Global Creator Hub (GCH)

Privacy Policy

Last Updated: August 16th, 2018

SUMMARY

What information do we collect about you?

We collect information when you set up your account for the Platform. If you set up an account on the Platform, we collect your email address, password, country and user name. More Information  

How will we use the information about you?

We use your information to allow you to access and use the Platform Services. We use your information to create and verify your account, allow you to manage your account and to support and improve the Platform Services. More Information  

Who do we share your information with?

We use third parties for support services, such as servers for hosting the Platform. We use these third parties services solely to process or store your information for the purposes described in this policy. We also share your information with our related group companies and as required by law. More Information  

Where do we process your information?

Your data is processed in Canada, Hong Kong, the United States and the People"s Republic of China (excluding Taiwan, Hong Kong and Macau) (" PRC"). Our and our third parties" support teams are located in our offices around the world (including the United States and the PRC). The Platform is hosted on servers located in the United States and Hong Kong. More Information  

How long do we keep hold of your information?

We generally retain your information for the Platform Services for the period during which you maintain an account. We delete certain information earlier at your request, and in accordance with local law. More Information  

How can I exercise my rights over my information?

You may have rights to access, receive copy of, or delete, your data or restrict or object to our processing of, your data. More Information  

Dispute Resolution

If you have any concerns or complaints, please contact us here   .

How will we notify you of changes?

If there are any significant changes to this privacy policy, we will notify you on the Platform. More Information   .

Contact Information

Data Controller : Proxima Beta Pte. Limited Email: GCH_DPO@proximabeta.com

EU Representative : Tencent International Service Europe B.V . Email: eudataprotection@tencent.com

INTRODUCTION

This privacy policy informs you of your choices and our practices regarding any personal information you provide to us. Your use of the Global Creator Hub (GCH) platform (the " Platform") involves the collection and use of your personal information. It is important for you to understand how this happens and how you may control it.

W hen you contract to use the Platform and any services available on the Platform (the " Platform Services"), you accept our rules and policies regarding your personal information and you expressly consent to us collecting, processing, using and storing your personal information, as described in this policy.

 

You acknowledge that you have read and understood this privacy policy . If you do not agree with this privacy policy, you must not use the Platform Services.

 

Proxima Beta Pte. Limited (" Proxima Beta", " we" or " us") is a company registered in Singapore with its office located at 10 Anson Road, #21-07 International Plaza, Singapore (079903). Our representative in the EU for the purpose of EU data protection laws is Tencent International Service Europe B.V., a company registered in the Netherlands. Their registered address is 26.04 on the 26th floor of Amstelplein 54, 1096 BC Amsterdam, the Netherlands and can be contacted at eudataprotection@tencent.com. Our data protection officer can be contacted at GCH_DPO@proximabeta.com. The data controller for the purpose of EU data protection laws is Proxima Beta Pte. Limited.

If you have any comments, questions or complaints regarding the processing of your personal information, you can contact us at: GCH_Support@proximabeta.com .

SECTION 1: WHERE WE ARE A DATA CONTROLLER

The Types of Personal Information We Use

This section describes the different types of personal information we collect and how we collect it. We will collect and use the following information about you:

"          Information you give us.  You give us information about you when you register for the Platform (including your user name, email address, password and country). You also give us information when you participate in various tasks on the Platform, such as social media information (including social media user name, follower count and other details about the content uploaded), game information and survey information.

"          Information we collect about you. We automatically collect certain data from you when you use the Platform, including information regarding your use of the Platform, such as requests to load web pages of an Internet site (" Page Views") and number of times a uniquely identified client (usually a combination of a machine and a browser) has generated Page Views or hits within a defined time period (" Unique Views"). We also track the number of users who choose to delete their accounts.

Cookies

We use cookies and other similar technologies (e.g. log files and pixel tags) (" Cookies") to enhance your experience using the Platform Services. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the web browser to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Platform Services may be unable to operate as designed.

For more information about our Cookies policy, click here   .

Children

Our Service is not intended for children. All users under the age of 16 are prohibited from using the Service for any purpose.

How We Use Your Personal Information

We will use the information in the following ways and in accordance with the following legal bases:

Personal Information

Use

Legal Basis for Processing (EEA)

Platform

Account Creation Information

"          email address

"          password

"          country

"          user name

"          language (only if you choose to link your social media account to your Platform account)

 

We use this information to:

"          create your account for the Platform in accordance with your request;

"          prevent account fraud;

"          notify you regarding changes in account activity (account activation, password reset, account deletion);

"          update you on new features or tasks on the Platform; and

"          provide answers to your queries.

Necessary to perform our contract with you to
provide the Platform
Services.

GCH Data

"          Login Details (email address, password)

"          Open ID of the relevant games

"          Discord ID (Optional)

We use this information to allow you to access the Platform Services.

"          It is necessary to collect login details to enable you to log in to the Platform and reset your password.

"          It is necessary to collect your Open ID to give you in-game rewards for games that you play.

Necessary to perform our contract with you to
provide the Platform
Services.

Task Statistics (participation rate, completion rate)

We use this information to provide you with feedback and information about your activity and progress on the Platform.

Necessary to perform our contract with you to
provide the Platform
Services.

Social Media Information (if you choose to provide information regarding at least one channel of social media in order to
participate in certain tasks on the Platform):

"          Facebook: social media user name, number of followers, content of posts (text, gif, videos), view count of posts, number of posts

"          YouTube, Twitch: social media user name, channel ID, follower count, details of
videos uploaded by user (number of videos, title,
duration, view count)

If you agree to participate in a task that requires you to use a social
media account, we use this
information to allow you to access the task on the Platform.

