Match Seaside Privacy Policy
Last Updated: May 12, 2026
Effective Date: May 12, 2026
Welcome to Match Seaside!
This Match Seaside Privacy Policy (“Policy”) applies to you (referred to as “you” or “user”) and Elementa Games Pte. Ltd., a Singapore company with its address at 9 North Buona Vista Drive, #02-01, the Metropolis, Singapore, along with its affiliated companies (referred to as "we", us, "our", or "Elementa Games").
This Policy explain how we collect, store, use, disclose, transfer, and protect your personal information during your use of Match Seaside and related services, websites, and applications (collectively, the “Services”).
We are committed to protecting your privacy. Please make sure to read this Policy carefully in its entirety and pay particular attention to the terms highlighted in bold. Make informed choices based on the guidance provided within this Policy. If you do not agree with this Policy, you should not use the Services. You are not required to provide your Personal Information to Match Seaside, but in some cases, if you choose not to do so, we may not be able to provide you with related features or services, nor will we be able to respond or resolve the problems you've encountered.
Age Notice: We do not knowingly collect personal information from children below the minimum age required in your jurisdiction (e.g., under 13 in the US and many other places, under 14 in South Korea, under 16 in the EU for certain processing). If you are under the applicable minimum age, do not provide any personal information unless you have obtained your parent’s or legal guardian’s permission and consent. See Section 7 for details.
We may update this Policy from time to time. If we update this Policy, we will notify you by announcements in the game, or on our website, email, or other appropriate means to let you know about the changes we made. By accessing or continue using our Services after we have placed such a notice, you are deemed to have accepted the updated Privacy Policy. You can check the “Effective Date” posted at the end of the Privacy Policy for the latest update time.
If you have any questions, please feel free to contact us at matchseaside_cs@elementagames.com.
You can also access this Privacy Policy by the following means: “Settings> Privacy Policy” or at matchseaside.elementagames.com.
This Policy will help you understand the following contents:
1. Personal Information We Collect and Purposes
2. Cookies and Similar Technologies
3. Who May Access Your Personal Data
4. How Your Personal Information is Stored
5. How Your Personal Information is Transferred
6. Security of Your Personal Information
7. Your Rights
8. Contact and Complaint
9. Protection of Minors' Information
10. Privacy Policy Updates
11. Supplemental Jurisdiction-Specific Terms
1. Personal Information We Collect and Purposes
We collect personal information about you in accordance with applicable data protection laws, and only where it is necessary to provide and improve Match Seaside and the Services. For the purposes of this Policy:
Personal Information/Personal Data: means any information that identifies, relates to, describes, or can reasonably be linked to an identified or identifiable individual. Information that cannot reasonably identify an individual on its own (e.g., aggregated or de-identified data) is not considered Personal Information unless it is combined with other data that enables identification. Where non-personal information is combined with Personal Information, we will treat such combined data as Personal Information and process it in accordance with this Policy. You are not required to provide Personal Information to use Match Seaside. However, if you choose not to provide certain information, we may be unable to provide specific features, functionalities, or respond effectively to your requests. We collect and process Personal Information only for the purposes described in this Policy.
We may process aggregated or de-identified data for analytics and research, service improvement, and/or business intelligence. Such data does not identify you and is not treated as Personal Information unless re-identified.
Data Subject: Data Subject is any living individual who is the subject of Personal Data. For the purpose of this Policy, you are the Data Subject of your data.
We may collect your Personal Information in the following ways:
1) information you provide to us;
2) information we obtain automatically during your use of Match Seaside;
3) information we obtain from third parties.
1.1 Information You Provide to Us
• Registration Information. If you sign up with your e-mail when you create an account in the Game, we will collect information associated with your account, including your e-mail address, verification code, age, username/nickname, password(stored in encrypted/hashed form), profile picture/avatar, age or date of birth (where required for age verification or compliance), and other profile details you provide. This information is necessary to create and manage your account, authenticate access and provide core gameplay services.
