1. Introduction

This Policy details our commitment to protecting the privacy of individuals who:

  1. visit our Websites (defined below) (“Website Visitors”) or individuals who request us to contact them via our online web forms;
  2. who register to use the products and services which we market on pwndepot.com.

For the purposes of this Policy, the term “Websites” shall refer collectively pwndepot.com as well as the other websites that GameSupply® operates and that link to this Policy. This Policy describes how the company collects, uses, shares and secures the personal information that you provide. It also describes your choices regarding use, access and correction of your personal information.

2. Scope Of This Policy

When this Policy applies:

In addition to the Websites that link to this Policy, this Policy applies to the following:

  • Pwndepot.com which is an online marketplace for online games and game accounts. The company and third parties may post games and applications to this marketplace. When we post a listing on pwndepot.com and the listing links to this Policy, this Policy applies. When a third party posts an application, the privacy policy of the third party applies.

When this Policy does not apply – Third party websites:

Our Websites may contain links to other websites. The information practices and the content of such other websites are governed by the privacy statements of such other websites. We encourage you to review the privacy statements of any such other websites to understand their information practices.

When this Policy does not apply – Service Data:

With the exception of Account Information (as defined below) and other information we collect in connection with your registration or authentication into our Services, this Policy does not apply to our security and privacy practices in connection with electronic data, text, messages, communications or other materials submitted to and stored within the any accounts purchased by you (“Service Data”). Service Data security and privacy practices are maintained by the publisher of such services or such other applicable agreement between you and any publisher or game company and your use of such Services, whether free or subscription based (collectively referred to as a “service agreement”.)

3. Information That You Provide To Us

Account and Registration Information:

We ask for and may collect personal information about you such as your name, address, phone number, email address, instant messaging ID, and credit card information, as well as certain related information when you register for an account to access or utilize one or more of our Services (an “Account”).

We refer to any information described above as “Account Information” for the purposes of this Policy. By voluntarily providing us with Account Information, you represent that you are the owner of such personal information or otherwise have the requisite consent to provide it to us.

Other Submissions:

We ask for and may collect personal information from you when you submit web forms on our Websites or as you use interactive features of the Websites, including: participation in webinars, surveys, contests, promotions, sweepstakes, requesting customer support, or otherwise communicating with us. We process your personal information to perform our contract with you for the use of our websites and the Service(s) and to fulfill our obligations under the Service Agreement to you; where we have not entered into the Service Agreement with you, we base the processing of your personal information on our legitimate interest to operate and administer our websites and to provide you with the content you access and request.

Mobile Application:

When you download and use our Services, we automatically collect information on the type of device you use, and the operating system version, to perform our Service Agreement with you.

4. Information That We Collect From You on our Websites

Cookies and Other Tracking Technologies:

We and our authorized partners may use cookies and other information gathering technologies for a variety of purposes. These technologies may provide us with personal information, information about devices and networks you utilize to access our Websites, and other information regarding your interactions with our Websites. For detailed information about the use of cookies on our Websites and how to manage your cookie settings, please read and review our Cookie Policy found here.

We may use web beacons, tags and scripts on our Websites or in email or other electronic communications we send to you. These assist us in delivering cookies, counting visits to our Websites, understanding usage and campaign effectiveness and determining whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our third-party service providers on an individual and aggregated basis.

We use Local Storage such as HTML5 and Local Shared Objects (“LSOs,” also known as Flash cookies) to store content information and preferences. Various browsers may offer their own management tools for removing HTML5. Third parties with whom we partner to provide certain features on our Websites or to display advertising based upon your Web browsing activity use HTML5 and Flash to collect and store information. For further information on how to manage Flash cookies, please click here.

We partner with third parties to either display advertising on the Websites or to manage our advertising on other sites. Our third party partners may also use technologies such as cookies, web beacons, tags, flash, HTML5, scripts, or other tracking technologies to gather information about your activities on our Websites and other sites in order to suggest advertisements based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here and here (or if located in the European Union you may opt into the use of cookies, by clicking here). Please note this does not opt you out of being served ads and you will continue to receive generic, untargeted ads.

Logs:

As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Websites and Services. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information. Occasionally, we connect personal information to information gathered in our log files as necessary to improve our Websites and Services. In such a case, we would treat the combined information in accordance with this Policy.

Analytics:

We collect analytics information when you use the Websites to help us improve them, including through the use of cookies. We may also share aggregated and/or anonymized data about your actions on our Websites with third-party service providers of analytics services. We also use mobile analytics software to allow us to better understand the functionality of our mobile versions of our Services on your mobile device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

5. Information Collected From Other Sources

Social Media Widgets:

The Websites include social media features, such as the “Facebook Like” button, and widgets, such as the “Share This” button or interactive mini-programs that run on our Websites. These features may collect your Internet protocol address, which page you are visiting on the Websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Websites. Your interactions with these features are governed by the privacy statement of the companies that provide them.

