We recognize privacy is important to our users. This document describes how and why Good
Gamer Entertainment Inc. (“GoodGamer”, “we”, “us” or
“our” ), collects, receives, possesses
or stores Personal Information (as defined below) as well as non-personally identifiable
data from users and website visitors, publishers, mobile applications and end users of
publisher sites to GoodGamer (www.goodgamercorp.com and goodgamer.gg) (“you”/ “your” ), and
how that data will be used, handled, dealt with and shared with third parties (“Privacy
Policy/Policy” ). GoodGamer is committed to respect the privacy of personal
well as non-personally identifiable data.
We urge you to read the Policy carefully in order to gain a clear understanding of the type
of Personal Information collected and how we may collect the same, usage or disclosure of
your Personal Information in the course of providing you with our products or services, and
your use of our website (www.goodgamercorp.com) and our mobile applications (the website and
mobile applications shall collectively be referred to as
“Portals” ) as well as reasonable
security practices and procedures adopted for the collection and usage of your Personal
Information. The user information is collected mainly vide two means: (i) information
supplied by the user itself or (ii) automatic retention of the user data during the
navigation of the Portals by the user.
contract formed under the Information Technology Act, 2000 and the rules made thereunder.
legally binding document between you and GoodGamer.
By using our Portals or services, or otherwise interacting with us, you consent to the
collection, usage and disclosure of your Personal Information by GoodGamer in accordance
1. What is Personal Information?
2. What Personal Information do we collect?
3. How do we collect your Personal
4. Cookies and tracking technologies
5. Online behavioural advertising
6. How do we use your Personal Information?
7. How do we share your Personal
8. How the information disclosed to the
third-party to be protected?
9. How long do we retain your Personal
10. Where do we store your Personal
11. How do we protect your Personal
12. What do we do to the Personal
Information provided by children?
13. How do we ensure protection of your
14. What do we do in case of a privacy or
15. How can you access or correct any
inaccuracies in your Personal Information?
16. Your choices with respect to the
collection, use and disclosure of your Personal Information
17. Links to other websites
19. Governing Law
20. The EU General Data Protection
1. What is Personal Information?
“Personal Information” means any information, recorded in any form, about an identified
individual or an individual whose identity may be inferred or determined from such
This Policy does not cover anonymized aggregated data from which the identity of an
individual cannot be determined. Good Gamer reserves the right to use anonymized data in any
way it determines appropriate.
2. What Personal Information do
We may collect the following Personal Information when you visit one of our Portals, contact
us, register with us, use our products or services or otherwise provide us with information
• full name;
• contact information, such as your email address, mailing address or telephone number;
• date of birth;
• bank account details;
• photograph, including social media and linked account profile pictures;
• username for our services or third-party services that you have linked to our
• shipping address;
• your location;
• content submitted by you, including video, audio, and social media data (which may
include who you follow, your followers, who you subscribe to and your subscribers);
• payment and banking information, including your credit card number, billing address
and transaction history. However, such information is encrypted using secure socket
layer technology (SSL) and stored with an AES-256 encryption; we do not retain payment
details that are processed by our payment provider; and
• any other personal information that you choose to provide to us.
Automatically Collected User
We obtain certain information about your use of our Portals. This information is collected
when publishers, advertisers, and advertisement networks use the Good Gamer platform.
Additionally, certain other information (such as cookies, described below) may be
transmitted by our web server to your computer. Specific types of usage information that may
be collected automatically are described below:
• information about how, when and where you
use our services;
• the hardware and software you use to
interact with our services;
• your device identifier;
• your mobile network information;
• the settings you use on our services;
• your network location;
• your IP address; and
• information about the webpages you
visited prior to coming to our Portals.
Information for complying with law
We may collect information from the users as a matter of compliance with the mandate of the
Information from the personnel
We may also collect Personal Information from prospective job applicants, our employees and
individuals associated with our business partners and service providers. Usually this
information is limited to name and contact details and the other information we need for the
purpose of managing the employment or business relationship.
3. How do we collect your Personal Information?
Good Gamer only collects Personal Information for purposes that would be considered
reasonable in the circumstances and only such information as is required for the purposes of
providing our products, services or Portals. We use only fair and lawful methods to collect
When you provide Good Gamer with the Personal Information, we ask for your express consent
to us collecting it and using it for that specific purpose only.
