1 GamesCo Data Privacy Principles
As customers ourselves, we know that privacy is important to you and we strive to be as open and transparent as possible in how we serve you. We are committed to compliance with the Singapore Personal Data Protection Act 2012 and any other applicable data protection laws and have implemented additional measures to protect your personal data. Our core principles are:
(a) When and where we don’t need your data for legal, regulatory or operational reasons, we try to not collect it and we have shied away from collecting what other websites traditionally collect, to safeguard our and your privacy and anonymity wherever possible.
(b) We also strive to be transparent about what we collect and how it is used, wherever possible. We also want to give you control and allow customisation of the data we collect so that you can always tell us when we get things wrong and how to serve you better.
2 Your Personal Data
2.2 Examples of such Personal Data which you may provide us include (depending on the nature of your interaction with us):
(a) your telephone number(s), email address and any other information relating to you which you have provided us in any form you may have submitted to us, or in other forms of interaction with you;
(b) your in-game nicknames, account number, GamerTag, User ID, avatar and/or any other information that you provide and/or is later assigned to you and used to reference your user account;
(c) information about your use of our Services, including cookies, information about your domain name, IP addresses, and membership details; and
(d) your geo-location and behaviour information.
3 Collection of Personal Data
3.1 Generally, we collect your Personal Data in the following ways
(a) when you submit forms (online or otherwise) relating to any of our services, or submit any online queries;
(b) when you enter into any agreement or provide other documentation or information in respect of your interactions with us;
(c) when you use our services provided through online and other technology platforms, such as websites and applications, including when you interact with our services by searching, clicking and/or customising your preferences;
(d) when you interact with our staff, including customer service officers, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails;
(e) when you request that we contact you or request that you be included in an email or other mailing list;
(f) when you request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions and other initiatives;
(g) when we receive references from business partners and third parties, for example, where you have been referred by them;
(h) when your images are captured by us via CCTV cameras while you are within our property and/or premises, or via photographs or videos taken by us or our representatives when you attend our events;
(i) when you are contacted by, and respond to, our marketing representatives and customer service officers;
(j) when we seek information about you and receive your Personal Data in connection with your relationship with us, including for our services or job applications, for example, from business partners, public agencies, your ex-employer, referral intermediaries and the relevant authorities; and/or
(k) when you submit your Personal Data to us for any other reason.
3.2 If you provide us with any Personal Data relating to a third party (e.g. information of your dependent, spouse, children, friends and/or parents), by submitting such information to us, you represent and warrant that the collection, use and disclosure of that Personal Data to us, as well as the further processing of that Personal Data by us for the purposes set out below, is lawful, and you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
3.3 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with services you have requested.
4 Purposes for the Collection, Use and Disclosure of Personal Data
In general, we collect, use and disclose your Personal Data for the following purposes:
(a) to provide you with the services that you have requested;
(b) to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our services;
(c) to provide a higher degree of personalisation of the services to your needs based on your preferences and related to your activity on our Services;
(d) to help us review, develop, improve, manage the delivery of and to the extent this requires the use of Personal Data, enhance our services, including analysing customer behaviour and future customer needs, conducting market research, list processing and data analytics (including by requesting feedback from you or your participation in surveys);
(e) to communicate with you and respond to your queries, requests and complaints;
(f) to handle disputes and conduct and facilitate investigations and proceedings;
(g) to protect and enforce our contractual and legal rights and obligations;
(h) to prevent, detect and investigate crime, including fraud and money-laundering, and to analyse and manage other commercial risks;
(i) to manage the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
(j) to manage our infrastructure operations, administrative operations and business operations and to comply with internal policies and procedures;
(k) to organise, facilitate, and administer roadshows, tours, promotional events, contests and/or competitions;
(l) to comply with any contractual terms and conditions to which GamesCo is bound by;
(m) to commence, respond to, or act in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution);
(n) to monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
(o) to match any Personal Data held which relates to you for any of the purposes listed herein;
(p) to facilitate business asset transactions (which may extend to any merger, licensing, acquisition or asset sales);
(q) to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or
(r) purposes which are reasonably related to the aforesaid.