• Third-party login: If you register or log in via Google or other social networks, we may collect Personal Information you authorized Google to share with us to sign up for our services. Exactly what information we receive from Google may vary due to your privacy settings on Google, but it would typically include your basic public profile information such as your profile name, nickname, age, User ID (or Google account ID) and profile picture. If you refuse to provide information of your third-party account, you may not have the option to register and log in by your third-party account.
• User-generated content (UGC): We collect content that you voluntarily create, upload, or share within the Services, including text messages, comments and chat logs, images, gameplay-related content or posts. Please note that UGC may be visible to other users depending on the feature.
• Purchases, transactions and promotions: When you make purchases or participate in promotions, we may collect transaction identifiers and purchase history, billing-related details (processed by third-party payment providers), contact information (e.g., name, email, phone number, mailing address), country or region and other data you consent to provide. We use this data to process transactions, deliver virtual or physical rewards, administer promotions, contests, and events. Where applicable, we may display limited identifiers (e.g., masked UID or username) with your consent.
• Customer support and feedback: When you contact customer service, we may collect your contact details, content of your enquiry, game ID and account information, device and technical details, purchase or transaction records, chat logs, gameplay data and other information relevant to your issue. This information is used to provide support, troubleshoot issues and improve our Services.
1.2 Information We Receive from Third Parties
We may receive Personal Information from:
• Social login providers (e.g., Google)
• Payment processors (e.g., confirmation of transactions)
• Analytics and advertising partners
• Other users, including reports, complaints, or shared content involving you
We process such data in accordance with applicable laws and contractual obligations.
1.3 Information We Automatically Collect:
We may collect some or all of the following Personal Information about you when you use our services for for purposes such as service delivery, security, and analytics. We do not knowingly collect sensitive personal data unless required by law or explicitly disclosed. We do not require users to provide Personal Information beyond what is necessary for the Services. Where processing is based on consent, you may withdraw consent at any time.
• Device and Technical Information. device type and model, operating system and version, Unique device identifiers (e.g., GAID, device ID, IMEI where permitted by law), operator information, application store information, IP address, network type and operator, language and regional settings.
• In-game and Usage Information. game version and session data, gameplay progress and interactions, feature usage and preferences, event logs and clickstream data, participation in promotions or activities, your login data and duration.
• Cookies and local storage: we may store data locally on your device (e.g., cookies or similar technologies) to maintain session state , store preferences and improve performance. Where required by law, we will obtain your consent before using non-essential cookies or tracking technologies.
• Location information. We may collect approximate location information based on IP address or device settings. We do not collect precise geolocation data (e.g., GPS) without your explicit consent where required by applicable law.
• Inferred or derived information: We may generate inferred data based on your activity, such as: gameplay preferences, behavioral patterns, fraud or risk indicators. This helps us improve gameplay experience and maintain security and integrity of the Services.
1.4 Purposes For Collection and Usage of Your Personal Information
We process your Personal Information only where we have a valid legal basis under applicable data protection laws. We do not knowingly collect sensitive personal data unless required by law or explicitly disclosed. We do not require users to provide Personal Information beyond what is necessary for the Services. Where processing is based on consent, you may withdraw consent at any time.
1.4.1 Legal Bases for Processing
Depending on your location and the specific processing activity, we rely on the following legal bases:
• Performance of a contract: To provide you with access to Match Seaside and its core functionalities in accordance with our Terms of Service.
• Legitimate interests: To operate, secure, and improve our Services, provided that such interests are not overridden by your fundamental rights and freedoms.
• Consent: Where required by law, including for certain marketing activities.
• Compliance with legal obligations: To comply with applicable laws, regulations, legal processes, or enforceable governmental requests.
• Protection of vital interests: In limited circumstances, to protect the safety, rights, or vital interests of users or other individuals
1.4.2 Specific Purposes of Processing
• For the purpose of provision and operation of the Services. To create, manage and authenticate your account. To general and associate unique identifiers (e.g., user ID, device ID, game ID). To enable gameplay features, including multiplayer functionality and in-game interactions, and to verify your identity.
