GDPR and CCPA Privacy Policy

Privacy Policy

This privacy policy explains what personal data we collect from you when you are using website available at TeppenTournament.com and how we use it.

1 Subject matter of data protection

Subject matter of data protection are personal data. According to Article 4 (1) GDPR, “personal data” means any information relating to an identified or identifiable natural person; this includes, for example, names or identification numbers.

2 Responsible controller/contact information

The data controller responsible for data processing via this platform is:

ReKTGlobal, LLC
1000 NC Music Factory Blvd, Suite B-9
Charlotte, NC 28206 USA
Phone Number: +1 (833) 367-7358 (833-FOR-REKT)
Contact Email: privacy@rektglobal.com

Representative within the EU (Art. 27 GDPR):

Hendrik Mokrusch
Koenigsallee 7
14193 Berlin, Germany
Contact Email: privacy-eu@rektglobal.com

If you have any questions or suggestions regarding data protection or if you want to exercise your rights, please do not hesitate to contact us.

3 Automated data collection

When accessing our platform, your device automatically transmits data for technical reasons. The following data is stored separately from other data that you may transmit to us: date and time of accessing our platform, shortened IP-address, browser type and version, operating system, URL of the previously visited platform (Referrer), amount of data sent.

These non-personal data are stored exclusively for technical reasons and are not linked to a specific person at any time.

4 Our Platform

The Teppen Tournament platform organizes various competitions and tournaments for users to participate in. When you use our platform, we process your personal data as necessary to provide you with the services requested according to our general terms and conditions at TeppenTournament.com/termsofservice.

4.1 Registration and requirements for use

You can only use our platform upon registration. The provision of certain personal data as indicated by the * in the registration form are mandatory. Based on how you intend to use our platform, this may include a username, your email address, your first/last name, the country you live in, your address and your date of birth.

If you do not provide the required data, you cannot register for our platform or use the platform as desired. The processing of your mandatory personal data is necessary to fulfill the registration contract, Article 6(1)(b) GDPR. The provision of further data is voluntary and not necessary for the registration. We collect this data to allow you to personalize your account and provide the best possible experience in participating in the competitions and tournaments, Article 6(1)(b) GDPR. After you have submitted the registration form and after we have confirmed your registration, you receive a link to confirm your registration. Only if you click on this link, you will have access to the platform. After registration, you may update your data or delete your date by cancelling your registration at any time via the user interface.

4.2 Voluntary information

In addition, you may provide the following voluntary information when registering or submitting your profile:

  • Photo or avatar
  • In-Game name
  • Nickname
  • Personal preferences (ex. favorite game, etc)

This information is voluntary and not necessary to register. Please note that this information may be publicly accessible according to your settings.

We collect this data in order to provide you with the corresponding functions of our platform, Art. 6(1)(b) GDPR.

You are not obliged to provide the above voluntary information. Without this data, however, we are not in a position to provide you with the corresponding functions of our platform and certain platform functionality may not properly work.

4.3 Community features

On our platform we offer various community functions with which you can interact with other users. You must provide a name (which does not have to be your real name), your e-mail address and your contribution.

Please note that your comments may be publicly accessible and that any personal information you post or provide on registration may be viewed by others depending on your settings. We cannot control how other users of our platform use this information. In particular, we cannot prevent unsolicited messages from being sent to you. Comments can be saved for an unlimited time. If at any time you wish to have any content removed, please send us an e-mail at the above address. Processing of any data entered in the context of the comment function is necessary to provide you with the comment function as intended, Art. 6(1)(b) GDPR. You are not obligated to provide us with this data, but without this data we are not able to provide you with the comment function. We also need your e-mail address in order to be able to contact you if there are any complaints about your comment.

4.4 Purchases and Payment Service Provider

The platform and all tournaments are free to participate in.

