PRIVACY POLICY

1.Data Protection

This Privacy Policy applies to Skirmish Limited and its holding company and/or subsidiary companies (“the Company and/or Skrmiish”) and covers our processing activities as a data controller. Skrmiish is registered in the Isle of Man. Pursuant to the Isle of Man Data Protection Act, the Isle of Man has adopted the General Data Protection Regulations(“GDPR”). The Skrmiish principal place of business is at c/o Optimus, St Mary’s, The Parade, Castletown, Isle of Man, IM91LG Isle of Man.

For the purposes of the GDPR, Skrmiish is considered a data controller.

Skrmiish respects Your privacy and is committed to protecting the information that You provide to us in connection with Your use of Our website, mobile applications, console or PC applications (“the Services”).

This Privacy Policy will explain which information We collect from You, why We collect it, how We use it and the choices We offer to You.

By utilizing the Services and submitting Your information to us via the Services You are consenting to the use of Your information in accordance with this Privacy Policy.

If You do not agree with the terms of this Privacy Policy, please do not use the Services and do not provide us with Your information.

2.What data do we collect?

Personally identifiable information (PII) is any information that can be used to identify You or contact You, whether online or offline, such as Your name, address, email, phone number, photograph or profile picture.

Device-identifiable information (DII) is any data that is linked to a particular browser, device or account but which does not directly identify a person.

Skrmiish collects the following PII from You: Your name; physical address; location; email address; phone number; photograph or profile picture.

Skrmiish also collects information about which Services You use and how You use the Services, including the selections You make on the Services. This information, includes the date and time of Your visit, the phone network associated with Your mobile device, Your mobile device’s operating system or platform, the type of mobile device You use, Your mobile device’s unique device ID and the features of Our Services which You accessed.

3.When do we collect your data?

You directly provide Skrmiish with most of the data We collect. We collect data and process data when You:

•Register an account to utilize the Services;

•Utilize the Services, including participation in any events, matches, promotions or competitions;

•Correspond with Us via email, telephone or any of the Services;

•Access the website, this information includes, but is not limited to, traffic data, location data, weblogs and other communication data;

•Make an application for a job with Skrmiish;

•Apply to join the Skrmiish Partner Program;

•Voluntarily complete a customer survey or provide feedback on any of Our message boards;

or

•Communicate with Our support team.

For the purposes of facilitating the registration or login of Your account, Skrmiish may offer the use of social login with social media platforms providing social login services. Skrmiish might therefore request Your consent to collect Your information from Your chosen social media platform, as supported by Skrmiish, for such purposes.

4.How will We use Your data?

Our Company collects Your data so that We can:

•Register, manage and operate Your account so that You can participate in the Services including the Partner Program, where applicable;

•Share your email address with a Skrmiish Partner solely for the purpose of awarding prizes to You;

•Provided that You have opted to receive such information, We will email You with special offers on other products and services we think You might like;

•Comply with Our legal and regulatory responsibilities including verifying that You are over 18 years old and reside in a territory where Skrmiish is permitted to offer its Services;

•Address, assist and/or resolve Your customer support related queries and requests;

•Improve Our overall offering to Our customers.

5.How will We store Your data and Transfer and Disclosure of Information?

We will take all reasonable steps to ensure that Your information is kept secure and protected.

All data is password protected, access controlled, backed-up securely and encrypted when appropriate.

Our Company securely stores Your data with Microsoft Azure cloud service provider located within Northern and Western Europe. Where We use the services of Third Parties as part of our data processing, we have Data Processing Agreements in place.

Where data is transferred outside of the European Economic Area, we ensure that there is appropriate protection of your data, including through the standard contractual clauses published in terms of the GDPR.

We do not sell your data to anybody nor do we share it with anyone other than our contracted partners.

In the event of an information breach, Skrmiish will notify you within a reasonable timeframe of such breach coming to Our attention.

We are entitled to share Your information, which includes PII, with regulatory bodies, including the law enforcement agencies, in order to investigate fraud or sports integrity issues and to comply with any regulatory obligations to which We are subject, including to verify Your age, identity and location.

Your account information will be retained for a period of not more than two years after closure of Your account.

6.Telephone Calls

Telephone calls to and from our Customer Support Centre are recorded for training and security purposes along with the resolution of any queries arising from the service You receive.