If we ask for your Personal Information for a secondary reason, for e.g. marketing, we will
ask you again for your express consent. In either case, we will provide you with an
opportunity to say no. We will not share your Personal Information with any third party
(other people or businesses) without your prior consent.
Withdrawing your consent
If after you opt-in, you change your mind, you may withdraw your consent for the continued
collection, use or disclosure of your information, at any time, by contacting Good Gamer and
intimating us of the same in writing.
However, please note that consent cannot be withdrawn retroactively. It should be noted that
in certain circumstances, our products or services can only be offered if you provide us
with your Personal Information.
Consequently, if you choose not to provide us with the required Personal Information, we may
not be able to offer you these products or services. We will inform you of the consequences
of the withdrawal of consent.
4. Cookies and tracking technologies
advertisements to users. Cookies are small text files placed on your hard drive that assist
make navigation of our Portals easier for visitors.
If you are concerned about cookies, most browsers permit individuals to decline cookies. To
learn how you may be able to reduce the number of cookies you receive from us or disable
cookies that have already been installed in your browser’s cookie folder, please refer to
your browser’s help menu or other instructions related to your browser.
You can also learn more about cookies by visiting www.allaboutcookies.org, which includes
additional useful information on cookies and how to block cookies using different types of
browsers. Note that while declining cookies may negatively affect your user experience on
our Portals, however it will not prevent us from transacting with you.
In order to properly manage our Portals, we may anonymously log information on our systems,
and identify categories of visitors by items such as domains and browser types. These
statistics are used to manage the operational efficiency of our systems.
5. Online Behavioral Advertising and Ad Tracking
As part of our ad delivery and reporting, we log page views and collect information for the
purpose of delivering advertisements or providing advertising-related services, including
providing a specific advertisement based on a particular type of browser or time of day;
statistical reporting in connection with the activity on a website; and tracking the number
of advertisements served on a particular day to a particular website (tracking web analytics
data). To do so, we collect information about the type of browser, referrer and operating
system of website visitors, as well as the domain name, day and time of visit, and page(s)
visited. We do so across multiple web domains owned or operated by different entities.
Opt-out: You can opt-out of the use of your Personal Information for the purposes of Online
Behavioral Advertising by contacting us, or by visiting Your Ad Choices at
http://youradchoices.ca/choices. The Your Ad Choices opt-out tool allows you to opt-out of
any advertising networks participating in the self-regulatory program for online behavioral
advertising. However, note that opt-outs will not be effective if your browser is configured
to reject cookies, or if you subsequently erase your cookies, use a different computer or
6. How do we use your Personal Information?
Good Gamer uses the data collected from users and Portals visitors, including Personal
Information, in order to:
• provide you with our products, services, and the use of our platforms;
• complete transactions and process payment;
• provide you with support and handle inquiries;
• for testing, research, analysis and product development. This allows us to improve and
enhance the safety and security of our services;
• for developing new features and products and finance solutions in connection with our
• for presenting you with relevant content, marketing materials and advertisements, by
analyzing your interests from the web pages you visit and online services that you use;
• communicate with you about our products and services, including updates or
• conduct surveys and market research;
• carry out promotions and contests;
• deliver content that may be of interest
• ensure that our Portals remains functioning and secure;
• investigate, prevent or act on any illegal activities or violations of our Terms &
Conditions and/or end user license agreement; and
• comply with any applicable law and assist law enforcement agencies as required.
We may also use statistical or aggregated information about the Portals’s use and share,
publish, post, disseminate, transmit or otherwise communicate or make available such
information, to suppliers, business partners, sponsors, affiliates and any other third
party, at our sole discretion.
Use of Push Notifications
We use push notifications to send you periodic alerts when we publish important and/or
sponsor-related news items to the platforms. When you first enter our platforms, you may
choose to approve or deny receiving push notifications. If you no longer wish to receive
these notifications, you may turn them off at the browser or mobile device level.