5 Contact form or e-mail inquiries

You can send us a message using the contact form. All data fields are necessary to process your inquiry. You can also send us an e-mail message or inquiry. If you do not provide this data, we may not be able to process your inquiry. You are free to provide further data on a voluntary basis. The processing of your personal data is necessary to deal with your inquiry, Article 6(1)(b) GDPR.

We store inquiries about agreements or of potential legal relevance during for up to twelve months. We store all other enquiries for a period of three months. After this period, your inquiries will be deleted unless we are obliged by law to retain them for a longer period.

The data is stored on the basis of our legitimate interest, the proper documentation of our business operations and the safeguarding of our legal positions (Art. 6(1)(f) GDPR). In the case of inquiries concerning agreements, data is stored for the purpose of initiating and fulfilling the respective contractual relationship (Art. 6(1)(b) GDPR) and, where applicable, for the fulfilment of legal obligations (Art. 6(1)(c) GDPR).

6 Newsletter and marketing messages

We may offer a newsletter. With our newsletter we inform you about new contributions which appear on our platform.

To subscribe to the newsletter, you can enter your e-mail address in the respective field on the platform. You will then receive a link to confirm your newsletter registration. Only if you click on this link you will be added to our mailing list and receive our newsletter. You can unsubscribe from the newsletter at any time. Each newsletter contains information on how you can cancel the newsletter with effect for the future. In this case, your personal data will be collected and processed in order to be able to offer you the newsletter as you subscribed to it, Article 6(1)(a) GDPR.

We can also send you a newsletter or other marketing messages concerning our services to the e-mail address you provided via registration on our platform based on our legitimate interest to market and advertise our services and products towards our customers, Article 6(1)(f) GDPR. Each newsletter contains information on how you can cancel the newsletter with effect for the future.

7 Cookies

We use so-called cookies in order to offer you a comprehensive range of functions and to make the use of our platform more convenient. Cookies are small files that are stored on your device by your browser. If you do not wish to use cookies, you can prevent the storage of cookies through your browser settings. Please note that the functionality and range of functions of our platform offer may be reduced as a result. By using the platform you agree, and consent, to receive cookies unless you manage your cookie setting options. Please also note that the use of information obtained by certain third party providers is also subject to their own privacy policies and may differ from ours.

Specifically, we use the following types of cookies (unless otherwise specified elsewhere in this privacy policy):

  • Session Cookies: These cookies are required for the technical operation of our platform and are automatically deleted after closing your browser.
  • Functionality Cookies: These Cookies allow the platform to remember choices you make (such as the language or the region you are in) and provide enhanced, more personalized features. These Cookies can also be used to remember changes you have made related to accessibility (e.g., text size, fonts) and customization. They may also be used to provide services you have asked for such as watching a video. The information these Cookies collect may be anonymized and they cannot track your browsing activity on other websites.
  • Consent cookie: This cookie saves your cookie settings for 1 (one) year.
  • Other cookies are technically necessary to enable you to move around our platform and use its features, such as accessing secure areas of the platform.
  • We only use marketing and tracking cookies in case you have given your consent to do so, Article 6(1)(a) GDPR.

The legal basis for the use of these cookies is Art. 6(1)(b) GDPR, insofar as these are necessary for the use of our website and the functions you have called up. Otherwise, we use cookies on the basis of the consent you have given us, Art. 6(1)(a) GDPR. You can withdraw your consent at any time via our Cookie Consent Management Tool – https://www.cookiebot.com/en/.

8 Google Analytics

If you give us your consent, we use Google Analytics, a web analysis service of Google LLC, 1600 Amphitheatre Pkwy Mountain View, California 94043, USA ("Google"). Google Analytics uses cookies to analyze how you use our platform. The information generated by the cookie about your use of our platform (including your shortened IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the platform, compiling reports on platform activity for platform operators and providing other services relating to your use of the platform and the Internet in general. Google may also transfer this information to third parties if this is required by law or if third parties process this data on behalf of Google.

For more information about how Google uses your information, please see Google's Privacy Statement: https://www.google.com/policies/privacy/.