Legal basis: Performance of contract.
• For the purpose of Service functionality, maintenance, and improvement. To ensure proper operation, stability, and performance of Match Seaside. To analyze usage patterns, troubleshoot issues, and optimize gameplay experience. To identify, diagnose, and resolve bugs or technical errors, and to develop new features and enhance existing ones.
Legal basis: Legitimate interests, and performance of contract where applicable.
• For the purpose of Security, integrity, and fair play. To maintain the security of your account and the Services, detect, prevent, and investigate fraud, unauthorized access, cheating, hacking, exploitation of bugs, or other prohibited activities, enforce our Terms of Service and other policies, and to moderate UGC and player interactions.
Legal basis: Legitimate interests, and legal obligation where applicable
• For the purpose of advertisement push-forward and personalization. To deliver advertisements, including interest-based or targeted advertising (where permitted), measure and analyze the effectiveness of advertising campaigns, and to send you marketing communications, including updates, offers, and promotional content. To further tailor content, gameplay experience, and recommendations, determine your general location (e.g., country or region) for localization purposes, and to customize settings such as language, region-specific features, and offers.
Where required by law, we will obtain your prior consent before sending marketing communications or engaging in targeted advertising. You may opt out of marketing communications at any time.
Legal basis: Consent, and legitimate interests where permitted by law.
• To provide you with customer service and feedback services. If you encounter any problems while using our services, you may contact us and seek assistance through our customer service. We may collect your Personal Information to contact you or help you resolve the problem, to respond to your inquiries, requests, or complaints, or to record the problem and its solution, or to communicate important service-related information, including updates, changes to policies, or security notifications.
If you choose not to provide such information, we may not be able to provide you with this service, but your use of other features of Match Seaside will not be affected.
Legal basis: Performance of contract and legitimate interests.
• For the purpose of transactions, payments and promotional activities. To process purchases, subscriptions, and in-game transactions and administer promotions, contests, sweepstakes, and reward programs. We may occasionally launch or offer you promotional activities such as a lucky draw. When you participate in a corresponding promotional activity or when we need to send you your gift, we will use such information to verify your eligibility and deliver rewards to you.
Legal basis: Consent, performance of contract and legal obligation
• For the purpose of Legal compliance and protection of rights. To comply with applicable laws, regulations, and legal processes, respond to lawful requests from public authorities, protect our rights, property, and safety, as well as those of our users, affiliates, and the public, and to establish, exercise, or defend legal claims.
Legal basis: Legal obligation and legitimate interests
We will only use your Personal Information for the purposes described in this Policy unless:
• The new purpose is compatible with the original purpose, or
• We obtained your consent, or
• The processing is otherwise permitted or required by law
2. Cookies and Similar Technologies
We and our third-party partners use cookies, web beacons, local storage, SDKs, and similar technologies to enable functionality, analyze usage, and support advertising (subject to applicable laws and your preferences).
You can manage cookie preferences through in-game settings or your device/browser. Where required by law (e.g., GDPR), we will obtain your consent for non-essential cookies.
3. Who May Access Your Personal Data
In addition to Elementa Games and/or its affiliates, other parties may also access your personal data in the following situations. You acknowledge that you have foreseen and agreed to the occurrence of such disclosure when you provide your personal data.
Other users or third-party platforms (if you choose to share externally) may, for example in a group challenge, see your in-game activities in group challenge. Other users may also see your display data and read the messages you have posted on or through the Elementa Games Services. You confirm that the Elementa Games Services may also include message boards, and/or other chat areas, where users may exchange ideas or communicate with other users and you acknowledge that any data you posted to any communication area is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive data at any time.