Combined anonymized data
With respect to data collected via the Good Gamer platform, we may share with third parties,
advertisers, and/or business partners anonymized, non-personally identifiable, or aggregated
data we receive or collect. The use and disclosure of such anonymized, non-personally
identifiable, or aggregated information is not subject to any restrictions under this
Logging in through third party social media platforms
If you log in to the Good Gamer platform through your account on a third-party social media
platform, your Personal Information that you shared through that social media platform may
be aggregated and disclosed to participating advertisers and ad networks for the purpose of
improving the relevance of the advertising presented to users.
Please note that logging in through your account on a third-party platform is optional. If
you do not wish for your Personal Information available through a third-party social media
platform to be used for these purposes, you may log in using your email address. If you had
previously logged in through your third party social media account, and wish to opt out of
the use and disclosure of your Personal Information for the purposes of improving the
relevance of advertising presented to you, you may do so by contacting us or by revoking
access given to Good Gamer through the third-party social media platform.
Our use of Personal Information is limited to the purposes described in this Policy. We do
not otherwise sell, trade, barter, exchange or disclose for consideration any Personal
Information we have obtained.
7. How do we share your Personal Information?
Good Gamer may disclose the data collected from users and Portals visitors, including
Personal Information, to the following parties, provided that such disclosure shall be for
the purposes which are related to the objectives for which such information is collected:
• individuals or organizations who are our advisers or consultants;
• our payment provider for the purposes of completing transactions with respect to our
products, services and contests;
• our shipping service provider for the purposes of arranging for shipping and delivery
of our products and/or prizes;
• the advertising, marketing and analytics service providers;
• other service providers, including individuals or organizations who are, or may be,
involved in maintaining, reviewing and developing our systems, procedures and
infrastructure including testing or upgrading of our computer systems.
• Provided however, our partners and service providers may change basis commercial needs
8. How the information disclosed to the third-party to be protected?
The parties to whom the Personal Information is shared in accordance with the Paragraph 7
above, shall maintain the confidentiality of the same and we shall undertake reasonable
steps for ensuring that the information shared to the third-party (for the above mentioned
purposes) is protected by the third-party, in accordance with the terms of this Policy
document. Usually we do this by imposing contractual requirements on or seeking assurances
9. How long do we retain your Personal Information?
We keep your Personal Information only as long as it is required for the reasons it was
collected. The length of time we retain information varies, depending on the purpose for
which it was collected and the nature of the information. This period may extend beyond the
end of your relationship with us, but it will be only for so long as it is necessary for us
to have sufficient information to respond to any issues that may arise at a later date. As
such, we may keep your account information after the termination of your account.
When your Personal Information is no longer required for the purposes for which it was
collected, we will destroy, delete, erase or convert it into an anonymous form. If we learn
that we have unintentionally stored Personal Information (e.g., if we become aware that a
URL that we store contains Personal Information), we will use commercially reasonable
efforts to anonymize or purge this information.
10. Where do we store your Personal Information?
Good Gamer may transfer Personal Information to a service provider where privacy laws may
offer different levels of protection from those in your location. Your Personal Information
may also be subject to access by and disclosure to law enforcement agencies under the
applicable foreign legislation.
11. How do we protect your Personal Information?
Our Portals is analyzed on a regular basis for any security gaps and identified
vulnerabilities for the purpose of securing the Personal Information collected by us.
Information that we collect is stored on servers that Good Gamer solely manages, using
standard physical, procedural and technical security procedures and practices appropriate to
the nature of the information in an effort to protect information from unauthorized access,
destruction, use, modification, or disclosure. The server is password protected and is
strictly limited. We further protect Personal Information by restricting access to it to
those of our employees that require access to the information in order to provide our
products or services on Portals.
However, no security precautions or systems can be completely secure. We cannot ensure or
warrant the security of any information you transmit to Good Gamer, and you do so at your
own risk. We cannot guarantee that such information may not be accessed, disclosed, altered,
or destroyed by breach of any of our physical, technical, or managerial safeguards, nor can
we guarantee that information you supply will not be intercepted while being transmitted to
us over the Internet, telephone or any other networks.
We do not favour any specific commercial product or service or any firm, trade name or
corporation name which is used or referenced on our Portals. The reference of such is only
limited to the informational purposes for the public.