Your data will be stored by Google Analytics for a period of 14 months. After this period the data will be deleted and only aggregated statistics will be stored.

There is no adequacy decision by the EU Commission for the USA. Therefore, we have concluded with Google the standard contractual clauses approved by the EU Commission in accordance with Art. 46 (2) c GDPR.

The use of Google Analytics is based on your consent (Art. 6(1)(a) GDPR).

You can withdraw your consent at any time via our Cookie Consent Management Tool – https://www.cookiebot.com/en/.

You can also disable Google Analytics using a browser add-on if you do not want the platform analysis to take place. You can download the add-on here: https://tools.google.com/dlpage/gaoptout?hl=e.

As an alternative, you can click here to disable Google Analytics.

9 Host provider

We operate our platform on servers of our host provider, Amazon Web Services (AWS), which processes personal data on our behalf. There is no adequacy decision by the EU Commission for the USA. Therefore, we have concluded with our host provider the standard contractual clauses approved by the EU Commission in accordance with Article 46 (2)(c) GDPR

Data is transmitted to our host provider on the basis of Article 28(1) GDPR.

10 Transfer of data to third parties

Unless otherwise set forth in this privacy policy or indicated by us, in principle, your personal data will only be passed on without your express prior consent in the following cases:

  • If it is necessary to discover or investigate any illegal use of our services or for prosecution, personal data will be forwarded to the law enforcement authorities and, if necessary, to injured third parties. However, this only happens if there are specific indications of illegal or abusive activity. A transfer may also take place if this serves to enforce terms of use or other agreements. We are also legally obliged to provide information to certain public authorities upon request. These are law enforcement authorities, authorities that prosecute fined administrative offenses and the tax authorities.

The transfer of this data is justified by our legitimate interest in combating abuse, prosecuting criminal offenses and securing, asserting and enforcing legal claims, Article 6(1)(f) GDPR or due to a legal obligation under Art. 6(1)(c) GDPR.

  • We pass on personal data to auditors, accounting service providers, lawyers, banks, tax advisors and similar bodies to the extent that this is necessary for the provision of our services (Art. 6(1)(b) GDPR) or the proper conduct of business (Art. 6(1)(f) GDPR) or if we are obliged to do so (Art. 6(1)(c) GDPR).
  • In the course of the further development of our business, the structure of ReKTGlobal, Inc may change due to a change in legal form, foundation, acquisition or sale of subsidiaries, parts of companies or components. In such transactions, customer information is shared with the part of the company to be transferred. Whenever personal data is shared with third parties to the extent described above, we ensure that this is done in accordance with this privacy policy and the relevant data protection laws.
  • The disclosure of personal data is justified by the fact that we have a legitimate interest in adapting our corporate form to the economic and legal circumstances and that your rights and interests in the protection of your personal data do not prevail, Art. 6(1)(f) GDPR

11 Content Delivery Networks

We have integrated services and content provided by third parties into our platform. In order to retrieve these services and contents, a transmission of your IP to the relevant third-party provider is usually required. In this regard, the programming language JavaScript is usually used. Thus, you can object to the data processing by deactivating JavaScript in your browser or installing a JavaScript blocker. Please note that the functionality and range of functions of our platform offer may be reduced as a result.

  • We use the video service YouTube, which is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Please note that this may also involve data processing by Google LLC based in the USA. Google’s privacy policy can be found here: https://policies.google.com/privacy?hl=en-GB&gl=uk. There is no adequacy decision by the EU Commission for the USA. Therefore, we have concluded with Google the standard data protection clauses approved by the EU Commission in accordance with Article 46 (2)(c) GDPR
  • We use the video service Twitch, which is provided by Twitch Interactive, Inc., 350 Bush Street, 2nd Floor, San Francisco, CA 94104, USA. The Twitch privacy policy can be found here: https://www.twitch.tv/p/legal/privacy-policy. There is no adequacy decision by the EU Commission for the USA. Therefore, we have concluded with Twitch the standard data protection clauses approved by the EU Commission in accordance with Article 46 (2)(c) GDPR

Any relevant data processing is necessary for the purposes of the legitimate interests in providing our users with the relevant content and features optimizing and operating our platform in an efficient way, Article 6(1)(f) GDPR.

