Privacy Policy

Last Modified: Feb 11, 2023

GMGaming, a Ugandan company with a registered office located at Nabweru, its technical processors are committed to protecting your privacy and granting importance to the confidentiality of your data over the Internet (hereinafter the “Company”, “We” or “we”). This privacy policy (hereinafter the “Privacy Policy”) applies to all services offered to persons using or visiting (hereinafter, the “Users”, “You” or “you”) the internet Application GMGaming (hereinafter the “APP”).

The purpose of this Privacy Policy is to inform you about the processing of your personal data collected when using the services available on the Website.

When you access to another website through a link or a URL available on the Website, this Privacy Policy does not apply anymore. The Company reserves the right to modify at any time this Policy Privacy and to inform you by any means. This Cookie Policy was last modified on the date indicated above.

This Privacy Policy is subject to the European Regulation of April 27, 2016, on the General Data Protection Regulation.

What are Personal Data?

In this Privacy Policy, “Personal Data” means any information relating to an identified or identifiable User, who can be identified, directly or indirectly, in particular by reference to his name, his email address, and his IP address (hereinafter the “Personal Data”). Personal Data does not include anonymized information that has been appropriately processed to make it non-identifiable in order to irreversibly prevent its identification.

When do we collect Personal Data and what data do we collect?

We may collect Personal Data when you use the services available on the Website such as:

• Visiting the Website
• Creation and management of an account on the Website
• Registration for a newsletter
• Registration and participation in, directly or indirectly, any tournament available
• Contacting our services

(hereinafter the « Services »).

For any Service that you may use, we only collect the data that is strictly necessary (i) for the delivery of the Services, (ii) for the performance of a contract for which you are the party, (iii) for which you have given consent for such processing of your data, or (iv) for compliance with a legal obligation to which we are subject.

Personal Data collected therefore differs from one User to another, depending on the number of Services used by each User.

Personal Data that we may collect through the use of the Services are for example your IP address, your name, your email, your age, your birthdate, your address, etc.

When you visit the Website or use some Services, we may install and store cookies on your terminal equipment (e.g.: computer, mobile). A cookie is a small text file of limited size that is stored on your terminal equipment when you visit an internet website.

Cookies are often used to improve the visit of the users (for example to temporarily remember your session in order to not ask you to fill in this information again each time you visit the Website or go from one page to another). Some other cookies are used to generate statistics or to remember your preferences.

What are the purposes of collecting your Personal Data?

Your Personal Data may be collected for the following purposes, depending on the Services you use:

• Providing Services or information that you request
• Performing technical and administrative features of the Website
• Management of your user account and associated preferences
• Provision of an instant messaging service
• Monitoring and analysis of the use of the Services by Users
• Measure the audience of the Website
• Sending targeted commercial offers by email
• Management of your newsletters subscription, notification by email
• Sharing information with tournaments organizers for the tournaments in which you participate in
• Reply to a request from an administrative authority or a judicial authority, in compliance with the legislation in force.

Personal Data collected for the purpose of using the Services is necessary to provide you with the Services you use.

Indirect collection of your Personal Data. For team tournaments, a member of the team can register all members of its team for the tournament. It is not necessary that every member of the team have a GMGaming account when registering for such a tournament. An email will be sent to all members of the team to inform them of their registration for the tournament. Should you desire to object to the storage of your Personal Data, contact us by email at gaming@greenmondayinc.com.

Newsletters and commercial offers. Prior to any direct marketing or commercial operation (for example for sending newsletters or commercial offers), we will first obtain your consent, either when creating your account on the Website or later by indicating your choice in your account settings. You will always have the right to withdraw your consent at any time, directly by clicking on the unsubscribe link available on each email received, by modifying your account settings, or by contacting us at the following email address gaming@greenmondayinc.com.

What are your rights and how can you exercise them?

Your rights. In accordance with the legislation in force, you have a right to access, rectify and object data concerning you. You can access and change the information and preferences you provided when you created your account on your account page or by contacting us at the address below.

Your rights from May 25, 2018. From May 25, 2018, and in accordance with the General Data Protection Regulation 2016/679 of April 27, 2016, you will be able to exercise your right to restriction of processing, to erasure (right to be forgotten), to receive your Personal Data in a machine-readable format (right to data portability) and to not be the subject of automated individual decision-making.