We do not provide any direct or indirect representation or warranty with regard to the
non-infringement of the third-party rights, title, merchantability, fitness and freedom of
any computer virus in relation to the product or service provided vide this platform. We
shall not be held liable for any direct, indirect, incidental, compensatory loss, loss of
goodwill, loss of income or profit or claims of third parties.
The information which is communicated vide a social media platform comes within the public
domain and we do not guarantee the security of the same.
Management and security of Personal Information
The user is advised to maintain the confidentiality of the login information which is
provided by the user for registering with us. Such login information includes username and a
password, which should be within the knowledge of the user only and should not to be
disclosed to any other person.
12. What do we do to the Personal Information provided by children?
The minimum age limit of the User to enter into any transaction in relation to the products
and services offered by us, is 18 years. The persons under the 18 years age are expressly
excluded from availing the services on our platform. We request the parent/guardian to
inform us on an immediate basis of their children’ submission of the Personal Information
with us, by contacting at privacy AT goodgamer DOT gg. We shall ensure the prompt deletion
of such Personal Information, upon receiving of such complaint by the parent/guardian.
13. How do we ensure protection of your payment transaction?
All the information in relation to the payment of the transactions are processed through the
payment gateways and are not stored on our servers. The information stored with the payment
gateways is encrypted through the Payment Card Industry Data Security Standard
Your purchase transaction data is stored only as long as is necessary to complete your
purchase transaction. After that is complete, your purchase transaction information is
deleted. All direct payment gateways adhere to the standards set by PCI-DSS as managed by
the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard,
American Express and Discover. PCI-DSS requirements help ensure the secure handling of
credit card information by the store and its service providers.
14. What do we do in case of a privacy or security breach?
A “ breach of security safeguards ” is defined as the
loss of, unauthorized access to or
unauthorized disclosure of Personal Information resulting from a breach of an organization’s
security safeguards or from a failure to establish those safeguards.
In case of a breach of security safeguards involving your Personal Information under our
control, we will notify you in the circumstances to believe that the breach creates a real
risk of significant harm to you, including physical, financial or reputational.
We will also notify any other organization or government institution that can reduce the
risk or mitigate the harm from the breach. We will keep a record of all breaches in
accordance with our legal obligations.
15. How can you access or correct any inaccuracies in your Personal Information?
Good Gamer endeavors to ensure that any Personal Information provided and in its possession
is as accurate, current and complete as necessary to the extent provided by you, for the
purposes for which we use that information.
If we become aware that Personal Information is inaccurate, incomplete or out of date, we
will revise the Personal Information and, if necessary, use best efforts to inform third
party service providers or contractors which were provided with inaccurate information so
that those third parties may also correct their records. However, we shall not be held
responsible for the authenticity of Personal Information as supplied by the user and we make
no claim, guarantee or promise for the accuracy of the data and expressly disclaim any
liability arising out of the inaccuracy in the content of information.
Good Gamer permits the reasonable right of access and review of Personal Information held by
us about an individual and will endeavour to provide the information in question within a
reasonable time, generally no later than 30 days following the request. To guard against
fraudulent requests for access, we may require sufficient information to allow us to confirm
that the person making the request is authorized to do so before granting access or making
Refusal to access the Personal Information
We reserve the right of refusal of the request for access of the Personal Information in
certain circumstances including, where providing such access would be unlawful. The refusal
statement shall be conveyed to the individual in writing along with the reasons for such
refusal and the appropriate grievance redressal mechanism for raising objections against the
16. Your choices with respect to the collection, use and disclosure of your Personal
Depending on the products, services or your use of our Portals, your choices may include the
• Cookies Settings and Preferences. You may
cookies and other tracking
technologies through the settings in your browser. While doing so may negatively
your experience with the use of our Portals, nevertheless, it will not prevent us
transacting with you.
• Marketing e-mails. You may sign up for our
mailing lists in order to receive
promotional and other materials that may be of interest to you. If you no longer wish to
receive marketing e-mails from us, you may choose to unsubscribe at any time by clicking
on the “unsubscribe” link in our emails or by contacting us at privacy AT goodgamer DOT
• Opt-Outs. You may contact us to opt out of the
use or sharing of your Personal
Information, including for marketing or advertising purposes, and/or the provision of
your personal information to our business partners for such purposes.