We may provide certain portion of your personal data to judicial or administrative authorities as so requested or for the purpose of compliance with applicable laws, regulations, or legal processes. Besides, we may disclose certain portion of your personal data within a strictly limited scope of recipients when we reasonably think it is necessary to protect us, our users or a portion of the public.
In addition to be required by applicable laws, we reserve the right to disclose your personal data in the cases if we, in our good faith, believe that disclosing such data is necessary to identify, contact, or bring legal action against you, if (a) you are violating any agreements between us, such as the Terms of Service and this Policy or otherwise damage us; (b) you are infringing third parties’ rights and interests (including but not limited to intellectual property rights) or damaging publich interests; and/or (c) we believe that it is necessary to prevent fraud or other illegal activities.
3.3 Third-Party Service Providers
We engage third-party service providers to perform services on our behalf. These providers act as data processors and are contractually obligated to process Personal Information only in accordance with our instructions and applicable law. These include:
• Infrastructure and cloud hosting: Data storage, hosting, and system maintenance; backup and disaster recovery services.
• Security and operational services: Fraud detection and prevention; anti-cheat and abuse detection systems; identify verification (where applicable); and error logging, crash reporting, and performance monitoring.
• Customer support services: Ticketing systems and user support and communication tools.
We ensure that：
• data shared is limited to what is necessary;
• providers are subject to data processing agreements (DPAs);
• appropriate confidentiality and security obligations are in place
3.4 Third-Party Platforms and Integration Partners
If you choose to log in or interact with third-party platforms (e.g., Google, or social networks), we may share limited information necessary to authenticate your account, enable cross-platform functionality, and facilitate account linking. Such information may include app or user identifiers, authentication tokens and basic account data.These third parties act as independent controllers, and their processing is governed by their own privacy policies. Please be aware that we cannot control the activities of such third parties, and we cannot guarantee that they adhere to the same privacy policy as we do. Since those contractors may access your data as data controller and operate under their own privacy policies, we strongly encourage you to check their privacy policies on their official websites and learn more about their data processing practices.
When you make purchases within the Services, payment processing is handled by third-party payment providers. We may share limited transaction-related data (e.g., order ID, purchase details). We do not collect or store full financial account or payment card information. Such data is processed directly by payment providers in accordance with their own privacy policies and applicable financial regulations.
3.6 Advertising and Analytics Partners
We may share certain information (such as device identifiers, IP address, and usage data) with advertising and analytics partners, including services such as Firebase (Google Analytics & Crashlytics), for purposes such as measuring campaign effectiveness, attribution and performance tracking, fraud detection and prevention in advertising, identifying and resolving game crashes and bugs, and improving product stability and user experience.
Where required by law:
• We will obtain your prior consent before engaging in such processing;
• We will provide opt-out rights for “sharing” under applicable laws.
We do not knowingly provide personalized advertising to children or where prohibited by law.
3.7 Affiliates and Corporate Group
We may share your Personal Information with our affiliated companies for purposes consistent with this Policy, including account management and authentication, service delivery and support, security, fraud prevention, and compliance. All affiliated entities are required to adhere to equivalent data protection standards and process data only for specified purposes.
3.8 No Unauthorized Sale of Personal Information
We do not sell your personal data and only share non-personally identifiable, aggregated, and public data with third parties. We do not share Personal Information for cross-context behavioral advertising without appropriate legal basis and user controls. Please also be aware that we cannot control the activities of the aforementioned third parties, and we cannot guarantee that they adhere to the same privacy policy as we do. Since those third parties may access your data as data controller and operate under their own privacy policies, we strongly encourage you to check their privacy policies on their official websites and learn more about their data processing practices.
Where applicable under law (e.g., California), you may exercise your right to opt out of the “sale” or “sharing” of Personal Information.
4. How Your Personal Information is Stored
We will keep your data for as long as your account is active or as needed to provide you the Elementa Games Services, fulfill the purposes outlined in this Policy, or comply with legal obligations. The user data we collected above is stored in Singapore.
