What’s This Policy?

Honestly? It’s what our lawyers are making us do. It’s not like we don’t care about your privacy; we totally do. It’s important. It’s just we have to lay it out like they say, so this is it. This privacy policy covers your online digital experiences on various PvP.com digital properties. Right now, that includes the website located at PvP.com (“we,” “us,” “PvP,”) and a downloadable digital app. In the event we have another site (we don’t yet; why toy with perfection), this policy will also govern the use of those online locations that collect information (we call them our “Digital Properties”).
This policy may also cover information you provide to us through the mail if we are required to digitize that content or respond to you via email. Bear with us on the legal stuff. We’ll try to make it as pain free as possible.

If you were wondering, PvP is subject to the investigatory and enforcement powers of the Federal Trade Commission. Sounds cool, huh? OK, let’s do this.

PvP is One Big Worldwide Family

What we mean by that is we have one policy for everyone. So, everyone gets treated the same, even if where you live doesn’t require us to do so. Our policy is based upon US law and the EU General Data Protection Regulation, along with other regulations, and this policy applies to everyone, dig? Oh yeah, please don’t hang out here if you are in an embargoed country or otherwise reside in a place where sites such as these are not allowed.

PvP is a “Data Controller.”

A “controller” is a legal entity (that’s us!) which, alone or jointly with others, gets to decide the reason we collect your personal data. We also get to decide how that data gets processed. That’s on us! We engage others to help us process your data (you know, like maybe help upload a file or process a payment, or maintain security). Those companies are called “data processors,” and we tell them what to do. It’s not a God complex or anything; we just make sure anyone we use to help us manage our Digital Properties isn’t going to go buck wild with your personal information. We control it; they process it at our direction.

Just to be clear: Although we control PvP.com and the information we collect on our Digital Properties, you may be able to find links to other sites that have been posted by us or users (people like you) not owned or controlled by us. After all, it’s all about getting connected up in here. So, while we provide these links for your convenience, we don’t control and are not responsible for the privacy practices of sites you visit once you leave. Take your time and proceed with caution. Same with social media, BTdubs: while we maintain a presence on social media sites (like on the Facebook), we do not control the privacy policies of those sites, though we do make commercially reasonable efforts to abide by them.

Playing Your Part (get it? “Playing?”)

You can visit us whenever you want without providing any personal information, but you cannot do much except look at pretty pictures. In order to access the good stuff, you have to create an account, which means registering with us and becoming a user (we hate that term though, so we’re gonna call you a “Player,” playa). Once you’re a Player, you must agree to our rules. Kind of like living at home, but without having to take out the trash. If agreeing to our rules is harshing your mellow, you don’t have to go home, but you can’t stay here. We do require you agree to this policy and our terms of use (located here) if you want to hang out and by staying here, that constitutes your agreement.

What We Collect

You’ve gotten this far, and you still want to hang out? Cool. It’s fair to tell you what we collect when you register to become a Player, and use our Digital Properties:

Other stuff: we’ve listed the things we believe may represent personal data, but we may also collect non-personal information about the computer or device you’re using, log data from interacting with the platform, non-personal information relating to your logins, and so forth. So, basically, when you come to play, we grab the common and usual information you would expect (namely, what you give and information about what you do on the site). We also make take additional information we find about you, and then there’s that whole cookie thing (see below).

PvP has a “Legitimate Business Interest” in Retaining and Managing Your Personal Data

We don’t grab your personal data willy nilly. We use it for various things we believe relevant. If we hold on to it, it means we have a legitimate business interest in holding on to it.

Cookies. Not just for Dessert.

Yes, like virtually every platform on the interwebs, we use cookies. It’s how we help you navigate our site with ease. When you visit our Digital Properties, we send cookies to your computer or the mobile device you’re using to access us. A cookie is a small digital file that helps us recognize your device when you visit us, it helps you stay logged in to your account if you’ve created on and keeps you from having to constantly go back to the home page while you’re hanging out with us. If you want to reset your browser so that it refuses cookies, you can do so. Check out http://www.allaboutcookies.org/manage-cookies/index.html for how to manage your cookies and even refuse them. Note that some of the features on our Digital Sites will likely not function properly if you do.

So you are aware: most browsers automatically accept cookies. You have the right to accept or decline non-necessary cookies. To change your preferences, go to the advanced preferences section of your preferred browser. We’ll place a bar at the home page the first time you visit, and you can hit us up there.

Necessary Cookies

We may use "pixel tags" or “web beacons” (cookies with attitude), which are small graphic files that allow us to monitor the use of our websites. A pixel tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable email, we may use "format sensing" technology, which allows pixel tags to let us know whether you received and opened an email we sent to you. We only use these with your consent.

