PRIVACY POLICY

Last updated on 02.02.2022


  1. Scope

    TKNZ is a service provided by TKNZ Ltd. (hereinafter also referred to as "Provider", "we", "us", or "our") and this privacy notice (hereinafter also "Policy") describes the collection and processing of personal data on the website https://www.tknz.gg  (hereinafter referred to as "Website" or "Platform"). For the purpose of this Policy "NFT" shall have the meaning of a non-fungible token which is stored on a blockchain (such as the Flow blockchain) and which is linked to certain data through the mediation of a smart contract.


    The protection of personal data has the highest priority for us. This Policy outlines how we collect and process data about you when you visit the Website, when you sign up for an account or when you conduct business with us. Please note that some of the data processing activities may be performed in joint controllership with one or more vendors on our Platform, as described in the relevant section further down. In such cases, please refer to the relevant vendor profile available on the Platform to learn about the joint controller's details.


  2. General information about data processing

    1. Purposes of processing

      We process personal data of users if this is necessary to provide a functional Platform, our contents and services and to close or perform contracts with users.


    2. Legal basis for the processing of personal data

      Most often we process personal data according to one of the following legal bases:


      • Consent

        Whenever we collect the data subject's consent to the processing of personal data, Art. 6 para. 1 a EU General Data Protection Regulation (GDPR) serves as the legal basis.


      • Legal obligation

        If the processing of personal data is necessary for compliance with a legal obligation which the Controller is subject to, Art. 6 para. 1 c GDPR serves as the legal basis.


      • Contract or pre-contractual measures

        If the processing of personal data is necessary for the performance of a contract to which the data subject is party, Art. 6 para. 1 b GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.


      • Legitimate interests

        If processing is necessary for the purposes of the legitimate interests pursued by the Controller or a third party and if such interests are not overridden by the interests, fundamental rights and freedoms of the data subject, Art. 6 para. 1 f GDPR serves as the legal basis. Unless otherwise specified within this privacy notice, the processing of your personal data is necessary for the performance of a contract with you or in the framework of pre-contractual measures, which take place at your request, and the legal basis for processing is therefore art. 6 para. 1 b GDPR.


    3. Data erasure and retention time

      In principle and unless otherwise stated, your personal data will only be stored until the purpose of the collection and storage is achieved. If the storage is based on your consent, personal data can be stored as long as you do not revoke such consent. Furthermore, data may be stored if it is required by European or national legal provisions, laws or regulations which we are subject to. Personal data will be blocked or deleted if the retention period set forth by any such regulations expires, unless further storage is necessary for the conclusion or fulfilment of a contract.


      You may request that we delete your personal data by submitting an email to us at team@tknz.gg and including the following text “I would like to have my personal data deleted” as a subject of your message. We will verify that you have access to that email and delete the personal data associated with your email address. You may expect us to respond to your request within 30 days of our receipt of verification of the request.


    4. Transfer to third countries

      Unless otherwise stated, all data processing operations take place within the UK, the EU or the EEA countries. Data processing operations carried out by third-party providers established outside the mentioned geographical area may be carried out in part or in full in the countries the respective providers are based in, in accordance with the relevant and applicable data protection regulations. A transfer of personal data outside the UK, the EU or the EEA shall only take place on the basis of on an adequacy decision of the European Commission, including the adequacy decision regarding the EU-US Privacy Shield, or subject to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. A list of current adequacy decisions is available on the European Commission's website. Further information about the EU-US Privacy Shield and a list of participating data recipients can be found on the website of the US Department of Commerce.


    5. Processing data of California residents

      If you are a resident of the State of California, USA, you have rights under the California Consumer Privacy Act ("CCPA"). Herewith we use the term "sell" as defined in the CCPA. We don't sell your personal information. According to the CCPA you have the right to request information about the use of your personal data over the past 12 months and in particular: categories of personal data that we have collected about you and the sources from which that personal data was collected; the business or commercial purpose for collecting your personal data; the third parties with whom we have shared your personal data. You also have the right to request deletion of the personal data we have collected about you.