In the case you request to remove or delete your personal data, we will retain your data as long as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and/or enforce the agreements between us. Please note that the remove or deletion any of your data may result in the termination of some of our applicable services.
We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or — where the applicable law provides for longer storage and retention period — for the storage and retention period required by law. After that your Personal Data will be deleted, blocked or anonymized, as provided by applicable law.
To provide you with the highest quality services, we embrace a strategy of diversification and globalization, with our affiliated companies operating worldwide. Under the service contract between you and us, your personal information may be processed on servers located outside your place of residence. Regardless of the server location, we will implement appropriate measures in line with the protection standards outlined in this Policy and applicable legal requirements to safeguard your rights.
Elementa Games is a global gaming enterprise with suppliers located worldwide. In accordance with the principles of necessity and data minimization, we may access certain information from various locations. Our support, engineering, and other teams around the world may process your information from places outside your country of residence, such as Singapore.
5. How Your Personal Information is Transferred
To the Successor. In the event of a merger, acquisition, reorganization, bankruptcy or other similar event, we will make an announcement in advance, disclose the details of the event and information about the successor, and with the express consent of you or your guardian again, your personal data may be transferred to the successor of Elementa Games.
Across Borders. For the purposes described in this Policy, and to the extent permitted by applicable local laws and regulations and with your authorized consent, we may also transfer your Personal Information to our servers other than the country/region where you access the Game for storage or processing, we may also transfer your Personal Information to third-party service providers and business partners and your data may therefore also be transmitted to other countries or regions.
In the circumstance that we transfer Personal Information outside of your jurisdiction, whether it transferred to our affiliates or third-party service providers, we will comply with relevant applicable laws. We will take appropriate security measures and safeguards to make sure that all such transfers meet the requirements of applicable local data protection laws.
6. Security of Your Personal Information
We are committed to maintaining the privacy and integrity of your Personal Information no matter where it is stored. We have information security and access policies that limit access to our systems and technology. We also protect data through the use of technological protection measures such as encryption. Your Personal Information will remain subject to our technical and organisational controls and our policies and procedures (including this Policy).
Unfortunately, the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee 100% the security of the information transmitted to our services; any such transmission of your information is at your own risk. Additionally, the system and communication networks you use to access Match Seaside may encounter issues beyond our control. We rely on you to select secure passwords, to protect those passwords, and to use appropriate security software on your devices.
We would like to make sure that you are fully aware of all of your data protection rights. As a data subject, you have a variety of rights regarding the use, access, correction, deletion, withdrawal, and control of your user Personal Information. Your rights include:
You have the right to access your Personal Data that we hold about you, i.e. the right to require free of charge
(i) information whether your Personal Data is retained,
(ii) information about how we use your Personal Data, and/or
(iii) duplicates of the detailed Personal Data retained (including the categories, recipients, and retention periods).
If we process your Personal Data, we shall endeavor to ensure by implementing suitable measures that your Personal Data is accurate and up-to-date for the purposes for which it was collected. If your Personal Data is inaccurate or incomplete, you may update certain account information directly within Match Seaside. Otherwise, you may contact us to request corrections.
You have the right to obtain deletion of Personal Data concerning you if:
• the data is no longer necessary for the purposes for which it was collected;
• you withdraw consent (where applicable);
• you object to processing and there are no overriding legitimate grounds;
• the data has been unlawfully processed.
• We may retain certain information where required for legal obligations, dispute resolution, or enforcement of agreements
You can exercise your right to delete your Personal Data by contacting us or by deleting your account. As a result of deleting your account, you will lose access to Elementa Games services, including your account, subscriptions and game-related information linked to the account and the possibility to access other services you are using the account for.
If your account is linked to a third-party platform (e.g., Google, or similar services) and no additional login credentials are bound, deleting the third-party account may also result in the deletion of your Match Seaside account and related data.