We may also use cookies that are designed to help us better understand you for advertising purposes or monitor the effectiveness of an ad banner or campaign or see where you go after you visit us. Some of these do not personally identify you; some do. For those that do, you have a total right to tell us to back off. That is, you are not required to accept cookies that track you over platforms. We sorta feel like if you’re going to get served ads (and you are, let’s face it, it’s the internet), you’d rather have more relevant content, but if you don’t want to get that close, you can request that we don’t track you. We also use Google Analytics to collect and analyze activity, trending actions, and information on our Digital Properties. Find out more about Google Analytics here www.google.com/policies/privacy/partners/. If you choose to, you can opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Oh, hey… our servers are located in the United States, so if you live somewhere else, we make commercially reasonable efforts to transfer your personal data consistent with GDPR or other regulatory frameworks that aim to safeguard your information.

What We Do with All of This

We retain your information to improve our Digital Properties and your experience as a threshold matter; that’s a legitimate business purpose. Then we “process” it in various ways; that’s also a legitimate business purpose. At a non-commercial level we use your information to Identify and authenticate a Player while in our Digital Properties; Use your gaming history (and combine it with other information) to improve our Digital Properties and make them more user-friendly; Maintain our Digital Properties, including performing internal tests and operations relating to security, fraud, and troubleshooting; Manage content offerings; Generally improve the services we provide on our Digital Properties; Send you necessary communications pertaining to game play, your status, information you’ve requested, information relating to your account, and information relating to activities you’ve engaged in on the Digital Properties that requires a response.

With your permission (yes, you get to opt in), we’ll also use your personal data for commercial purposes. For instances, we might use your information to Ship you products (digitally or actually); Send you targeting advertising based upon your preferences; Share your information with vendors or advertisers who are looking for people just like you. In short, we may use your information for commercial purposes, but we’ll only do so with your consent.

Sharing is Caring

OK, sharing isn’t always caring, but we do sometimes disclose personal data to third parties or the public, in the following situations: When you have already shared something in a public forum; When you have given us specific permission by opting into a contest, sweepstakes, or tournament in which the rules provide for sharing your information.

When you give us permission to let us share on other applications or websites that may integrate with our API (or vice versa); With subsidiaries and related entities; With marketing partners when we have your permission; With law enforcement or government authorities if we feel we have to share. For instance, if there are exigent circumstances that we believe put your or someone else in danger, or if we reasonably believe you are engaged in criminal activity. By the way, we’re not asking; we’re just doing it (within the confines of the law, of course);In aggregated form or anonymized form that does not identify you; If we are legally required to do so; If we reasonably believe disclosure and sharing of your information is required to protect the safety, rights, or security of PvP, related parties, the Digital Properties, or for a technical reason.

Don’t Worry. You Have Rights Too.

Not only do you get the fun that comes with being a member of the world’s best gaming community, but you also have a right to know what’s going on behind the scenes.

You have the right to obtain information about what data we have on you and where it went. You have the right to withdraw any consents you have given us. You can correct and even erase all personal data (one exception: we will retain certain information about you if you violate our terms so that you cannot get back on the site, or for safety, privacy, and other legitimate business purpose, dudes and dudettes: we wanna keep this place a troll-free zone).

You can know whether we’ve corrected or updated any personal data, and you can correct information we have if it’s incorrect (win-win). You can take your stored data with you (that is, you can port your information). You can lodge a complaint about us with a competent data protection authority (we’d prefer you contact us first, though. We’re very nice and can usually fix you right up!).

You have the right to be forgotten. That is, if you don’t come back and visit us within a reasonable amount of time (say, a year), and you are not receiving any updates or news letters from us at all, then we will automatically sundown your account, after a deletion notice sent to you goes unanswered. If you would like to revoke your consent to receiving commercial messages you have previously opted in to receive as the result of a promotion, you can use the unsubscribe link in any marketing email message, or reply “STOP” to any marketing text message you receive if you entered a promotion via text message. You may also send an e-mail to [email protected] that contains the email address or phone number you wish to revoke consent for marketing messages.

As we’ve noted, PvP uses third parties to process your personal data when it serves a legitimate business purpose. That’s legal mumbo jumbo to let us hire companies like web managers or production companies to help us process and maintain your data when it’s reasonably required. Our contracts with these company processors require them to comply with the terms and the intent of this privacy policy, and to make all commercially reasonable efforts to safeguard your information. In the event that one of these third parties violates privacy principles like those in here, including the EU and/or Swiss Privacy Shield principles, we will remain liable (basically, we’ll take the heat) under the principles unless it proves that it is not responsible for the event giving rise to the damage. We joke a bit, but we do take this stuff seriously.

