ReadyUp Privacy Policy

ReadyUp, LLC (“ReadyUp”) owns and operates a service that offers matchmaking, team management, commerce and other data services for competitive video game players (the “Service”) described in more detail at http://www.readyup.com. At ReadyUp, we feel strongly about protecting the privacy of individuals who visit our website or who use our Service.

This Privacy Policy applies to all information received by ReadyUp through your use of our website or the Service. It informs you what information is collected, how we use this information, how we store it and under what circumstances we will disclose it to third parties. We collect, use and disclose personal information in a manner consistent with the laws of the countries in which we do business. ReadyUp currently operates as an independent U.S. business entity. Future subsidiaries, joint ventures, or other companies under common control with ReadyUp will be required to adhere to this Privacy Policy as well.

This Privacy Policy also sets forth the privacy principles that ReadyUp follows with respect to transfers of personal information here in the United States and between the United States and member states of the European Union, Iceland, Liechtenstein and Norway (the European Economic Area, or “EEA”).  ReadyUp is subject to the investigatory and enforcement powers of the Federal Trade Commission (“FTC”) and other U.S. authorized statutory bodies.

DEFINITIONS

Personal information is any information that can be used to identify you as an individual, for example your name, address, telephone number, email address, and any other information that can be combined to identify you. When you visit certain areas of our website or our Service, we may ask you for personal information if you request information about our Service, for example, in order to  comply with age verification requirements regarding mature content or requests for game specific newsletters.

Anonymous information is information that is collected about you as you use our website or Service, but which does not identify you as an individual, or connect to your name, address, or any other personal information. Examples of anonymous information about you that might be collected while you visit our website or as you use the Service are the pages you visited, the length and time of your visit or use of the Service, the browser and operating system you use, your device type, your general geographic location, and the rate at which data you requested was transferred to you. One method we use to collect anonymous information about you on our site is through the use of cookies. A cookie is a small data file that a website can send to your browser to be stored automatically on your computer. Cookies are commonly used to track your visits to a site so you don’t have to log in on every page and to analyze how you use the site. This allows website operators like ReadyUp to serve you better.

PRIVACY SHIELD AND GENERAL DATA PROTECTION REGULATIONS (“GDPR”). ReadyUp fully complies with the EU-US Privacy Shield framework as set forth by the U.S. Department of Commerce and the European Union GDPR regarding the collection, use, and retention of personal information from European Union member countries.  ReadyUp is in the process of certifying its adherence to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability with the U.S. Department of Commerce. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles or GDPR, the Privacy Shield Principles and GDPR will govern. To learn more about the Privacy Shield program, including our certification page, and GDPR compliance please visit https://www.privacyshield.gov and https://www.eugdpr.org.

1. NOTICE: When ReadyUp collects personal information from individuals in the EEA, we will inform them about the purposes for which this information is being collected and used, the types of third parties to which we may disclose such information, and the choices and means that we offer individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to ReadyUp or as soon as practicable thereafter, and in any event before we use the information for a purpose other than that for which it was originally collected.

2. CHOICE: When ReadyUp seeks to collect personal information from you, you have the opportunity to decline having your information disclosed to a third party, or used for a purpose other than the express purpose for which it was originally collected by emailing us with your request at privacy@readyup.com. If you choose to opt-out in this manner, your request will be processed immediately and take effect within 30 days.

3. ONWARD TRANSFERS TO THIRD PARTIES: ReadyUp will use reasonable efforts to obtain assurances from its third party partners that they will safeguard personal information consistent with the policies set forth in this Privacy Policy. Examples of appropriate assurances that may be provided by third party partners include a written contract obligating the third party partner to provide at least the same level of protection for the personal information it has access to as is required by the Privacy Shield Principles and GDPR, or evidence of Privacy Shield and GDPR certification by the third party partner. If we become aware that a third party partner is using or disclosing personal information in violation of this Privacy Policy, we will take reasonable steps to prevent or stop the use or disclosure. In cases of onward transfer of the data of EEA individuals to third party processors received pursuant to the Privacy Shield and  GDPR, ReadyUp is potentially liable for violations of the Privacy Shield Principles and GDPR by such parties. ReadyUp is partnered with entities that support the performance of the Service by collecting and storing your personal information and all of which are currently Privacy Shield certified and compliant with GDPR. ReadyUp is partnered with third parties to support the performance of the Service by processing your anonymous information in order to provide end user usage reports and to optimize and enhance the Service.