17. Links to other websites
We may provide links to, or automatically produce search results for, third-party websites
or resources, or third-party information referencing or linking to third-party websites or
resources. Good Gamer has no control over such third-party websites and resources, and you
acknowledge and agree that Good Gamer is not responsible for the content or information
contained therein. When you follow such a link, you are no longer protected by our Privacy
Policy, and we encourage you to read the privacy statements or other disclaimers of such
other parties. Good Gamer is not responsible for the privacy or security practices or the
content of external websites, services or products.
Good Gamer cannot and does not guarantee, represent or warrant that the content or
information contained in such third-party websites and resources is accurate, legal,
non-infringing or inoffensive. Good Gamer does not endorse the content or information of any
third-party website or resource and, further, Good Gamer does not warrant that such websites
or resources will not contain viruses or other malicious code or will not otherwise affect
your computer. By using Good Gamer’s Portals to search for or link to a third-party website,
you agree and understand that Good Gamer shall not be responsible or liable, directly or
indirectly, for any damages or losses caused or alleged to be caused by or in connection
with your use of, or reliance on, Good Gamer to obtain search results or to link to a
frequently. Changes and clarifications will take effect immediately upon their posting on
the Portals. If Good Gamer makes material changes to this Policy, we will notify you here
that it has been updated, so that you are aware of what information we collect, how we use
it, and under what circumstances, if any, we use and/or disclose it. The continued usage of
our platform shall be treated as a deemed acceptance to the modifications to the Privacy
Policy, as and when such modifications are undertaken. If Good Gamer is acquired or merged
with another company, your information may be transferred to the new owners so that we may
continue to be able to transact with you.
19. Data Protection Regulation
The Company shall on a best effort basis protect the Personal Data of its Users in the
following manner, in addition to its statutory obligations as stated under Clauses 1 to 18
as stipulated under this Clause 19.
“Personal Data” means, generally, data that
identifies or can identify a particular unique
user or device – for instance, names, addresses, cookie identifiers, mobile device, precise
location data and biometric data.
a. Legal grounds for processing your Personal Data
We may tell you about the legal basis we’re relying on to process any Personal Data about
The legal basis for us processing your Personal Data for the purposes set out above will
typically be because:
• You provided your consent. In order to store and gain access to information stored on your
device, we rely on your consent. For this so-called “cookie consent” (which applies not only
to “cookies” but also to mobile ad identifiers), we rely on our own compliance steps and our
web and mobile partners’ compliance steps, designed to ensure that consent is collected and
passed on to partners, and to ensure that we only facilitate the collection of legally
obtained data. We may choose to obtain consent in other cases as well, in which case we will
adhere to applicable laws relating to such consent and its withdrawal.
• The processing is in our legitimate interest. In some cases, we use legitimate interest as
a legal basis for processing Personal Data, in order to provide our and/or other data
controllers’ services. Such processing goes beyond the original collection of mobile ad
identifiers. A legitimate interest we rely on, for instance, is the tailoring of promotional
communications to users of web and mobile properties, which is beneficial to users and is an
integral part of the ecosystem by which freely available content is funded through
advertising revenue. This also sometimes includes providing analysis of and reporting about
ad campaigns, as well.
• We also rely on legitimate interest when we use Personal Data to maintain the security of
our Services, such as to detect fraud or to ensure that bugs are detected and fixed.
• Contractual Relationships. Sometimes, we process certain data as necessary under a
contractual relationship we have (such as our customer records and contact information).
• Legal Obligations. Finally, some processing of data may be necessary for us to comply with
our legal or regulatory obligations.
b. Transfers of Personal Data
As Good Gamer works with global companies and technologies, we may need to transfer your
Personal Data outside of the country from which it was originally provided. When we transfer
Personal Data outside of your location, we take steps to make sure that appropriate
safeguards are in place to protect your Personal Data. Feel free to contact us at the
contact information below, for more information about the safeguards we have put in place to
protect your Personal Data and privacy rights in these circumstances.