Exercising Your Rights

You want the truth? You can handle the truth! Pursuant to your reasonable request, we will provide you or a third-party you specify (yes, some people have “people” to do this) with a list of all of your personal information that PvP has collected. Send us an email with the request and your account information. Also, if the email from which you are sending is not the same one you registered as a Player with, please include that in the email. We may follow up with you to determine the legitimacy of the request or ask you for more information in order to fulfill it. We’re thorough like that. Need the email address? Here it is: [email protected]

You can also use it to make corrections to our records of your personal data.

The Right to Be Forgotten.

Honestly, who would forget you? But what if you forget us? In short, we’ll keep your account open and your information as long as you have an active relationship with us, including if you have subscribed to a newsletter, or opted in to receive commercial content (like cool emails) from us, have visited the site while logged in, have ordered a product through our links (or through us if we decide to sell you something), participated in a promotion, or have affirmatively made requests of us that we, or our data processors (remember them?), are fulfilling. Hey, we’re hip; you can ghost. Once you have no more connection with us and have not logged in for twenty-four (24) months after that relationship ends, we’ll delete your data and close your account. We’ll do it earlier if you specifically request we delete your information prior to the expiration of that period. Also, if PvP determines it no longer requires your information for the legitimate purposes for which it was collected, we’ll also delete that.

If you would like us to delete all of your personal information and/or remove your name and address from promotional lists (including any personal information gathered by our service providers) and place your name on our “do not contact” list, contact our Data Privacy Team at [email protected] to tell us to close your account, and request that you be placed on our “do not contact” list. Please note that because names may be similar, you must include in your request all associated email addresses and phone numbers (if any) that you wish to be removed in the body of the email. We reserve the right to contact you for administrative purposes to request more information in order to assist us in deleting your content. We will make commercially reasonable efforts to delete your information within thirty (30) days from our active files, provided, however, that we may retain—for legal compliance purposes only—your request and associated email in a hashed format so that we do not inadvertently restore your information to our database (also, that fraud thing).

We work hard, but we’re not robots; we review your requests manually. Your request may take up to five (5) days. You may also request that we stop processing your information without deleting it, and we will comply within ten (10) days of receipt of such a request. What’s the difference? Well, if you tell us to shut it all down, you’ve got no more account, you’ve got nothing. But if you tell us to stop processing your data, your account goes dormant (and you can’t hang out), but we can restore it for you later. Totally your call.

Just to be clear though, and notwithstanding the above, PvP will retain your information indefinitely if it believes in good faith that it has a legal obligation to do so.

Do-Not-Track Signal

The Do-Not-Track Signal (DNT) is used by some web browsers to automatically request that a web application disable site tracking. Because the DNT often does not reflect the actual preferences of an individual consumer, our website does not respond to the DNT. Instead, and in order to allow you to personalize your experience with our Digital Properties, you can opt out and in to tracking as we’ve described above.

Security

We said it above, and it’s still true: no data transmission over the Internet can be guaranteed to be 100% secure. While we strive to protect your non-public personal information, we cannot guarantee the security of any information you transmit to us or receive from us while it is in transit. Once we receive your personal information, we maintain physical, electronic, and procedural safeguards to protect it. If a data breach occurs, we will notify you and the proper EEA authority (if required) within seventy-two (72) hours (if reasonably feasible).

You mad, boo? How to lodge a complaint.

Dispute Resolution

We are happy to answer questions or clarify our policy. Just ask. We really hope we can resolve all your questions and concerns about privacy with an email, and our track record is excellent. Even if it takes a few communications, we usually get there. Here’s the levels:

Step 1 (email our team):

If you have an inquiry or complaint regarding PvP, and whether we have violated our obligations to you under this Privacy Policy, or if you are an EU, UK or Swiss resident with an inquiry or complaint regarding whether PvP has violated its obligations under the Privacy Shield Principles as to you (your “Complaint”), you should first contact our Data Privacy Team by email to [email protected]. We will acknowledge your Complaint within forty-eight (48) hours, and respond to your complaint within forty-five (45) days. We may ask that you provide additional information and/or request a one-on-one discussion or conference.

Step 2:

If you have a complaint left unresolved by all available recourse mechanisms, you may invoke binding arbitration. For additional information go here: www.privacyshield.gov/article?id=How-to-Submit-a-Complaint

Ch-ch-ch Changes.

Things change. Growth is good. Clarification is better We reserve the right, at our sole discretion, to change, modify, add, or remove any portion of this Privacy Policy, in whole or in part, at any time.

Modification of changes in the Agreement will be disseminated via our Digital Properties, including posting on our website at www.pvp.com/privacy. By using this our Digital Properties, you agree to be bound by any such revisions and should therefore periodically visit the page to determine the then current terms of use to which you are bound.