12 Automated individual case decisions and measures for profiling

We do not use automated processing procedures to bring about a decision or profiling.

13 Erasure of your data

Unless otherwise stated, we delete or anonymize your personal data as soon as they are no longer required for the purposes for which we have collected or processed the respective personal data in accordance with this policy. As a rule, we store your personal data for the duration of the usage or contractual relationship via the platform plus a period of 7 days in which we store backup copies after erasure, unless this data is required longer for legal reasons or for criminal prosecution or to secure, assert or enforce legal claims.

If we are obliged to further retain personal for legal reasons (e.g., applicable tax law retention periods), it will be restricted in its processing. The data is then no longer available for other use.

Storage beyond the scope of the contractual relationship is based on our aforementioned legitimate interests pursuant to Art. 6(1)(f) GDPR or on our legal obligations, Art. 6(1)(c) GDPR.

14 Changes of purpose

Your personal data will only be processed for purposes other than those described if permitted by law or if you have consented to the changed purpose. In the event of further processing for purposes other than those for which the data was originally collected, we will inform you of these other purposes before further processing and provide you with all other relevant information.

15 Your rights as data subject

As a data subject, you have the following rights, which you can exercise by contacting us via one of the channels indicated above:

15.1 Right of access

You have the right to request information from us at any time about the personal data we have processed concerning you within the scope of Article 15 GDPR.

15.2 Right to rectification of inaccurate data

According to Article 16 GDPR you have the right to have us correct any personal data concerning you immediately if it is inaccurate.

15.3 Right to erasure

You have the right to have us delete personal data concerning you under the conditions described in Article 17 GDPR.

15.4 Right to restriction of processing

You have the right to have us restrict processing of your personal data in accordance with Article 18 GDPR

15.5 Right to data portability

You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format in accordance with Article 20 GDPR.

15.6 Right to object

You have the right to object on grounds relating to your particular situation at any time to processing of your personal data, which is based, inter alia, on Article 6(1)(e) or (f), according to Article 21 GDPR. We will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

15.7 Right to withdraw your consent

In the case of consent, you have the right to withdraw your consent at any time, Art. 7 (3) 1 GDPR. You can do this by contacting us via one of the channels indicated above or by any specific measure indicated above separately (e.g. via our Cookie Consent Management Tool – https://www.cookiebot.com/en/. The lawfulness of the processing carried out before your withdrawal is not affected by this.

15.8 Data processing when exercising your rights

When you exercise your rights, we only use the personal data provided by you in order to process your request and for accountability purposes. These processing activities rely on the legal basis of Article 6(1)(c) GDPR.

16 Right to lodge a complaint with a supervisory authority

You also have the right to lodge a complaint with a supervisory authority in the event of complaints. You can find an overview over data protection authorities in the EU here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

17 Amendments of our privacy policy

The current version of this privacy policy is available at all times at TeppenTournament.com/privacypolicy

18 Changes to our privacy policy

We may amend this privacy policy from time to time. Use of information we collect now is subject to the privacy policy in effect at the time such information is used. If we make major changes in the way we collect or use information, we will notify you by posting an announcement on the website and/or the platform. A user is bound by any changes to the privacy policy when he or she uses the website, services, or platform after such changes have been first posted. Should you have any question or concern, please write to teppen@greenlitcontent.com.

19 Children Under Thirteen

ReKTGlobal, Inc does not knowingly collect or store any personal information from children under thirteen (13) in the United States or under the relevant age threshold in other jurisdictions where the child is located. If you are under thirteen (13) years old in the United States, or under the relevant age threshold in the jurisdiction where you are located, you cannot use the website or platform without the permission of your parent or guardian.

