legitimate interest. The payment information is added by the user to enable deposits and withdrawals from the Service. It is a core feature when participating in competitions.


Purpose

To prevent cheating, crime, abuse or fraud.

How the data is processed

  • Communication to the user on ban from Service

  • Review of game logs

  • Review of user accounts

  • Automatic risk flagging 

  • Information disclosure to local law enforcement according to local legislation

Personal Data used for this purpose

  • E-mail address

  • Username 

  • Profile Picture 

  • IP address

  • IP login logs

  • Date of birth

  • Free Competitions log

  • Competitions log

  • Leaderboards

  • Deposits

  • Full name 

  • Masked card number

  • Withdrawals

  • Anti-cheat analysis based on keyboard strokes & mouse movement 

  • Game data

  • Game ID 

Lawful basis for processing

Contract. In the Terms and Conditions of the Service, G-Loot clearly states the rules and regulations connected to the Service. The cheat prevention processing activities and data is limited to users who display patterns which could indicate wrongful use of the Service. The flagging of these patterns is done automatically to decrease the amount of bias and exposure of user data to G-Loot employees.


Purpose

To provide customer support and service guidance

How the data is processed

  • Communication and answering to support tickets 

  • Identify users within the Service

  • Troubleshooting in user data to solve support tickets 

  • Commandeer user accounts for additional troubleshooting

Personal Data used for this purpose

  • E-mail address

  • Username (optional)

  • IP address

  • IP login Logs

  • Date of birth

  • Game ID's and/or Nicknames

  • Competition logs

  • Full name 

  • Game data

Lawful basis for processing

Legitimate interest. The processing of the data is triggered by a support ticket from the user in question and the processing will be used to enable usage of the Service for the user again. 


Purpose

To improve, research, evaluate and develop our services, competitions, and customer support.

How the data is processed

  • Analysis of service usage to support improvement of the Service 

  • Analysis of service usage to identify and map unusual or suspicious behaviour that could entail fraud or cheating 

Personal Data used for this purpose

  • Cookie adv. data

  • E-mail address

  • Username 

  • IP address

  • IP login logs

  • Mail interaction 

  • Game ID's and/or nicknames

  • Competition logs

Lawful basis for processing

Legitimate interest. The information processed to improve, evaluate, and develop our services is deemed as a shared interest to meet our users expectations and interest in a fully functional and continuously improved service. 


Purpose

To prohibit usage of the Service from regions and areas where the Service is not provided.

How the data is processed

  • Location tracking 

  • Blocking of Service access from prohibited areas

Personal Data used for this purpose

  • IP address

  • IP login logs

Lawful basis for processing

Legal obligation. The Service provided by G-Loot is only available to users in regions where the Service is deemed lawful and thus, G-Loot tracks user IP addresses to ensure compliance with local legislation.


Purpose

To limit the Service functionality for users under the age of 18.

How the data is processed

  • Service limitations such as:

    • Monetary prizes competitions blocked 

    • Unable to deposit/ withdraw 

    • Unable to subscribe to the Service

Personal Data used for this purpose

  • Email address

  • Date of birth

  • Legal guardian?

Lawful basis for processing

Contract. In accordance with the terms and conditions, users below the age of 18 and above 13 need a legal guardian to use the Service, and the Service will be limited until the user turns 18. 


Purpose

To prohibit the use of the Service by children under the age of 13. 

How the data is processed

  • Age-control for date of birth

  • Stored encrypted emails to block repeated registration tries  

Personal Data used for this purpose

  • Email address

  • Date of birth

Lawful basis for processing

Contract. The Service is only provided for users above the age of 13, to ensure a lawful and safe service, younger users’ emails will be blocked from creating accounts in the Service.


Purpose

To invite you to participate in G-Loot’s community on various social media platforms.

How the data is processed

  • Voluntary connection to social media accounts

Personal Data used for this purpose

  • Social media account link(s)

Lawful basis for processing

Legitimate interest. The user adds all social media information voluntarily in the Service to participate in the community and can remove this at any time.


Purpose

To provide relevant and targeted ads on our website

How the data is processed

  • Ads on the G-loot website will display content based on both previous and current data gathered by a third-party provider.

Personal Data used for this purpose

  • IP Adress

  • User Location

  • Website interaction

Lawful basis for processing

Consent. When visiting our websites, we display ads through the service Google AdSense, when consenting to the processing above, these ads are adjusted to your specific profile. You as a user can always withdraw your consent, which will stop all further processing for this purpose. Ads will still be displayed, but will not be targeted. 

For further information, see the segment about cookies below, and third-party providers. 


Definitions

As we want to make sure that you fully understand our Privacy Policy, we will define some important terms.

“Applicable Data Protection Regulation” refers to the General Data Protection Regulation (GDPR), which implements the EU Regulation 2016/679, including all relevant case law, guidelines and regulations from governmental authorities and such.