4.2 In addition, we may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
(a) If you use the Services:
(i) when you provide any Personal Data when using the Services;
(ii) to verify your personal particulars in relation to provision of the services which you may have requested for;
(iii) to communicate with you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to services offered to you and notifying you of service issues and unusual activity;
(iv) providing customer service and support;
(v) administering and processing your requests including creating and maintaining profiles of our members in our system database for administrative purposes (including but not limited to tracking your use of the Services);
(vi) personalising your experience on the Services and conducting market research, understanding and analysing customer behaviour, location, preferences and demographics in order to improve our service offerings;
(vii) if you use the Services, sending you notifications and facilitating the provision of our services to you; and/or
(viii) for purposes which are reasonably related to the aforesaid.
(b) If you are an employee, officer or owner of a vendor, contractor or other external service provider, or prospective vendor, prospective contractor, or other prospective external service provider of GamesCo:
(i) to conduct appropriate due diligence checks;
(ii) to evaluate your organisation's suitability as a vendor, contractor, and external service provider for GamesCo and to conduct background checks on you;
(iii) to create and maintain profiles of our vendors, contractors, and external service providers in our system databases;
(iv) to process and facilitate necessary actions and processes for the purposes of the work or engagement of said vendor, contractor, and external service provider;
(v) to process and facilitate payment of invoices and bills;
(vi) to respond to emergencies;
(vii) to communicate with you changes and development to our policies, terms and conditions and other administrative information;
(viii) for facilities management purposes (including but not limited to issuing visitor access passes and facilitating security clearance);
(ix) to communicate with your deployed staff, after award of contract, who are in our properties to carry out work or services, and for any emergency or/and security concerns; and
(x) for purposes which are reasonably related to the aforesaid.
4.3 Furthermore, where permitted under the Data Protection Laws, GamesCo may also collect, use and disclose your Personal Data for the following "Additional Purposes":
(a) taking or filming photographs and videos for corporate publicity or marketing purposes, and featuring your photographs and/or testimonials in our articles and publicity materials;
(b) providing or marketing services and benefits to you, including promotions, service upgrades, loyalty, reward and/or membership programmes (including event invitations, newsletters and marketing and promotional information to you pursuant to such membership programmes);
(c) organising roadshows, tours, campaigns and promotional or events and administering contests and competitions;
(d) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of services;
(e) sending you details of services, services updates and rewards, either to our customers generally, or which we have identified may be of interest to you;
(f) conducting market research, aggregating and analysing customer profiles and data to determine health-related patterns and trends, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you other services as well as special offers and marketing programmes which may be relevant to your preferences and profile; and/or
(g) purposes which are reasonably related to the aforesaid.
4.4 If you have provided us with your telephone number(s) and/or email and have indicated that you consent to receiving marketing or promotional information via your telephone number(s), then from time to time, GamesCo may contact you using such telephone number(s) (including via voice calls, text, fax or other means) with information about our services.
4.5 In relation to particular services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
4.6 You may withdraw your consent for receiving marketing or promotional materials/communication by contacting us using the contact details below, the preferences and notifications settings located in the Services (where applicable) and/or in such manner as may be prescribed by GamesCo from time to time.
4.7 Once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 calendar days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time.
4.8 Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the Services.
5 Disclosure of Personal Data
5.1 Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:
(a) amongst GamesCo and its related corporations or affiliates (including their respective staff);
(b) companies providing services relating to insurance or other service providers to GamesCo;
(c) agents, contractors, sub-contractors or third party service providers who provide operational services to GamesCo, such as courier services, telecommunications, information technology, payment, printing, billing, debt recovery, processing, technical services, transportation, training, market research, call centre, security, or other services to GamesCo;
(d) vendors or third party service providers and our marketing and business partners in connection with marketing promotions and services;
(e) our corporate clients;
(f) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);
(g) external banks, credit card companies, other financial institutions and their respective service providers;
(h) our professional advisers such as consultants, auditors and lawyers;
(i) relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or
(j) any other party to whom you authorise us to disclose your Personal Data to.
5.2 We may share information about you in aggregate or anonymised form, for example, we may want to know how long the average reader spends on our Services, or which pages or features get the most attention.
6 Keeping Your Personal Data Accurate and Up-To-Date
6.1 We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability to provide, or delays in providing you with services you have requested, or processing any requests and applications you may have made to us.
