July 12, 2023
This Privacy Policy Statement sets out how we collect, use, manage and protect the personal data or information (“Data”) that we may collect from or about you. It applies to all individuals whose Data may be handled, whether as controller or processor, by ER Esports Limited (collectively “EES”, “we”, “us” or “our”, being Emperor Esports Stars, its subsidiaries, affiliates and associated companies, including without limitation, social media platforms under EES). You shall read this Privacy Policy Statement carefully so as to ensure that you fully and clearly understand the contents herein.
Protecting your privacy
We are dedicated to processing your Data in accordance with the required standards. This includes protecting your privacy and ensuring the security of your Data in compliance with, where applicable, the requirements of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “Ordinance”), Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”) and other relevant regulations where applicable.
Before using and providing your Data for the purposes as set out in this Privacy Policy Statement, we may be required by law to obtain your written consent, and in such cases, only after having obtained such written consent, may we use your Data in the manner as specified. If you are a minor or under 16 years old or a person who are mentally incapable, you must obtain express consent from your parents or guardian before providing any personal data to us. If you do not accept the following terms of this policy, please stop accessing, browsing or using this website/our e-services.
Your Data
We may collect, use and hold a range of different Data about you. For the purposes of carrying on our business (including the verification of your identity to detect, prevent and address fraud, security or technical issues (collectively, “Service(s)”) and complying with laws, rules, guidelines, regulations and/or requests issued by applicable government authorities, courts, law enforcement or other authorities or regulatory bodies, you may be requested to provide Data such as, but not limited to:
(a) contact details including but not limited to name, address, phone number, mobile telephone number and/or email address, etc.;
(b) Data that you have shared with third party social media platform operators (e.g. account login name, profile picture, contact details), etc.;
(c) device specific information such as hardware model, operating system, version, unique device identifier, serial numbers, setting configurations and software and mobile network configuration;
(d) information about how you use our Services such as your network usage, how you use our network, and your location when you are using our Services;
(e) all Data requested by applicable government authorities, courts, law enforcement or other authorities or regulatory bodies to enable us to comply with or in connection with any law, rule, regulation, judgment or court order (whether within or outside of Hong Kong); and
(f) any other Data as may be required by any members of EES and/or their respective contractors, sub-contractors, intermediaries, agents, business partners or representatives from time to time and which is necessary for the provision of the Services.
(g) In some instances, where required by law to do so, we may seek your consent to process the following types of “Special Data” to us so that we may further improve our Services and/or better tailor the type of information or content that we present to you:
(i) age;
(ii) gender and ethnicity;
(iii) marital status;
(iv) Month of birth;
(v) education and profession;
(vi) monthly income range;
(vii) hobbies and leisure activities;
(viii) the Services that you have subscribed for; and
(ix) contact details, etc.
Provision of the Special Data mentioned immediately above is optional although, where the requested Service is a personalised Service or provision of a product is dependent upon your provision of all requested Data, failure to provide the requested Data may prevent us from providing those particular Services to you.
How we collect Data
We collect Data in a number of ways, including from:
(a) you directly, for example, when you provide Data by phone or via email, attend our functions, complete an application form or agreement for one of our Services, or when you submit your Data through our websites, mobile apps, or online chat sessions; or when you contact us with a query or request; or during the ordinary course of the continuation of our business relationship with you; or when we are legally required to do so;
(b) third parties such as related entities, business partners, or other customers, or your representatives with appropriate consent from you;
(c) publicly available sources;
(d) our own records of how you use our Services;
(e) your visits on our websites, or mobile apps (see “Privacy Data” section below); and/or
(f) your participation in surveys or marketing promotions organised by us or on our behalf, etc.
Participation in Promotional Activities
When participating in promotional activities organized by EES or online media or co-organized by our business parties, users may not be required to be registered as our member but will be required to provide personal data for registration.
Privacy Data
To better serve your needs and preferences, our web servers may collect Data relating to your website, device or app activity. We may also collect aggregated, anonymous, statistical data on the server’s usage so that we may better cater to the behaviour of users of our websites and mobile apps. This type of Data may include, but is not limited to:
(a) browser type, version and user agent;
(b) operating system;
(c) IP (Internet Protocol) address and/or domain name;
(d) connection data, statistics on page views and/or referral URLs;
(e) device ID, location and phone contacts;
(f) videos watched or searched for;
(g) links or images clicked on;
(h) cookies and/or browser, app or web server log data; and
(i) device and software characteristics and/or configuration.
Some of our websites may use cookies or similar tracking tools on your machine or device in order for us to, for example, personalise your user experience and/or maintain your identity across multiple webpages and/or Internet sessions. This Data may include, but is not limited to, relevant Data relating to your activities and the preference configurations on your device and across our websites and mobile apps. Our Website may embed third party features such as videos, maps and social media apps that provide you with a better browsing experience. Pages with these embedded features may present cookies from feature providers. We do not collect information from these cookies and do not control the dissemination of these cookies. These cookies or similar technologies are owned and controlled by third parties, and therefore the third parties – and not EES – are responsible for their use. As such, we cannot guarantee that we have listed every cookie or similar technology you might get from a third party since a third party could change them at any time as their needs change. You should check the relevant third party website for more information about these. Our websites may set up to accept cookies. You can opt-out of or delete historical cookies by changing the settings on your web browsers; however, if you do so, you may find that certain features on our website and/or our app do not work properly. (Note: Disabling the cookies function may cause inaccessibility to some parts of our websites and thus you may not be able to enjoy our Services.)
Apart from that, as for any link or advertisement on our websites (if any), its owner may set or identify cookies on your browser. The use of cookies by third-party advertisers or advertising providers is not subject to this Privacy Policy, but their respective privacy policies.
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