Information From Services Provided by Third Parties:

We may also obtain other information, including personal information, from third parties and combine that with information we collect through our Websites. For example, we may have access to certain information from a third party social media or authentication service if you log into our Services through such a service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third party social media or authentication service is in accordance with the authorization procedures determined by that service. If you authorize us to connect with a third party service, we will access and store your name, email address(es), current city, profile picture URL, and any other personal information that the third party service makes available to us, and use and disclose it in accordance with this Policy. You should check your privacy settings on these third party services to understand and change the information sent to us through these services. For example, you may choose to log in to the Services using single sign-in services such as Facebook Connect or an Open ID provider.

These single sign-on services will authenticate your identity, provide you with the option to share certain personal information (such as your name and email address) with us, and pre-populate our sign-up form. Services like Facebook Connect give you the option to post information about your activities in the Services to your profile page to share with others within your network.

6. How We Use Information That We Collect

General Uses:

We may use the information we collect about you (including personal information, to the extent applicable) in order to perform our obligations under our Service Agreement with you and on the basis of our legitimate interest including to (a) provide, operate, maintain, improve, and promote the Websites and the Services; (b) enable you to access and use the Websites and the Services; (c) process and complete transactions, and send you related information, including purchase confirmations and invoices; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about us and our partners (you can opt-out of receiving marketing communications from us by going to Contact and providing the names/email address(es) that you would like removed from our marketing databases and added to our ‘Do Not Contact’ list” or following the unsubscribe instructions included in our marketing communications); (f) process and deliver contest or sweepstakes entries and rewards; (g) monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes; (h) investigate and prevent fraudulent transactions, unauthorized access to the Websites and the Services, and other illegal activities; (i) personalize the Websites and Services, including by providing features or advertisements that match your interests and preferences; and (j) for other purposes for which we obtain your consent.

Legal basis for processing (EEA visitors only):

If you are a visitor from the European Economic Area (“EEA”), our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we need the personal information to perform a contract with you (e.g. to provide you with our Services), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent. In some cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time why we need to use your personal information. If we process personal information in reliance on your consent, you may withdraw your consent at any time.

If you have questions about, or need further information concerning, the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact Us” section below.

7. Sharing Of Information Collected

Third-Party Service Providers:

We share information, including personal information, with our third-party service providers that we use to provide hosting for and maintenance of our Websites, application development, backup, storage, payment processing, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.

We may also share aggregated and/or anonymized information regarding your use of the Services with third parties for marketing purposes based on our legitimate interest to develop and promote Service(s). However, we would never identify you, your Agents or End-Users as the source of the information.

We may collect, and we may engage third-party analytics providers to collect, metrics and information regarding your use of the Service, including evaluating how Agents and End-Users use the Service (“Usage Data”), to develop new features, improve existing features or inform sales and marketing strategies, based on our legitimate interest to improve the Services. When we process Usage Data, any personal information shall be anonymized. Any such third-party analytics providers will not share or otherwise disclose Usage Data, although we may make Usage Data publicly available from time to time.

Compliance with Laws and Law Enforcement Requests; Protection of Our Rights:

In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required by law.

Testimonials:

From time to time, we may post testimonials on the Websites that may contain personal information. We always obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact us at privacy@pwndepot.com

Referrals:

If you choose to use our referral service to tell a friend about our products and services, we will ask you for your friend’s name and email address. You must only provide your friend’s name and email address if you have a reasonable belief they will not object to us contacting them. If you do, we will automatically send your friend an email inviting him or her to visit the Websites and will store this information for the purpose of sending this initial email, tracking the success of our referral program and other marketing activities. Your referral may contact us at privacy@pwndepot.com to request that we remove his/her information from our database.

Community Forums:

The Websites may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features (“Interactive Areas”). You should be aware that any information that you post in an Interactive Area might be read, collected, and used by others who access it. To request removal of your personal information from an Interactive Area, contact us at privacy@pwndepot.com In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Market our Services:

We may share information, including personal information, with our channel partners, solely for the purpose of enabling our channel partners to notify you about our Services. The company requires its channel partners to provide an opt-out option within its communications to you. By opting out, you are opting out of receiving future communication from our channel partner.

With Your Consent:

We may also share personal information with third parties when we have your consent to do so.

8. International Transfer of Personal Information

We do not share your personal information with third parties, unless it is necessary to carry out your request, for our professional or legitimate business needs, or as required or permitted by law. Where we do transfer your personal information to third parties or service providers, appropriate arrangements will be made in order to ensure correct and secure data processing in compliance with applicable data protection law.

Data retention

In some cases we need to retain data aggregated to provide ongoing support. When we have ongoing legitimate business need to process your personal information, we will either delete or aggregate it, or, if this is not possible then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. How to Exercise Your Data Protection Rights

You have certain choices available to you when it comes to your personal information. Below is a summary of those choices, how to exercise them and any limitations.

Correcting, updating and removing your information:

At any time you’d like to have your data corrected, amended, deleted or restricted simply contact us @ privacy@pwndepot.com and that we will respond with the action taken within thirty(30)days.