7.4 Right to Restriction of Processing
You have the right to request that we restrict processing of your Personal Information where:
• You contest its accuracy;
• The processing is unlawful but you oppose deletion;
• We no longer need the data, but you require it for legal claims.
When our processing of your Personal Data is based on legitimate interests according this Policy, you have the right to object to this processing. If you object we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing; in particular if the data is necessary for the establishment, exercise or defense of legal claims.
Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
7.7 Right to Personal Data portability
You have the right to receive your Personal Data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller under the conditions to the extent permitted under applicable laws and regulations. Elementa Games makes your Personal Data available in structured HTML format through the Privacy Dashboard as described above.
7.8 Right to Lodge a Complaint
You also have the right to lodge a complaint at a supervisory authority about our collection and use of your user information. For example, you can lodge a complaint with your local supervisory authority.
If you have questions or wish to make a complaint about how we process your Personal Information, please contact our Data Protection Officer at matchseaside_cs@elementagames.com and we will endeavor to deal with your request as soon as possible.
9. Protection of Minors’ Information
We do not collect personal information from a child, as defined by the applicable laws in your country or region. For example, in South Korea, “child” refers to individuals under 14 years old, whereas in some other countries or regions, it refers to individuals under 13 years old. If you are considered a child under these definitions, you must immediately stop using the Services.
If you are above the age defined as a child in your country or region but you are a minor (the specific age is determined according to the definition of “adult” age in the laws of the country or region where you reside, for example, under 19 years old in South Korea, and under 18 years old in some countries and regions) or you are lacking the legal capacity to agree with a privacy policy, you must read this Policy accompanied by your parents (or legal guardians) and use the Services only after obtaining the consent of your parents (or guardians) to all the terms. The above requirements also apply to all amendments or modifications of this Policy.
If you are a guardian and discover that an individual under your care has used our Services or provided Personal Information, please terminate their use of our Services immediately and notify us promptly so we can take appropriate action. If you wish to query or delete your information, please refer to the “Your Rights” Section. Our customer service team may need to verify and confirm the guardianship. Once confirmed, we will assist you in deleting the information and the corresponding account as per your request
We reserve the right to modify or update this Policy as necessary. When changes are made, we will notify you by updating the “Last Updated” date at the top of the revised Policy or through any other notice required by applicable law. We encourage you to periodically review this Policy to stay informed about our current privacy practices.
You can also access this Policy by the following means: “Settings> Privacy Policy” or at [matchseaside.elementagames.com]
11. Supplemental Jurisdiction-Specific Terms
Certain jurisdictions require additional disclosures or rights. If you reside in one of the regions listed below, the following terms apply in addition to the rest of this Policy.
11.1 Additional Information for California Residents
If you are a California resident, once a year, you are entitled to request notice of certain information about the Personal Information that we may share with third parties for marketing purposes (e.g., the categories of user information shared, and contact information of applicable third parties), as well as request that we disclose to you what Personal Information we collect, use, disclose and sell about you, and the right to request deletion of Personal Information we collect or maintain about you. If you would like to exercise any of these rights, please email your request to us as provided below.
You have to right to request deletion of your Personal Information, subject to legal exceptions and the right to opt out of the “sale” or “sharing” of Personal Information (as defined by law)
Content Removal for Users Under 18: Users who are California residents and are under 18 years of age may request and obtain removal of User Content they posted by contacting us by the contact information below. All requests must provide a description of the user Content you want removed and information reasonably sufficient to permit us to locate that User Content. We may not be able to respond if you do not provide adequate information. Please note that your request does not ensure complete or comprehensive removal of the material. For example, materials that you have posted may be republished or reposted by another user or third party.
You also have the right to not be treated in a discriminatory manner for having exercised your rights regarding your privacy rights under the California Consumer Privacy Act (CCPA).
