LAST UPDATED: 12 NOVEMBER 2020
We at UDP Romania (“we” or “our” or “us”) want to make sure all the personal information we have collected about you is safe and secure whether we collect it through our website at www.udpromania.ro (“Site”) or from you via other electronic means (such as email or social media platforms) or in-person at our events. This notice sets out our commitments to you, in compliance with and beyond the General Data Protection Regulation (commonly known as the GDPR) and explains how we collect, store and use your personal information.
Collecting your information
Most of our pages on our Site can be accessed without giving us your personal information. If, however, you:
- Sign up to receive our newsletter (a “Subscriber”), we’ll ask you for your email address;
- Enter one of our giveaways or competitions (including the giveaways we run on behalf of our partners/sponsors), we’ll ask you for your name, email address, phone number and delivery address (a “Giveaway Entrant”);
- Commence or complete the purchase of products from our online shop (either via shop.udpromania.ro, or using our tablet at an Event (see below)), we’ll ask for your name, email address and delivery address, and we may need to ask for a copy of your ID (a “Customer”);
If at an organised event, you sign up to receive our newsletter, we’ll ask for you for your name and email address (also a “Subscriber”).
If you engage with us to provide a temporary service (i.e. you are a contractor, a freelancer, an influencer but you are not an employee or a consultant), we might ask you for your name, nickname, social handle(s), gaming tags, occupation, phone number, email address, home address, bank details, your dietary requirements or other health matters (a “Freelancer”).
If you express an interest in investing in UDP ROmania (whether directly through a sign up form, or by contacting UDP personnel directly or through a platform or intermediary), we might ask you for your name, email address, phone number and age (“Investor”). By expressing your interest in such an investment, you acknowledge that investments of this nature carry risks to your capital – please invest aware.
SPONSOR OR OTHER
If you are an individual that works at one of our sponsors or another organisation that we deal with, we’ll ask you for your name, email address and telephone number (“Others”).
How do we use your information?
|What do we use your information for?||What type of information do we use?||What reason do we have to use it (this is the boring legal bit…)|
|To send you information which you have asked us to send to you.||Name and email address||Only where you have told us you want to receive this type of information.
If you are under the age of 13 your parent or guardian must have given their consent to allow us to send you marketing messages.
|To send you other information which we think you might like such as details about product sales, competitions and events we are running, offers and discounts and any updates on esports.||Name and email address||We need this information to make sure we do a good job in managing your relationship with us and to comply with any request made by you.|
|To send you the prize if you win the competition||All the personal information we collect.||We need all this information to make sure you get the prize you have won.|
|To provide you with merchandise or other services/ products you have ordered from us.||All contact details.
If applicable your parent/guardian’s payment information.
Personal identification documentation, such as a passport or driving licence copy, for the purchaser.
|We need all this information to make sure you get the merchandise or products you ordered.
Our payment and fraud prevention system may flag inconsistencies in the information provided by customers. If this happens, your order cannot be completed unless you provide personal identification information which allows us to confirm that your transaction is legitimate.
|To contact you if you abandon your cart (i.e. you place items into your cart but do not complete your order).||The email address supplied in relation to the abandoned cart||We have a legitimate interest in generating sales by retargeting customers who have already indicated a strong interest in purchasing goods from UDP ; and a legitimate interest in understanding why a transaction may not have completed. It is important to note that we do not retain the email address utilised for cart abandonment emails, unless consent for retention has been expressly given by the relevant customer (i.e. they are a Subscriber).|
|To help you if you have a question or you are not happy with something we have done.||Contact details and any chats we have had.||To make sure we deal with any issues you have quickly.|
|To enter into and perform contracts, where we may be supplying products/services to you and/or you may be supplying products/services to us or we may be involved in similar arrangements with third parties||All the personal information we collect||To enter into and perform contracts with either yourself or the organisation that you represent.|
|To make sure we are keeping up with health and safety.||Your dietary requirements or other health matters||It is in our interests to make sure we provide you and others like you with a safe place/environment to work.
Sometimes we may have to keep your details because the law tells us we have to.
|To arrange for any trip or transportation to and from an event.||Any ID cards or passport information you give us, details of family members and emergency contacts, your parent/guardian’s payment information and details about your health.||We need all this information to make sure we can make arrangements for any trip you go on.|
|To promote esports, our events or our sponsors||Any photos or videos of you||Only where you have told us you are happy to use your image.|
|To comply with our legal obligations||All the personal information we collect||To comply with any legal obligation or requirement|
|To send you information relating to your investment, and comply with our general legal obligations in relation to shareholders||Name and email address||We need this information to make sure we do a good job in managing your relationship with us and to comply with any request made by you.|
|To comply with our contractual obligations to developers||Name, email address and extent of holding in UDP its affiliates||To protect UDP against breach of its contractual obligations, and to protect the integrity of esports through the disclosure of conflicts of interest among investors|
|To enter into and perform contracts, where we may be supplying products/services to you and/or you may be supplying products/services to us or we may be involved in similar arrangements with third parties||All the personal information we collect||To enter into and perform contracts with either yourself or the organisation that you represent.