  3. Processing of personal data in general

    Regardless of whether you take advantage of any of the Website's features - such as the registration to receive notifications - we automatically collect data about your use of the Website. This includes in particular the accessed URL, access date and time, transferred data volume, http status code of the access reply, web browser type and operating system, HTTP referrer, as well as IP address. This information is not associated with your person. We collect and process such data to ensure Website operation and availability. In addition, it is used to analyze, store and evaluate information about user behavior in an anonymous form and to continuously improve and further develop our service. We only store your IP address in the log files for a limited period of time, if this is necessary for security purposes. These purposes constitute our legitimate interest, which justifies data processing pursuant to art. 6 par. 1 lit. f) GDPR.


  4. Data processing when registering to receive notifications

    When registering to receive notifications, we store the following data: first and last name, e-mail address, favorite esport, favorite esports player/team.


  5. Personal data you freely upload

    • Personal data processed when contacting us

      If you submit a support request to us via the Platform, we will only collect such data and information that you will provide when describing the reason for your request. The provision of personal data is not required to this end. Should any personal data be provided, it will only be used to process your request and reply to it. If you contact us via the contact form available on our website, you will be required to provide the following personal data: name, e-mail address. This information will only be used to process your inquiry and reply to it.


    • Personal data processed in connection with surveys, polls and quizzes

      Whenever you participate in polls, surveys or quizzes as performed from time to time via our Website, we'll collect various personal data referring to you on an entirely voluntary basis. We will inform you in connection with each specific circumstance, what personal data are affected and for which purposes they are being collected. Unless otherwise specified, the processing of personal data described in this section takes place within the framework or in preparation of a contract with us, according to art. 6 par. 1b GDPR. From time to time, we may, however, request your consent to perform processing activities not directly linked to a contract with us. In such cases we will ask for your consent according to art. 6 par. 1a GDPR.


  6. Data Processors

    In order to provide our services, we may cooperate with selected third-party providers who process data on our behalf ("Processors"). This may for instance be the case whenever we need to send e-mail notifications to users for contractual purposes. Such e-mail could be managed and sent out via a third-party service. Similarly, in case the service is provided against a fee, payments shall be processed through one of the Processors we cooperate with. Payment data shall therefore be directly collected and processed by the selected payment service provider, that will then inform us about the payment status. We do not collect or store any personal data regarding payment methods. Furthermore, we cooperate with processors to handle logistics and fulfilment processes, as well as to operate and maintain our infrastructure. As far as legally required, we have entered into agreements pursuant to art. 28 GDPR with Processors, including payment service providers, processing your personal data on our behalf.


  7. Processing in compliance with a legal obligation

    Please note that, in addition to what is specified in this privacy notice, your data may be processed in compliance with legal obligations to which we or our joint controllers are subject to. For instance, we may be obliged to store your data for a legally determined period to comply with tax law provisions. Please contact us if you want to learn further details about such processing activities. In such cases the legal basis of the processing is art. 6 par. 1c GDPR.


  8. Use of Trackers

    1. Description and scope of data processing

      In order to improve user experience of our Website and to enable selected functions, we implement cookies or other trackers (hereinafter jointly referred to as "Cookies") on various pages. These are small data sets being stored on your device. Some of the Cookies we use expire after the end of the browser session, i.e., after closing your browser (so-called session Cookies). Other Cookies remain on your device and enable us or our partner companies to recognize your browser or device on your next visit (persistent Cookies). You can set your browser preferences in order to be notified about the setting of Cookies and decide individually about accepting or refusing them in certain cases or generally. You can also manually delete Cookies from your device at any time. Failure to accept Cookies may result in minor limitations in our service's functionalities. Cookies are stored on the user's computer and from there transmitted to our site. Therefore, you as a user have full control over the use of Cookies. You can deactivate or restrict the transmission of Cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If Cookies are deactivated for our Website, it may no longer be possible to use all functions of the Website in full. You can also manage your cookie preferences via recognized third-party services such as https://www.youronlinechoices.eu/ (if you're based in the EU).


    2. Strictly necessary Cookies

      Some of the Cookies we use are strictly necessary to allow us to deliver the service you requested or to operate our Website and Platform. Some elements of our Website require that your browser be identified after page changes. Such technical Cookies may collect personal information about you, such IP address, log-in information, etc. The strictly necessary Cookies we implement have a lifetime that ranges between the duration of a browsing session ("session Cookies") and 12 months. The processing of personal data through strictly necessary cookies is art. 6 par. 1f GDPR. In case such cookies are necessary as a pre-contractual measure or for performing a contract with you, the legal basis is art. 6 par. 1b GDPR.