Other data protection rights:

If you wish to exercise any other data protection rights that are available to you under your local data protection laws (such as the right to data portability or to data restriction) then please send your request to privacy@pwndepot.com and we will respond to that request in accordance with applicable data protection laws.

11. Children’s Personal Information

We do not knowingly collect any personal information from children under the age of 16. If you are under the age of 16, please do not submit any personal information through our Websites or Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Websites or Services without their permission. If you have reason to believe that a child under the age of 16 has provided personal information to us through the Websites or any service, please contact us @ privacy@pwndepot.com and we will all reasonable efforts to delete that information.

12. Business Transactions

We may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge. If we do, we will inform them of the requirement to handle your personal information in accordance with this Policy.

13. Supplemental Terms and Conditions for Certain Regions

Brazil:

Personal information collected, stored, used and/or processed by the company, as described in this Policy, is collected, stored, used and/or processed in accordance with Brazilian Law No. 12,965/2014. Those individuals who use or access our Website or Services expressly consent to the collection, use, storage and processing of their personal information by us for the purposes described in this Policy.

Australia:

Personal information collected, stored, used and/or processed by the company, as described in this Policy, is collected, stored, used and/or processed in compliance with the Australian Privacy Act 1988 (Commonwealth) and the Australia Privacy Principles.

If you are dissatisfied with our handling of a complaint or do not agree with the resolution proposed by us, you may make a complaint to the Office of the Australian Information Commissioner (“OAIC”) by contacting the OAIC using the methods listed on their website at http://www.oaic.gov.au. Alternatively, you may request that we pass on the details of your complaint to the OAIC directly.

Singapore:

Personal information collected, stored, used and/or processed by the company as described in this Policy, is collected, stored, used and/or processed in compliance with the company’s obligations under the Personal Data Protection Act 2012 of Singapore (“PDPA”) .

Canada:

Personal information (as the term is defined in the Personal Information Protection and Electronic Documents Act of Canada (“PIPEDA”)) will be collected, stored, used and/or processed by the company in compliance with the company’s obligations under PIPEDA.

Supplemental Privacy Policy for California Residents:

The California Consumer Privacy Act (“CCPA”), which is effective as of January 1, 2020, regulates how we handle personal information of California residents and gives California residents certain rights with respect to their personal information.

The company would be classified as a business under the CCPA. The following supplemental privacy policy applies to information we collect in our role as a business—this is when we interact directly with you – not when we act as your agent when dealing with support issues pertaining to any licenses sold on your behalf to the company.

This supplemental privacy policy is effective as of January 1, 2020, shall apply only to residents of California, and may be subject to change. The general privacy policy shall continue to apply to the extent that it applies to you as a resident of California.

If you are a resident of California, we are required to disclose certain uses and disclosures in a certain format, as well as to inform you of certain rights you may have. Any capitalized terms used in this supplemental privacy policy shall have the same meaning as in the general privacy policy.

Information We May Collect:

We may collect the following categories of information:

  • Identifiers
  • Demographic Information
  • Commercial Information
  • Internet or other electronic network activity information
  • Geolocation data
  • Audio, electronic, visual, or similar information
  • Professional or employment-related information

For each category of information, we collect the information from a variety of sources, including directly from you, from your devices, from your social media profiles, and/or from third party providers. We collect the information to provide you with services, protect our customers and ourselves (including the services), and to improve the services. We do not share personal information with Third Parties as the term is defined under the CCPA.

Additional Disclosures:

We do not sell personal information of any individual, including personal information of minors under 16 years of age.

We have disclosed the following categories of personal information for a business purpose in the 12 months prior to this Policy’s last update.

  • Identifiers
  • Demographic Information
  • Commercial Information
  • Internet or other electronic network activity information
  • Geolocation data
  • Audio, electronic, visual, or similar information
  • Professional or employment-related information
  • Inferences drawn from any of the above information.

We have not disclosed any personal information for valuable consideration in the 12 months prior to this Policy’s last update.

Your Rights:

You may have certain rights with respect to your personal information, including:

  • The right to access, including the right to know the categories and specific pieces of personal information we collect;
  • The right to deletion of your personal information, subject to certain limitations under applicable law;
  • The right to request disclosure of information collected;
  • The right to disclosure of information disclosed for valuable consideration; and
  • The right not to be discriminated against for exercising certain rights under California law.

To exercise any of these rights please submit a request by emailing privacy@pwndepot.com.

Contact:

If you have questions regarding this Policy or about the company’s privacy practices, please contact us by email at privacy@pwndepot.com

14. Changes To This Policy

This Policy may be updated from time to time to reflect changing legal, regulatory or operational requirements. We encourage you to periodically review this page for the latest information on our privacy practices.

If there are any material changes to this Policy, you will be notified by our posting of a prominent notice on the Websites prior to the change becoming effective.

If you do not accept any changes made to this Policy, please discontinue use of the Websites and the Services.

15. Contact Us

If you have questions or complaints regarding this Policy or about the company’s privacy practices please contact us by email at privacy@pwndepot.com