Right to object. To the extent permitted by law, at the exception of the processing for which there are compelling and legitimate grounds for the processing of your Personal Data, you can, at any time, object the processing of your Personal Data, in particular for data processed for direct marketing or commercial purposes.

Right to restriction of the processing. You can request us to restrict the processing of your Personal Data where one of the following applies or for any other case provided by the applicable legislation:

• You oppose the erasure of your Personal Data and request the restriction of their use instead of their erasure in the event that the processing is unlawful (for example in the event that a malevolent person has created an account with information related to you such as your email address or other personal data)
• You contest the accuracy of the Personal Data, for a period where we will verify the accuracy of the data we collected
• The Personal Data are no longer needed for the purposes of the processing, but you require that we store them for the establishment, exercise or defence of legal claims.

In the event processing has been restricted, your Personal Data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest.

In the event the restriction of processing is lifted, we will inform you by the most appropriate mean (for example by email or mail).

Right to data portability. We grant you the possibility to receive your Personal Data in a structured, commonly used and machine-readable format. You can exercise this right on your account page or contact us at the address indicated below.

Right to erasure. You can exercise your right to erase your Personal Data on your account page, in the “Delete” panel. The erasure of your Personal Data applies to all data that you have provided, with the exception of the pseudonym which has been used for tournaments in which you have registered or for those you have actually participated. The storage of the pseudonym has for the purpose to preserve the integrity of the tournament results, and for historical and archival purposes.
In the event that you would like to erase your pseudonym, you must contact us by email before erasing your account. We will send you a reply within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.

Exercise your rights. You can exercise your rights by contacting us by mail or by email at the following address:
GMGaming – Privacy
E-mail: gaming@greenmondayinc.com

In the event that the replies are not satisfactory, you can also contact the Data Protection Officer by mail or by email at the following address:
GMGaming – DPO
E-mail: gaming@greenmondayinc.com

In order to ensure the confidentiality and the protection of personal data, a copy of an identity document must also be included in the application.

To the extent permitted by applicable legislation, where requests from a data subject are manifestly unfounded or excessive, in particular, because of their repetitive character, we can refuse to act on the request or charge a reasonable fee taking into account the administrative costs of providing the information requested.

Should you still be unsatisfied with the reply, you can lodge a complaint with a supervisory authority.

What are the particularities concerning children’s rights?

To access and use our Services, children aged under 16 years old must be authorized by their legal representative (for example by their father, mother, legal guardian or any other legal representative holding the parental responsibility).

When a child aged under 16 years old wants to register an account on the Website, we make reasonable efforts to verify that the access and the use of the Services have been authorized by the legal representative of the child. We reserve the right to request written parental consent from the legal representative at any time.

To verify that a child is under 16 years old, the child must, during the creation of their account, certify that he has obtained the authorization of his legal representative.

How long is your data stored?

Your Personal Data is stored in a technically secured environment.

Depending on the processing of your Personal Data, the data may be subject to a different storage period.

Most of your Personal Data is stored for a duration of five (5) years from your last use of the Website, or a Service.

However, the IP address we collect during your visit is stored for a period of one year.

At the end of the storage period, the Personal Data are purged and therefore deleted from our database.

Who are the recipients of your data?

We may transmit to our processors and partners the processing of your Personal Data, according to our instructions. In addition, when you register for a tournament available on GMGaming, you accept that the tournament organizer will have access to the data you entered when you registered for the tournament.

The recipients of your data are:

• Tournament organizers
• Website moderation service
• Computer security service of the Website
• Police authorities in the context of judicial requisitions concerning fraud or any other legal grounds
• Administrative and judicial authorities concerning requests related to the investigation or the identification of a person, in strict compliance with the legislation in force
• The companies, subsidiaries and affiliates, of the group

We also work with processors for the following operations:

• Computer hosting
• Computer security
• Collection of customer opinions
• Statistics analysis
• Email and newsletters management

We do not sell your Personal Data to any advertisers or any third party. We use your Personal Data to display relevant advertisements, based on your preferences. We make reports related to the advertisement campaigns, in particular statistics, without any reference or information related to the personal data of visitors or users of the Website. You can also block advertising cookies on the dedicated “cookies” page.