7 Transfers of Personal Data Outside of Singapore
Your personal data may be stored in external servers located overseas. In addition, as described above, in the course of our business operation needs, we may be required, from time to time, to transfer your personal data with and between our related corporations and/or organisations and their affiliates, and third party service providers, some of which may be located in countries outside of Singapore.
Cookies – Small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. Cookies allow a website to recognise a particular device or browser. There are several types of cookies:
- Session cookies expire at the end of your browser session and allow us to link your actions during that particular browser session.
- Persistent cookies are stored on your device in between browser sessions, allowing us to remember your preferences or actions across multiple sites.
- First-party cookies are set by the site you are visiting.
- Third-party cookies are set by a third party site separate from the site you are visiting.
Cookies can be disabled or removed by tools that are available in most commercial browsers. The preferences for each browser you use will need to be set separately and different browsers offer different functionality and options.
Web beacons – Small graphic images (also known as "pixel tags" or "clear GIFs") may be included on our sites and services. Web beacons typically work in conjunction with cookies to profile each unique user and user behaviour.
Similar technologies – Technologies that store information in your browser or device utilising local shared objects or local storage, such as flash cookies, HTML 5 cookies, and other web application software methods. These technologies can operate across all of your browsers.
We may use the terms "cookies" or "similar technologies" interchangeably in our policies to refer to all technologies that we may use to collect or store information in your browser or device or that collect information or assist in identifying you as a unique user in the manner described above.
8.3 We may employ cookies, web beacons and other technologies as follows:
(a) to collect information about how you access and use our Services;
(b) to identify your device for the following purposes:
(i) for the operation and the provision of our Services;
(ii) to temporarily allow you to carry information between pages or interfaces of our Services to avoid having to re-enter such information; and
(iii) to temporarily identify your device after you have logged in to a secure page on our Services in order for you to carry out certain actions;
(c) to enable us to improve our Services by tracking your access to and use of our Services, so as to gather statistics on new and repeat visitors to evaluate effectiveness;
(d) to enable us to better tailor our Services for you and make our Services more relevant to your interests;
(e) to store and remember your login and preferences in accessing and using our Services (for example, your choice of language and region) to avoid you having to re-enter such information when you return to our website and/or application;
(f) to maintain access controls for you to view privileged pages without seeking further permission from you (provided that no additional personal data is collected);
(g) to conduct, operate, facilitate or determine your eligibility to participate in any rewards or promotions relating to the use of our Services; and
(h) to provide online advertisements or offers on our Services which are most likely to interest you, limit the number of times you see an advertisement or offer, and to evaluate the effectiveness of our online marketing and advertising programs.
8.4 Some cookies we use are from third party companies to provide us with web analytics and intelligence about our Services. These companies collect information about your interaction with our Services. We use such information to compile statistics about visitors who interact with our Services, to gauge the effectiveness of our communications, and to provide more pertinent information to our visitors, customers and users.
8.5 We use the cookies of third party social networking platforms and websites to enable you to interact with these platforms and websites to share information about our websites through them (e.g. through "Like" or "Share" buttons or through comment boxes, etc.). The social networking platforms in question will have access and use the information in these cookies for their own purposes and we invite you to consult their respective privacy and cookie policies.
8.6 The Services and certain site features and services are available only through the use of these technologies. You are always free to block, delete, or disable these technologies if your browser so permits. However, if you decline cookies or other similar technologies, you may not be able to take advantage of the Services and certain site features or services tools. For more information on how you can block, delete, or disable these technologies, please review your browser settings.
9 Third-Party Sites
10 Contacting Us – Withdrawal of Consent, Access and Correction of your Personal Data
10.1 If you:
(c) would like to obtain access and make correction to your Personal Data records, please contact us as follows:
Method & Contact Particulars
Data Protection Officer
Digital Games International Pte. Ltd.
6 Raffles Boulevard
#03-308 Marina Square
Data Protection Officer
10.2 Please note that if your Personal Data has been provided to us by a third party (e.g. your employer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to GamesCo on your behalf.
10.3 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, GamesCo may not be in a position to continue to provide its services to you, or administer any contractual relationship in place, which in turn may also result in the termination of any agreements with GamesCo, and your being in breach of your contractual obligations or undertakings. GamesCo's legal rights and remedies in such event are expressly reserved.
11 Governing Law