To exercise any of these rights, please contact us at matchseaside_cs@elementagames.com. We will respond to such requests without undue delay and generally within one month or such other period provided for by law and will let you know with the reason if we need more time to respond to your request. We may ask that you provide further information or complete a form in connection with a request. However, please note that We may not be able to fulfill requests that would interfere with rights of others (e.g. where providing Personal Information would reveal information about another person) or our rights (e.g. where we have an independent basis for processing, or the information includes our trade secrets or intellectual property).
If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request.
11.2 Additional Information for the EEA and UK residents
If you are in the European Economic Area (EEA) or the United Kingdom (UK), the following additional information applies to you in addition to the Privacy Policy set out above.
(1) Data Subject Rights
In addition to the information set out in the Privacy Policy above, you have the right to:
• ask us to restrict the processing of your personal data,
• data portability,
• to object to the processing of personal data.
(2) Legal basis for processing your personal data
Our legal basis for collecting and using the information described in the Privacy Policy above is:
• To establish and perform our contract with you (i.e. our Terms of Service) and to provide our services;
• For our or our partners’ legitimate interests, where those interests are not overridden by your data protection interests of fundamental rights and freedoms, e.g. to protect our legal rights, to pursue or defend legal claims, to improve our services;
• Consent, where obtained separately;
• For compliance with our legal obligations under applicable laws and regulations;
• To protect our or your vital interests or those of another person (for example, another player), e.g. against fraud and violations of our terms;
• While we typically do not collect sensitive or special category personal information, where we do this, it will be on the grounds of consent or other applicable lawful basis.
If you have questions, need further information about the legal bases for processing your personal information, or want to withdraw your consent, please contact us at matchseaside_cs@elementagames.com.
(3) Cross-border data transfer
We may transfer your personal data to our affiliates, third party service providers and partners that operate around the world, which are located in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.
Where we transfer your personal information to countries and territories outside of the European Economic Area and the UK, which have been formally recognised as providing an adequate level of protection for personal information, we rely on the relevant “adequacy decisions” from the European Commission, where applicable.
Where the transfer is not subject to an adequacy decision, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. The safeguards we use are the European Commission’s Standard Contractual Clauses as issued on 4 June 2021, including the UK Addendum, and/or the UK International Data Transfer Agreement permitted under Article 46 of the UK GDPR. This is how transfers of personal information between us and other companies will be safeguarded. All companies are required to protect personal information that they process from Europe in accordance with European Union data protection law. Transferred personal information includes basic information such as your name or contact information such as your email address.
11.3 Additional Information for Brazil Residents
If you are using our Services in Brazil, your Personal Information is processed in accordance with the Lei Geral de Proteção de Dados (Law No. 13,709/2018 – “LGPD”). Under the LGPD, you have the following rights, subject to applicable legal limitations:
• Confirmation of Processing – the right to obtain confirmation as to whether we process your Personal Information;
• Access – the right to request access to your Personal Information;
• Correction – the right to request correction of incomplete, inaccurate, or outdated data;
• Anonymization, Blocking, or Deletion – the right to request anonymization, blocking, or deletion of unnecessary or excessive data, or data processed in non-compliance with the LGPD;
• Data Portability – the right to request transfer of your Personal Information to another service provider, subject to regulatory requirements;
• Information on Sharing – the right to request information about public and private entities with whom we share your Personal Information;
• Information on Consent – the right to be informed about the possibility of denying consent and the consequences of such denial;
• Withdrawal of Consent – the right to withdraw consent at any time, where processing is based on consent.
To exercise your rights, or if you have any questions regarding the processing of your Personal Information, you may contact our Data Protection Officer (DPO) at matchseaside_dpo@elementagames.com
11.4 Additional Information for Philippine Residents
If you are using our Services in the Philippines, the following additional terms shall apply pursuant to the relevant laws, rules and regulations and issuances by the Philippines National Privacy Commission (“NPC”) on data privacy.
To the extent that the relevant laws, rules and regulations on data privacy recognize your rights and freedoms as data subjects, you shall have the right to information, object, access, rectification, erasure or blocking, lodge complaints before the NPC, damages and data portability. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.