Necessary to perform our contract with you to provide the Platform Services.

Game Information (if you choose to provide information regarding one or more of games): Open ID or Character ID, location, game statistics

To view the games featured on the Platform, please click here   .

We use this information to enable you to be awarded in-game
rewards for completion of tasks on the Platform.

Necessary to perform our contract with you to provide the Platform Services.

Survey Information -- content varies depends on purpose of the survey (optional)

If you agree to participate in a survey run by us, we use this
information to improve our services.

We collect this
information with your consent.

Log Data (Page Views, Unique Views, user log activity (including when the GCH account was registered and activated, and when social media account was linked to the GCH account)

We use this information to:

"          improve our services;

"          provide support to you in the event of errors or
failures experienced on the Platform.

Necessary to perform our contract with you to
provide the Platform and retain your record of
progress.

Customer Support Ticket ID & User Communications with
Support

We use this information to:

"          improve our services;

"          provide troubleshooting, such as addressing and
remediating technical
issues and bugs.

Necessary to perform our contract with you to
provide and support the Platform.

 

How We Store and Share Your Personal Information                                    

In order to perform our contract with you, your personal information will be accessible from and will be processed in:

"          Canada;

"          the United States;

"          Hong Kong; and

"          the People"s Republic of China (excluding Taiwan, Hong Kong and Macau) (" PRC").

We share your personal information with selected third parties in and outside your country, including:

"          third parties that provide services in support of the Platform, including:

o    providers of customer support, for the purpose of processing support ticket ID and support communications; and

o    providers of cloud services that processes information identified in this policy on their servers for the purpose of providing the Platform Services.

"          related group companies with whom we share your personal information to operate the
Platform Services.

"          law enforcement agencies, public authorities or other judicial bodies and organisations . We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

o    comply with a legal obligation, process or request;

o    enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof;

o    detect, prevent or otherwise address security, fraud or technical issues; or

o    protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection); and

"          a third party that acquires all or substantially all of us or our business. We will disclose information to a third party in the event that we sell or buy any business or undergo a merger, in which case we will disclose your data to the prospective buyer of such business. We will also disclose information to a third party if we sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. Our group companies have information security and access policies that limit access to our systems and technology. We also protect data through the use of technological protection measures such as encryption. Your personal information will remain subject to our technical and
organisational controls and our policies and procedures (including this Privacy Policy).

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our services; any transmission of your information is at your own risk.

Data Retention

We will retain your personal information as described below (except if otherwise required to be
retained by applicable law).

Personal Information

Retention Policy

Platform

Account Creation Information

Stored for the lifetime of your use of the Platform (i.e. until account deletion in accordance with your request) and then for 7 days.

Log Data 

GCH Data

Task Statistics

Social Media Information

Game Information

Survey Information

Stored for 6 months after the survey is completed, or within 30 days of a lawful request from you for the erasure of such data (see the Erasure section of this privacy policy).

Customer Support Ticket ID & User Communications with Support

Stored until deletion within 30 days of a lawful request from you for the erasure of such data (see the Erasure section of this privacy policy).

 

Personal information is kept until the end of its life cycle (as set out in the retention policy above). When destroying personal information, measures will be taken to make the personal information irrecoverable or irreproducible, and electronic files which contain personal information will be deleted permanently using a technical method which makes the files irreproducible.

In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including for the purposes as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle (as set out in the retention policy above), we will destroy your personal information in accordance with local laws).

Your Rights

This section ("Your Rights") applies to users that are located in the European Economic Area only.

You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be
extended by a further two months in certain circumstances). To exercise any of your rights, please
contact us at GCH_DPO@proximabeta.com.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your Platform account (as applicable). If you believe we hold any other personal
information about you, please contact us at GCH_DPO@proximabeta.com.

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent (e.g., survey information ) or pursuant to our contract with you (e.g., email address), as described in the section " How We Use Your Personal Information ". You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party. 

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another"s rights (e.g., where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction

You have the right to correct any personal information held about you that is inaccurate. You can access the personal information you have made available as part of your account by logging into your Platform account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at GCH_DPO@proximabeta.com. 

Erasure

You can delete your account, or remove certain personal information, by logging into your Platform account. If there is any other personal information you believe we process that you would like us to erase, please contact us at GCH_DPO@proximabeta.com.

You may request that we erase the personal information we hold about you in the following circumstances:

"          you believe that it is no longer necessary for us to hold such personal information; or

"          you believe the personal information we hold about you is being unlawfully processed by us.

You can also exercise your right to restrict our processing of your personal information (as described below) whilst we consider your request.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case.  Where you have requested that we erase personal information that has been made available publicly on the Platform Services and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.  

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (e.g., for the defence of legal claims or for another"s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.  

You may request we stop processing and just store the personal information we hold about you where:

"          you believe the personal information is not accurate for the period it takes for us to verify whether it is accurate;

"          you wish to erase the personal information as the processing we are doing is unlawful but you want us to retain the personal information but just store it instead; or 

"          you wish to erase the personal information as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims. 

Objection

You have the right to object to our processing of personal information about you. We will consider your request in other circumstances as detailed below by contacting us at
GCH_DPO@proximabeta.com
.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at GCH_DPO@proximabeta.com.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (such as when we temporarily suspend Platform access for maintenance , or security, privacy or administrative-related communications ). You may not opt-out of these service-related announcements, which are not promotional in nature. 

Contact & Complaints

Questions, comments and requests regarding this policy are welcomed and should be addressed to GCH_Support@proximabeta.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at GCH_DPO@proximabeta.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.

Changes

If we make any material changes to this policy, we will post the updated policy here and notify our users on the Platform. Please check this page frequently to see any updates or changes to this policy.