We have a legitimate to properly perform contracts with third parties
If you have told us we can use your information in a certain way, you can tell us to stop using it at any time (see Contact section below). Also look out for the link at the bottom of any messages we send you which will also put a stop to any messages.
Who else receives your personal data?
We may send your details to others to help us run our organisation. These are:
- Anyone you have said you are happy for us to send your details to.
- Organisations that provide services to us: such as marketing specialists, the people that manage our website on our behalf, third party payment providers, computer services (like our cloud storage services and collaboration tools) and third party mailing providers (e.g. Mailchimp);
- Organisations that help us: such as companies that help us with our supplies such as couriers, or companies that help us to deliver things to and from other parts of the country or overseas, marketing platforms, customer relationship management platforms and our affiliated companies ;
- The Government: where the law tells us to do so or to help them with any investigations.
- Banks and nominated payment providers: if your bank/payment provider requests proof that the transaction is legitimate. Police, law enforcement and security services: to help them with any investigation, prevention of crime or matter of national security.
- Investment: if you have invested in UDP or any of its affiliates through a crowdfunding or other third party platform, we may share your information with that platform (to the extent required to facilitate the management of your investment), with other investors who request it (via disclosure of our cap table, which will also identify the extent of your investments) and with any game developer (to the extent required to ensure UDP complies with restrictions intended to prevent individuals owning shares in more that one esports team).
We may share your personal information with third parties where required by law, where it is necessary for our working relationship or where we have another legitimate interest in doing so.
Those third parties may be located in third countries outside of the EU (see section below). By submitting your personal data, you agree to this processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this notice.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Transferring your data outside of the EEA
UDP uses third parties to provide services which are important to the operation of our business. Some of these third parties are based, or store information, outside of the Romania and the European Union. We may transfer the personal information we collect about you to these providers, if this is necessary, in order to perform our contract with you, or if we consider that we have a legitimate interest to do so. Our third party providers include (but are not limited to) Amazon/ AWS, Dropbox, Impact, Google, Mailchimp, Salesforce, Slack, Stripe and Shopify. These organisations have provided us with assurance that they use and protect data in accordance with GDPR.
How long will we keep your personal data for?
We collect personal data from you for different reasons and so we might keep it for different lengths of time. For:
- Subscribers, it will generally be a period of 2 years after we were last in contact with you.
- Giveaway Entrant, it will generally be a period of 2 years after we were last in contact with you.
- Customers, it will generally be a period of 6 years after the last purchase (save for email addresses contacted via a cart abandonment email, which are not retained).
- Casual Worker, it will generally for a period of 6 years after the end of our relationship with you.
- Individual contacts at customers and suppliers/sponsors this will be for as long as we continue to have a relationship with that customer or supplier/sponsor and then for a period of 6 years afterwards.
- Investors, it will generally be for a period of 6 years after the date you cease to be an investor in UDP Romania.
Your rights to your personal data and complaints
You’re entitled to know what personal information we hold about you and how that information is processed, which means you can ask us to do any of the following things:
- to provide access to your data;
- to rectify any mistakes relating to your data;
- to erase your data;
- to stop processing your data;
- to receive an electronic copy of your data;
- to object to our processing of your data;
- to object to any automated decision making that we may do using your personal data; and
- (automatic) to receive a notification of any breach of your personal data.
Just let us know (see Contact section below) if you’d like to exercise any of your rights.
Our site contains cookies (a small text-only file that is placed on your computer by another computer on the internet to enable that computer to know when you are visiting a particular site). They are widely used in order to make sites work, or work more efficiently, as well as to provide information to our site owners.
Overall, cookies help us to provide you with a better site by enabling us to monitor which webpages you find useful and which you do not. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site.
WHAT COOKIES DO WE USE?
Our site uses:
- essential cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site, use a shopping cart or make use of e-billing services. You can’t use our site without accepting essential cookies
- Functionality and preference cookies. These cookies are used to recognise you when you return to our site, and to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in. Cookies in this category enable us to personalise our content for you, greet you by name and remember your preferences.
- Analytics and statistics cookies. These allow us to recognise and count the number of visitors, to see how visitors move around our website when they are using it, provides us with information about the type of browser visitors are using and their device, and remembers if users have closed our pop-up information. Cookies in this category help us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. Social media-related cookies also fall into this category.
When you first visit our site (or you clear your browsing data), we give you the option to accept only essential cookies, or accept all cookies. Depending on your browser, you may be able to modify your browser setting to automatically decline cookies. We note that any visitor accepting only essential cookies will not receive our full intended user experience.
General queries regarding UDP’s products and services should be directed to: [email protected]
We welcome any queries or enquiries or requests in respect of this notice, you can contact us by sending us an email on: [email protected]