4. SECURITY: ReadyUp will take reasonable and industry standard precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

5. DATA INTEGRITY AND PURPOSE LIMITATION: ReadyUp will only use personal information for the purpose for which it was collected or subsequently authorized by the individual. We will take all steps necessary to ensure that personal information is relevant to its intended use, complete, and current.

6. ACCESS: ReadyUp acknowledges that California and EEA residents have the legal right to access the personal information that we have collected and stored about them.  Any such individual who seeks access to their personal information, or who seeks to correct, amend, or delete inaccurate data, should direct questions to privacy@readyup.com and we will respond to such inquiries within 10 business days.

7. RECOURSE, ENFORCEMENT AND LIABILITY: ReadyUp will conduct annual compliance audits of its privacy practices to verify adherence to this Privacy Policy. ReadyUp employees that are found to have violated this Privacy Policy will be subject to disciplinary action up to and including termination of their employment with ReadyUp.

COLLECTION AND USE OF INFORMATION ON THE READYUP WEBSITE.  ReadyUp collects some personal information and some anonymous information about you from our website in order to maintain the website and to tailor the website to your needs. We do not collect personal information that is connected to your online activities over time or across third-party websites or online services, but we may collect this type of anonymous information about you through the use of digital retargeting technology. We may require the use of your personal information collected through our website to complete a transaction that you have specifically requested and with respect to commercial transactions you complete we will send a receipt of such transaction to the email address associated with your account. For example, if you request to receive Service related offers, newsletters, contest information, or promotions and you give us your express consent to send you such offers, newsletters, contest information, or promotions from time to time.  If you give us your express consent, ReadyUp and its third party partners may also use your mailing address, telephone number or email address to alert you about updates to the Service or to discuss special promotions. If you give us express consent to use your personal information for a specific purpose described here and you decide later that you don’t want us or our third party partners to contact you or to use your personal information in the manner you have previously consented, you have the ability to rescind your consent by visiting your Account Settings page and opting out of consents previously granted. Anonymous information collected through our website is used for maintenance and monitoring of the website, and market research.

COLLECTION AND USE OF INFORMATION THROUGH THE READYUP SERVICE. ReadyUp collects some personal information and some anonymous information through your use of the Service in order to provide the Service to you. For example, ReadyUp may collect anonymous or (with your consent) personal information relating to your use of the Service, specifically, how you have used the Service and how long you have used certain parts of the Service, in order to assess general performance of the Service, to maintain the Service, and to optimize the Service. Anonymous information gathered from your use of the Service may be used in conjunction with personal information gathered at the same time in order to support customer service requests that you initiate with us. For example, we may contact the email address associated with your account in order to answer support questions you send us. Personal Information we collect from you through the Service may be collected and used for the sole purpose of providing the Service. Personal Information we collect from you through the Service may be collected and used for purposes related to marketing, promotions, Service updates, newsletters and the provision of content information if you expressly consent to receive such information. We also use personal information provided to us by you to assist you with questions and to resolve problems relating to your use of the Service. ReadyUp uses anonymous information to efficiently operate the Service, to enhance your experience using the Service, and to optimize the performance of the Service. For example, we may use anonymous information to diagnose and correct any problems you or others are having with the Service or include anonymous information in a Service usage report during a meeting with a potential partner to show how the Service is used by existing customers.

CHILDREN. Many of our games on the Service are are intended for general audiences and not for children under the age of 13. ReadyUp does not knowingly collect any personal information (as defined under the Children’s Online Privacy Protection Act, also known as COPPA) from children under 13. Where users are identified as children under the age of 13, ReadyUp will provide the Services at all times consistent with applicable law, including COPPA.  ReadyUp will not ask for the personal information of children, will collect information from children only for limited purposes that are consistent with applicable law, will restrict children from accessing parts of the Service where such access would not comply with applicable law, and will obtain consent from the parents of children for the collection, use, and sharing of any personal information. If ReadyUp learns that a child under the age of 13 has provided us with personal information that is not subject to a COPPA exception, we will delete the  information immediately upon receiving such notice. If you are a parent and you want to revoke a consent that you previously provided, review information that we have collected from your child, or have such information deleted, you may contact privacy@readyup.com with your request. If we make a material change to how we use, collect, or share your child’s personal information, we will notify parents by email or by in-game notice in order to obtain verifiable parental consent for the new uses of your child’s personal information. Certain parts of the Service may not permit children to participate at all regardless of consent.