7.Marketing

Skrmiish would like to send you information about products and services of ours that We think You might like, as well as those of Our partner companies.

If You have agreed to receive marketing, You may always opt out at a later date.

You have the right at any time to stop Skrmiish from contacting You for marketing purposes or giving Your data to other members of the Skrmiish team.

8.What are Your data protection rights?

Skrmiish would like to make sure You are fully aware of Your data protection rights. You are entitled to the following:

The right to access – You have the right to request copies of Your personal data from Skrmiish. We may charge You a small fee for this service.

The right to rectification – You have the right to request that Skrmiish correct any information You believe is inaccurate. You also have the right to request Skrmiish to complete the information You believe is incomplete.

The right to erasure – You have the right to request that Skrmiish erase Your personal data, under certain conditions.

The right to restrict processing – You have the right to request that Skrmiish restrict the processing of Your personal data, under certain conditions.

The right to object to processing – You have the right to object to Skrmiish’s processing of Your personal data, under certain conditions.

The right to data portability – You have the right to request that Skrmiish transfer the data that We have collected to another organization, or directly to You, under certain conditions. If You make a request, we have one month to respond to You.

If You would like to exercise any of these rights, please contact the Skrmiish Data Protection Officer at Our email: DPO@skrmiish.com

Skrmiish may also use technology, such as cookies, transparent gifs, tracking pixels, frames, server log analysis and other technologies as they are developed, to enhance Your experience with the Services.

Cookies are text files placed on Your computer to collect standard internet log information and visitor behaviour information. When You visit the Services, We may collect information from You automatically through cookies or similar technology.

For further information, visit allaboutcookies.org.

9.How do we use cookies?

Our Company uses cookies in a range of ways to improve Your experience on our website, including:

•Keeping You signed in;

•Understanding how You use Our website.

10.What types of cookies do We use?

There are a number of different types of cookies, however, Our website uses:

•Functionality – Our Company uses these cookies so that We recognize You on Our website and remember Your previously selected preferences. These could include what language You prefer and location You are in. A mix of first-party and third-party cookies are used.

•Advertising – Our Company uses these cookies to collect information about Your visit to Our website, the content You viewed, the links You followed and information about Your browser, device, and Your IP address. Skrmiish sometimes shares some limited aspects of this data with third parties for advertising purposes. Skrmiish may also share online data collected through cookies with Our advertising partners. This means that when You visit another website, You may be shown advertising based on Your browsing patterns on Our website.

11.How to manage cookies

You can set Your browser not to accept cookies, and the above website tells You how to remove cookies from your browser. However, in a few cases, some of Your website features may not function as a result.

12.Privacy policies of other websites

The Skrmiish website contains links to other websites. Our privacy policy applies only to the Skrmiish Services, so if You click on a link to another website, You should read their privacy policy.

13.Changes to Our privacy policy

Skrmiish keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 11 March 2022.

14.How to contact Us

If You have any questions about Our Company’s privacy policy, the data we hold on You, or You would like to exercise one of Your data protection rights, please do not hesitate to contact at: DPO@skrmiish.com

15.How to contact the appropriate authority

Should You wish to report a complaint or if You feel that Our Company has not addressed Your concern in a satisfactory manner, You may contact the Information Commissioner’s Office at:

P.O. Box 69, Douglas, Isle of Man, IM99 1EQ

Telephone: +44 1624 693260

Email: ask@inforights.im

16.Special Notice Regarding Minors Under 18 Years of Age

Skrmiish respects the privacy of children of all ages. Skrmiish particularly recognizes the sensitivity of personal information concerning minors under the age of 18 and therefore provides this special notice to parents and guardians regarding the collection and use of information collected from minors in this age group.

The Services are not directed towards young children or minors under the age of 18. Skrmiish is intent on complying with applicable laws and regulations regarding minors, including the United States’ Children’s Online Privacy Protection Act. Specifically, Skrmiish will not knowingly collect and maintain any personally identifiable information from children under 18.

If You are a parent or guardian who has discovered that Your child has submitted his or her personal information, Skrmiish will make all reasonable efforts to delete the information from its database, at Your request. To request the deletion of Your child’s information, please send an email to support@skrmiish.com. Include in Your message the username, email address and password that Your child submitted.