What can tournament organizers do with the data collected from participants?

Registration and participation in tournaments. The Services available on GMGaming allow tournament organizers to collect and process the Personal Data of participants who have registered for their tournament. Tournament organizers shall be responsible for the processing of Personal Data collected for their tournament.
As a tournament organizer, you may choose to define the purposes and means of processing implemented for the performance of your tournament, in compliance with this Privacy Policy and the provisions related to the General Data Protection Regulation of April 27, 2016. GMGaming is therefore acting as a processor on behalf of the organizer who is responsible for any processing carried out.
In the event that a tournament organizer collects Personal Data that does not comply with the provisions of this Privacy Policy or with the provisions of the General Data Protection Regulation of April 27, 2016, GMGaming reserves the right to close the organizer’s account by written notice unless, within thirty (30) days, the breaching organizer cures such breach, or immediately in the event of a serious or repeated breach of any of such provisions.
Data collected by organizers. Tournament organizers are authorized to collect participants' data that are strictly necessary for the performance of their tournament. For example, these data can correspond to personal data necessary to verify the eligibility conditions of the tournament, such as age, address, or any other necessary information. In addition, the organizer may request from the participant proof to verify the accuracy of such data.
Tournament organizers are not authorized, through the use of the Services, to request from participants personal data that are sensitive or that may present a risk (for example, political opinion, religious opinion, passport number, credit card, or social security number).
Data security. Tournament organizers undertake to take all appropriate security measures to protect GMGaming and users or visitors of the Website against any unauthorized access, modification, disclosure or destruction of Personal Data collected through the Services.
Users Rights. Tournament organizers undertake to respect the rights of users as defined in this Privacy Policy. Report Abuse. If you believe that a tournament organizer is not acting in compliance with this Privacy Policy, you may notify us by email to gaming@greenmondayinc.com.

What is the Data Protection Officer?

GMGaming has designated a Data Protection Officer in charge to assist the controller in compliance with the General Data Protection Regulation. For any questions related to the privacy policy in GMGaming, you can contact the Data Protection Officer by email at gaming@greenmondayinc.com.

Is your data sent outside European Union?

For the use of certain Services, some of your Personal Data may be sent to partners or processors who are located in the territory of the European Union or in territories that offer an adequate level of personal data protection or to partners who adhere to an agreement in the field of personal data protection regulation such as the EU-US Privacy Shield.

Organizers located in territories that do not offer an adequate level of personal data protection. The Services are available worldwide and as such, some organizers may be located in countries that do not offer an adequate level of personal data protection. As any other organizer using the Services, these organizers are required to comply with this Privacy Policy and the European General Data Protection Regulation of April 27, 2016.

In the event that you are an organizer located in a territory that does not offer an adequate level of personal data protection of that do not adhere to an agreement in the field of personal data protection such as the EU-US Privacy Shield, you shall have to ensure that you will take all necessary security measures to ensure the security of the Personal Data collected through our Services.

How do we protect your Personal Data?

We take various measures to ensure the security of your data against the loss, unauthorized access, modification, disclosure or destruction of your Personal Data and in particular:

• Users' passwords are encrypted in the database
• The TLD protocol is used for forms containing Personal Data, allowing data encryption on the network
• Access to personal data is strictly reserved for persons authorized for the performance of their missions
• In accordance with the European General Data Protection Regulation of April 27, 2016, GMGaming has ensured that processors undertake to respect data security and confidentiality
• All GMGaming employees working on the Website are aware of the protection of personal data through training, newsletters and team meetings.

Modification

We reserve the right to make changes to this Data Protection Policy. In case of a substantial modification such as the addition of a new purpose, we will provide you with information about this new purpose beforehand. This is to make sure you have a reasonable timeframe to exercise your right in accordance with applicable laws and regulations.
We nonetheless encourage you to regularly review this Data Protection Policy in order to take note of the ways and means of protecting your personal data.
This Data Protection Policy was last modified on the date indicated above.

Contact

For any questions related to our Cookie Policy, you can contact us at gaming@greenmondayinc.com or by mail at GMGaming - Privacy – Nabweru, Uganda.