c. Personal Data Retention
As a general matter, we retain your Personal Data for as long as necessary to provide our
Services, or for other important purposes such as complying with legal obligations,
resolving disputes, and enforcing our agreements. We generally render our own identifiers
(e.g., those we use to “sync” our customers data to online users) inactive after 13 months,
provided that we may retain them if we have a legal or significant operational need to do
so, such as for auditing, corporate record-keeping, compliance accounting or security and
d. Your Rights as a Data Subject
The following rights may apply to you:
(i) Right to restriction: you have the right to
restrict the processing of your Personal
(ii) Right to object: you have the right to object to
our processing of your Personal Data
which is based on our legitimate interests. We will no longer process your Personal Data
upon your request, unless we have compelling legitimate grounds for the continuation of
processing which override your interests, rights and freedoms, or for the establishment,
exercise or defense of legal claims. You may also object to our use of your Personal
for direct marketing purposes.
(iii) Right to data portability: under
circumstances, you have the right to have your
Personal Data transmitted to another data controller in a structured, commonly used and
(iv) Right to obtain a copy of personal data safeguards used
for transfers outside your
location: you can ask to obtain a copy of, or reference to, the safeguards
under which your
personal data is transferred outside of your location. We may redact data transfer
agreements to protect commercial terms. The law may provide you with certain rights in
respect of Personal Data that data controllers hold about you, including certain rights to
access Personal Data, to request correction of the Personal Data, to request to restrict or
delete Personal Data, and to object to our processing of your Personal Data (including
profiling for online ad targeting).
(v) Right to Access: if you wish to exercise your
right to access Personal Data we process
as a data controller; you may do so by requesting access through the e-mail address support
AT goodgamer DOT gg. When we receive your request, we will provide you with current,
step-by-step instructions to follow in order to obtain access. As we are required to verify
a requestor’s identity prior to providing Personal Data, we will assess requests to exercise
certain data access rights on a case-by-case basis: in doing so, we consider (a) the
difficulty of verifying whether data that we hold and data we have linked to it truly and
solely belongs to the data subject making the request, along with (b) the potential adverse
effects on disclosure of personal data to the wrong individual. Because such improper
disclosure would likely adversely affect the privacy rights and freedoms of the data
subject, we may limit the Personal Data we make available.
Please note that we will only grant requests submitted via email for Personal Data for which
we are a data controller, as explained further, below. Where we act as a processor for one
of our customers, we will refer your request to that customer. Please identify the customer
your request refers to (if possible), to simplify this process.
(vi) Right to Correct: if you wish to exercise your
right to correct Personal Data, you may
do so by contacting us at the contact information below.
(vii) Right to Object to Processing or to Withdraw Consent:
by using the browser-based
may withdraw consent for processing on which we rely on consent. If you do so, we will cease
processing your Personal Data for purposes of our services within 30 days or less.
We either collect these opt-out signals ourselves or receive them from the mobile apps we
(viii) Right to Erasure. you also have the right to
obtain the erasure of Personal Data
concerning you that we hold as a controller. The above opt-out process satisfies this right.
When a user opts-out through our partners (or through mobile device settings), and we
receive this signal, we no longer use Personal Data to provide our advertising services. We
will also manually delete your Personal Data if prefer that we do so; please contact us at
support AT goodgamer DOT gg for further instructions, if you wish to exercise this right
manually. Please note, however, that we may retain copies of certain Personal Data on
inactive or back-up files, for our own internal and necessary purposes, such as auditing,
accounting and billing, legal or bug-detection. We will in most cases delete such data
within 36 months, absent a compelling reason to retain it.
(ix) Right to Lodge Complaints. you have the right
to lodge a complaint with a supervisory
authority. However, we hope that you will first consult with us, so that we may work with
you to resolve any complaint or concern you might have and the same may be raised at privacy
AT goodgamer DOT gg
e. GoodGamer as a data controller and a data processor
EU data protection law makes a distinction between organizations that process Personal Data
for their own purposes (known as “data controllers” )
and organizations that process Personal
Data on behalf of other organizations (known as “data
processors” ). As noted above, we are
not always a data controller of the data in our possession but are sometimes a data
processor for other companies such as our customers. In such cases, we may direct your
inquiry to the relevant data controller, since data controllers are the ones with primary
responsibility for your Personal Data.
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