    3. Other Cookies

      • Google Analytics

        We implement "Google Analytics". Google Analytics is a web analysis service provided by Google Inc. The information generated by the Google Analytics Cookie about your use of our Website is generally transmitted to and stored by Google on servers in the United States. IP anonymization has been activated on our Website: this means that the IP address of users based within the European Union or the European Economic Area are abridged, and therefore anonymized, before being transferred abroad. Only in exceptional cases is the unabridged IP address transferred to a Google servers in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the Website, to draft reports about Website activity and to provide us with other services relating to Website and Internet use. The IP address transmitted by your browser in the context of Google Analytics is not put in relation with other Google data. You may object to the use of Cookies by selecting the appropriate settings on your browser, however please note that doing so may result in limited functionality of this Website. You can also prevent Google from collecting the data generated by the Cookie and relating to your use of the Website (including your IP address) and processing this data by installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. To find out further information about how Google handles personal data, please refer to Google's privacy policy: https://policies.google.com/privacy?hl=en.


  9. Promotional e-mail messages

    You can subscribe to our newsletter by entering your e-mail address in the respective form. You will then receive an automatic confirmation e-mail to the address you entered, which contains a link. The registration process is only completed once you confirm it by navigating to that link. We use your email address to send you promotional content and offers about our own services. The data will not be passed on to third parties. You can withdraw your consent to receive newsletters at any time without stating reasons by following the instruction provided in each newsletter sent, or by sending us an unambiguous notice at team@tknz.gg. We will inform you about the right to withdraw your consent upon subscription to the newsletter service and within each newsletter sent.


  10. Data Subjects' rights

    As a data subject, you have the following rights pursuant to the GDPR:


    • Your right of access - You have the right to ask us for copies of your personal information.
    • Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
    • Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances.
    • Your right to notification - If you have exercised your right to have the Controller rectify, erase or limit the processing, the Controller shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data concerning you have been disclosed, unless this proves impossible or involves disproportionate effort. You have the right to be informed about those recipients.
    • Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances. Please find further details in the box below this section.
    • Your right to withdraw consent - You have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
    • Your right to data portability - You have the right to ask that we transfer the information you gave us to another organization, or to you, in certain circumstances.
    • You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
    • Your right to file a complaint. You can also complain to a data protection authority if you do not agree on how we have used your data.
    • You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions. The Controller shall no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time without giving reasons to the processing of the personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

    11. Please reach out to us at the contact details indicated in this Policy if you wish to make a request.


  11. Amendments to this privacy notice

    This Policy may be amended from time to time at our sole discretion or due to changes in legislation. We will be notifying you of any change to this Policy by uploading the amended Policy on our Website. The date of the latest edition of the Policy is stated at the beginning of this Policy. It is your responsibility to visit our Website from time to time and check for changes in this Policy.


    If the change to the privacy notice only affects the use of data in a general form and does not affect the use of data within the scope of a user account, the new privacy notice shall apply from the date of its update on the Website. A change of the privacy notice, which refers to the use of the data already collected and stored in your user account shall only take place if this is reasonably acceptable for you. If and to the extent that changes to the privacy notice reflect on the use of data already collected and stored in your user account, we will notify you in good time via e-mail, on our Website, or in any other suitable way. You have the right to object to the new privacy notice within six weeks of receiving the notification. In the event of an objection, we reserve the right to delete your user account. If no objection is raised, the amended privacy notice shall become effective for you. We will inform you about your right to object and about the consequences thereof in the amendment notice.


  12. Disclaimers

    Notwithstanding anything to the contrary which is stated in this Policy, we cannot alter nor delete any piece of information that is stored on a blockchain, e.g., the Flow blockchain, as we do not have custody nor control over any blockchains. The information stored on the blockchain may include data about your transactions related to your blockchain address and the NFTs stored at that address.


    Some of the features of the Platform will be available 3 (three) months post-launch hence some categories of data will not be collected and/or processed within this timeframe.


  13. Contact us

    Should you have a privacy concern, question or would you like to place a complaint, please contact our Data Protection Officer, so that you can always reach out at: team@tknz.gg.


    Unless otherwise stated we are acting as a Controller for personal data we collect via our Platform in accordance with the relevant data protection legislation. TKNZ Ltd is registered under company number 13290098 in the United Kingdom with address: 27 Broomfield Road, Addlestone, KT15 3BN.