“Personal Data” refers to any data, whether by itself or when linked to other information in the possession of, or likely to come into the possession of G-Loot, that can be used to directly or indirectly identify a living person.

“Processing” refers to any operation, or set of operations, which is performed on Personal Data, whether or not by automated means, such as the collection, organization, storage, use, erasure, disclosure by transmission or otherwise making it available.

All other definitions in this Privacy Policy shall be interpreted in accordance with Applicable Data Protection Regulation and the General Terms and Conditions.

Who is the data controller?

G-Loot is the data controller and is responsible for the Processing of your Personal Data. We shall ensure that the Processing conducted by us complies with applicable Data Protection Regulation. We shall ensure that the Personal Data Processed about you is accurate, necessary, and legitimate.

Accuracy of Personal Data

When you use the Service we may ask you to provide certain Personal Data, as described in the table above. By providing this information, you represent that it is accurate and complete, and agree to promptly update the information as necessary to ensure that it remains current. 

Payment information

We do not process user credit card information. For means of customer support we will, however, have access to user transaction history, IP address, currency, and name entered when registering a payment method in our Service. Sensitive credit card information is only Processed by our payment providers. G-Loot does not have access to your sensitive credit card information.

For how long do we keep your Personal Data?

Your Personal Data is only kept as long as needed to fulfill the purposes for which it was collected according to this Privacy Policy as outlined in the table above. We may keep the information for a longer period of time if necessary to comply with legal requirements or to protect G-Loot’s legal interests, for instance, if there is an ongoing legal process. User data is continuously anonymized after 24 months of inactivity from the user. Data connected to visitors to our site will be removed or anonymized immediately after you leave the site as a visitor. Support tickets sent from you as a visitor/user to our customer support will be viewed as independent from the user data and archived after 120 days. Transactional data will, in accordance with local legislations, be kept for a minimum of 7 years. 

Who can access your Personal Data?

Some of the Personal Data, such as username, profile picture, and contest results will be made public within the Service and is therefore available to other G-Loot users while you participate in the Service.

All postings in G-Loot’s public forums will be available for other users as well as the Internet general public. Information posted on the public forum will therefore not be private or confidential.

To be able to deliver the Service, G-Loot may share your Personal Data with third parties, such as relevant payment service provider(s) and partnered third-party game developers.

To process payments, we will transmit your user account information and other Personal Data to a third-party service provider. G-Loot may also transfer or disclose your Personal Data to third parties if it is necessary to comply with legal requirements or requirements from authorities that G-Loot is subject to, to protect G-Loot’s legal interests or to detect, prevent or draw attention to fraud and other security or technical issues. 

For more information about our third-party providers, see the list of third-party providers.

In the event that there is a sale of the assets of G-Loot or corporate restructuring, or as a result of a change of control of G-Loot or one of its group companies, or in preparation of any of these events, any third party to which G-Loot transfers or sells G-Loot’s assets will have the right to continue to use the Personal Data and other information that you provide to us in the manner set out in this Privacy Policy. We will not sell or rent your Personal Data to any third party outside of these circumstances.

In cooperation with the games in which our Service is available, G-Loot may transfer or disclose your Personal Data to countries outside the EU/EEA as necessary to provide you the Service. If Personal Data is transferred to a country outside the EU/EEA, G-Loot will take action to ensure that it continues to be protected. G-Loot will take appropriate and necessary measures to lawfully transfer Personal Data to countries outside the EU/EEA.

Third-party providers

Supplier

Sum and substance - KYC process - https://sumsub.com/data-protection-policy/ 

AnyBrain - Anti-cheat software - https://anybrain.gg/privacy 

Bambora, PaymentIQ - Payment provider - https://www.bambora.com/en/ca/privacy-policy/ 

PayPal - Payment provider - https://www.paypal.com/myaccount/privacy/privacyhub 

Overwolf - Game information - https://www.overwolf.com/legal/privacy/ 

Hotjar - Site improvement - https://www.hotjar.com/legal/policies/privacy/ 

Google Analytics - Site analysis - https://policies.google.com/privacy?hl=en-US  Google AdSense - Display Ad targeting - https://policies.google.com/privacy

Braze - Mailing service - https://www.braze.com/company/legal/privacy 

MailChimp - Investor, Mailing service - https://mailchimp.com/legal/privacy/ 

Amplitude - Service improvement - https://amplitude.com/privacy 

ZenDesk - Customer service & support - https://www.zendesk.com/company/agreements-and-terms/privacy-policy/ 

HyperWallet - Payment provider - https://www.hyperwallet.com/privacy-policy/ 

UserTesting - Service improvement - https://www.usertesting.com/privacy-policy 

Send Grid - Mailing service - https://sendgrid.com/policies/security/ 

Protection of your Personal Data

You should always be able to feel safe when we are Processing your Personal Data. G-Loot has taken appropriate security measures required to protect your Personal Data against unauthorized, unlawful, or accidental access, modification, loss, destruction, and damage.