STORAGE OF INFORMATION. ReadyUp utilizes third party service providers to store personal information and anonymous information. Such providers are SSAE 16 certified and maintain a variety of physical, electronic and procedural safeguards to guard your information. All personal and anonymous Information is stored on physically and electronically secured servers. Access to this information is strictly limited to individuals who have a legitimate reason to use the information. The information is protected with security industry best practices, including; network security controls, logical and physical access controls, segregation of duties, and the principle of least privilege to prevent unauthorized access. While we cannot guarantee that loss, misuse or alteration of your data will not occur, we work hard to prevent such occurrences.

SECURITY OF INFORMATION. ReadyUp maintains a variety of physical, electronic, and procedural safeguards to protect your information while it is under our control, including the use of industry standard security measures to protect against the loss, misuse and alteration of your information. For example, your information resides on physically and electronically secured servers. We also use encryption technologies and other methods, depending on the type of information being transmitted or stored, to increase the security and privacy of information traveling to, from and within the Service. While we cannot guarantee that loss, misuse or alteration of your data will not occur, we work hard to reduce the risk of such occurrences by storing the information in a secure operating environment that is not available to the public. Although we take reasonable steps to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent all third-parties from obtaining your information.

SHARING INFORMATION WITH THIRD PARTIES. ReadyUp does not sell, rent or lease any of your personal information to third parties without your express permission. ReadyUp may disclose any of your information with or without notice to you if required by a subpoena, judicial or administrative order or as required by law, or where, in our sole discretion, we have a reasonable belief that it is necessary to protect the safety of any individual or the general public, to prevent a violation of the ReadyUp Terms of Service Agreement or the rights of ReadyUp or any third party. We may also be required to disclose an individual’s personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. In the event of a change in ownership, or a merger or acquisition of or with ReadyUp and another entity, we reserve the right to transfer all of your information to the acquiring entity. We will notify you by posting a notice on our website, and by contacting you directly via email if we have your email address, regarding any such change in ownership, and you may choose to modify any of your personal information at that time.

LINKS TO OTHER SITES. This website may contain links to other sites that are not owned or controlled by ReadyUp. Please be aware that ReadyUp is not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our website and to read the privacy policies of every website that may collect your personal information. ReadyUp is not responsible for personal information you provide to other such services or the privacy practices and other policies of such services.

PRIVACY RIGHTS OF CALIFORNIA RESIDENTS. A California resident who has provided personal information to ReadyUp may request information about whether we have disclosed your personal information to any third parties for direct marketing purposes. If you make this request we will provide you with a list of all third parties who have received your personal information from us in the preceding calendar year, as well as a list of the categories of personal information that were disclosed. You can request further information about our compliance with this law by emailing us at privacy@readyup.com. In compliance with California law, we will respond to one such request for information from you per year, provided the request is made through privacy@readyup.com, and no other means.

California minors also have the right to request that any content they have posted to a website, social media profile, or online service while under the age of 18 be deleted. If you are minor using the Service in compliance with our Terms of Service and you wish to request the removal of any such content, please contact us at privacy@readyup.com.

QUESTIONS. If you have any questions or comments about our use of your information or about this Privacy Policy, please contact us via e-mail at privacy@readyup.com.

UPDATING OR REMOVING USER INFORMATION

At any time and for any reason you may choose to correct or update your personal information by emailing us with your request at privacy@readyup.com. If you choose to remove your data it will be deleted from our records within 30 days, but may remain in our archive or backup records for approximately 90 days.

DISPUTE RESOLUTION. If you have any questions or comments about our use of information collected through the use of our website or Service, or about this Privacy Policy, please contact us at privacy@readyup.com. ReadyUp will use reasonable efforts to promptly investigate any complaint you have regarding our use of such information and to comply fully with the legal and regulatory authorities responsible for enforcing our adherence to the privacy principles stated above.

In compliance with the EU-US Privacy Shield Principles and GDPR, ReadyUp is committed to resolving complaints about our collection or use of your personal information.  EEA individuals with inquiries or complaints regarding this Privacy Policy should contact ReadyUp at:

ReadyUp LLC
P.O. Box 11329
Oakland, CA 94611
privacy@readyup.com

CHANGES TO THIS PRIVACY POLICY. ReadyUp may make changes to this Privacy Policy from time to time. We will post these changes here, so be sure to check back periodically. By using our website or Service you agree that we may also choose to contact you via the any email address or other contact information that you have provided to us in order to notify you of any significant changes to this Privacy Policy.