However, we may collect technical information required for delivering the service and for the support of our internal operations from all users of our website and/or platform. If parents or guardians believe that we have unintentionally collected their children’s personal information or otherwise used their children’s personal information for another purpose, they may reach out to us at teppen@greenlitcontent.com. Parents should contact us immediately if they have any concerns.

20 For California Residents: CCPA Information

This privacy notice for California Residents supplements the information contained elsewhere in this privacy policy and applies solely to all visitors, users, and others who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

20.1 Rights and Choice

The CCPA provides consumers located in the state of California with certain rights regarding their Personal Information and data. The following section describes those rights and explains how to exercise them:

20.2 Access to Specific Information and Data Portability Rights

You have the right to request that ReKTGlobal, Inc disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (as described in the section “Exercising Access, Data Portability, and Deletion Rights”), we will disclose to you:

  • The categories of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting or selling that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • The specific pieces of Personal Information we collected about you (also called data portability request)
  • If we sold or disclose your Personal Information for a business purpose, two separate lists disclosing:
    • Sales, identifying the Personal Information categories that each category of recipient purchased, and
    • Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained

20.3 Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.

Any CCPA-permitted financial incentive we offer will reasonably relate to your value and contain written terms that describe the program’s material aspects.

20.4 Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at teppen@greenlitcontent.com.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You have the right to request that the company disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request we will disclose to you:

  • The categories of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting or selling that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • The specific pieces of Personal Information we collected about you (also called data portability request).
  • If we sold or disclose your Personal Information for a business purpose, two separate lists disclosing:
    • Sales, identifying the personal information categories that each category of recipient purchased, and
    • Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained

You may only make a verifiable consumer request for access of data portability twice within a twelve (12) month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

20.5 Information We Collect

Our Websites, emails (with your consent, where required by law), and other products, services and platforms collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, our websites, apps, emails, and other products, services and platforms may have collected the following categories of Personal Information from its consumers within the last twelve (12) months:

Category

Collected

A. Identifiers

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

NO

C. Protected classification characteristics under California or federal law

NO

D. Commercial information.

NO

E. Biometric information.

NO

F. Internet or other similar network activity.

NO

G. Geolocation data.

NO

H. Audio, electronic, visual, thermal, olfactory, or similar data.

NO

I. Professional or employment-related information.

NO

J. Education information.

NO

K. Inferences drawn from other Personal Information.

NO

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy.

20.6 Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a newsletter or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we or our third-party service providers will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product or service orders and requests.
  • To provide, support, personalize, and develop our websites, emails, and other products, services and platforms.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our responses.
  • To personalize your websites, apps, emails, or other product, service or platform experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, apps, emails, and other products, services and platforms.
  • To help maintain the safety, security, and integrity of our websites, apps, emails, and other products, services and platforms, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our websites, apps, emails, and other products, services and platforms.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the websites' assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by ReKTGlobal, Inc about our Website users is among the assets transferred.

ReKTGlobal, Inc will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

20.7 Sharing Personal Information

ReKTGlobal, Inc may disclose your Personal Information to a third-party for a business purpose or sell your Personal Information, subject to your right to opt-out of those sales (see the ‘Sales of Personal Information’ Section below). When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales (see the ‘Sales of Personal Information’ Section below).

We may share your Personal Information with the following categories of third parties:

  • Subsidiaries and affiliates.
  • Contractors and service providers.
  • Data aggregators.
  • Third parties with whom we partner to offer products and services to you.

20.8 Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, ReKTGlobal, Inc has disclosed the following categories of Personal Information for a business purpose:

  • Category A: Identifiers.

20.9 Sale of Personal Information

In the preceding twelve (12) months, ReKTGlobal, Inc has not sold any category of Personal Information collected through our ad-supported services.

Status: February 8, 2021