You are solely responsible for your login information to the Service. G-Loot will never request your password or ask you to provide sensitive account information.

Your rights

You have the right to request that G-Loot corrects, rectifies, erases, or restricts the Processing of your Personal Data, in accordance with Applicable Data Protection Regulations. To exercise these rights, please contact G-Loot customer support.

You have the right to request information regarding all Processing of your Personal Data conducted by G-Loot. The information provided shall include; what categories of Personal Data is Processed, the purpose of the Processing, the anticipated period during which the Personal Data will be stored, if the Personal Data is disclosed to third parties, and if the Personal Data is transferred to third countries. This information shall be provided to you free of charge.

You can at any point in time prohibit G-Loot from using your Personal Data to send you information and news. When G-Loot receives your notification, we will stop processing your Personal Data for these purposes. You are given the opportunity to unsubscribe from receiving further information and news regarding the Service in every such email from us.

Website cookies, advertising, and analytics

When you visit any of our websites (gloot.com, investor.gloot.com, gll.gg, play.gloot.com, help.gloot.com, Raidmasters.gg, Developers.gloot.com), G-Loot may place cookies on your browser. The types of data collected include cookie values, pages visited, and other types of website activity. IP addresses are always, due to the nature of internet technology, included with all requests. We do, however, whenever possible make sure that IP addresses are not stored. We base these activities on consent, hence you can consent or not consent to targeted marketing activities as well as withdrawing your previous consent in your privacy settings.

G-loot may choose to display advertisements on our websites (listed above) and in our software (client). To ensure that this advertising is both relevant for you as a user/visitor and also to continuously improve the advertising, we gather data (through third parties) about how you as a user interact with the ads on the site. Interaction data gathered includes which ads have been shown to you and/or other users, how many times ads have been viewed and clicked.

This data, in combination with previously collected demographic information (e.g. gender, age, country) is then used to determine which advertisements to show you, and when. Information about your device's current geographic location, your browser and which sites you’ve recently visited is also used to adjust how you are segmented in terms of advertisement shown.

G-Loot allows third-party providers (see table above) to gather, process, and store data, for displaying advertisements. For specific information about which data is gathered and how it is used, please visit the links in the table above for detailed information. The aim of this processing is, as previously stated, to keep the advertisement that is shown for you relevant. You can adjust which data is gathered for this purpose through our cookie settings. Doing so will not block advertisement on site, but you can adjust which cookies we gather.

For us to be able to advertise on other sites based on user activity, such data may be used by third parties such as Facebook, Google, Twitter, Snapchat, Adroll, Bing, and Reddit. We also use cookies to understand site usage and to improve or customize the content on our site.

To opt-out of receiving targeted advertising, check www.aboutads.info, networkadvertising.org/choices or, for those of you who are in Europe, youronlinechoices.eu.

In your browser, you can also change your privacy preferences regarding the use of cookies and similar technologies. You may set your browser to accept all cookies, block certain cookies, require your consent before a cookie is placed in your browser, or block all cookies. Blocking all cookies will affect your online experience. Consult the Help section of your browser for more information.

Age limitations, children and Personal Data

All users of G-Loot Services are to confirm their age at the point of registering, or attempting to register, a G-Loot user account. The Service is not directed towards or intended for people under the age of 13, and G-Loot will not knowingly acquire any additional data beyond account creation attempts from people under 13. Users between the age of 13-18 may, however, use the Service with the permission of, and the use of Personal Data from, a legal guardian. The guardian’s data is then used for all Processing connected to payments within the Service, thus having a joint account where the guardian is bound by G-Loot’s terms and conditions and payment regulations until the user turns 18. See above for details about the processing.

The Service will be limited for any user below the age of 18 (yet above the age of 13), where the user cannot use the following features in the Service:

  • Engage in competitions that have an entry fee

  • Most competitions with monetary prizes

  • Make any deposits or withdrawals

  • Establish any paid subscription

If you are a parent or guardian who has discovered that your Child has submitted Personal Data, without your permission, please contact us at G-Loot Customer Support and we will delete the information from the Service.

Changes to the Privacy Policy

G-Loot has the right to change this Privacy Policy at any time. We will give you reasonable notice of any changes to the Privacy Policy. If you do not accept the changes, you may not be able to participate in the Service.

Contact information

Let us know if you have any questions about this Privacy Policy or the Processing of your Personal Data or if you wish to request information regarding the Processing of your Personal Data. Our contact information is found at the beginning of this Privacy Policy.

To make G-Loot better we collect information from you as visitor with help from cookies. We would also like to ask for you consent to share your data with Facebook, Google, Snapchat, Adroll and Bing to conduct relevant marketing of G-Loot's services within Facebook, Google, Snapchat, Adroll and Bing's network.