Privacy Policy

Data we collect directly

  1. Contacting us

You can contact us in various ways, and in addition to your name, e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and contract.

  1. Account Registration

If you register for an account, we will request mandatory and, where applicable, non-mandatory data in accordance with our registration form this may include your name, display name, email address, password, your billing address. The entry of your data is encrypted so that third parties cannot read your data when it is entered and the data you submit to us is used in connection with the services and your account. The legal basis are your consent and the fulfillment of our contractual obligations.

  1. When using our services

We process the Personal Data involved in your use of our services in order to be able to provide our contractual services. This in turn however may also reveal data that centres on your gaming and spending habits and may possibly reveal sensitive information. Accordingly, the processing of data is limited to the strict needs of allowing you to participate in our competitions and is solely based on your consent. The legal basis for providing your data is the fulfillment of our contractual obligations and your consent.

  1. Gift Card

If you order a Gift Card on our website, we will process your order and send you the relevant gift card to the email address you have provided. This is done on the basis of a contract.

  1. Payment Data

If you make a purchase your payment will be processed via our payment service provider. Payment data will solely be processed through our payment service provider. The legal basis for the provision of a payment system is the establishment and implementation of the user contract for the use of the service.

  1. Administration, financial accounting, office organisation, contact management

We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

  1. Marketing

Insofar as you have also given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to. Your consent can be obtained in a number of ways, including by selecting a box on a form or implied from your interactions with us or our contractual relationship. Implied consent however is limited to the assumption that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.

Our Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. Every directly addressed marketing sent by us or on our behalf will include a means by which you may unsubscribe or opt out.

  1. Economic analyses and market research

For business reasons, we analyse the data we have on business transactions, contracts, inquiries, etc., whereby the group of persons concerned may include contractual partners, interested parties, customers, visitors, and users of our online offer.

The analyses are carried out for the purpose of business evaluations, marketing, and market research (e.g., to determine customer groups with different characteristics). The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarised, i.e., anonymized values. Furthermore, we take the privacy of users into consideration and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g., as summarised data). For further information, please also refer to our Cookie Policy.

General Principles

  1. Who receives my data?

Within AA Comps, those that need your data to fulfill our contractual and legal obligations will receive access to it.

Processors used by us may also receive data for these purposes. These are companies in the categories of IT services, telecommunications, and sales and marketing. Where we use processors to provide our services, we take appropriate legal precautions and corresponding technical and organisational measures to ensure the protection of personal data in accordance with the relevant legal provisions.

Data is only passed on to third parties within the framework of legal requirements. We only pass on users’ data to third parties if this is necessary, for example, for contractual purposes or on the basis of legitimate interests in the economic and effective operation of our business or you have consented to the transfer of data.

  1. How long will my data be stored?

As far as necessary, we process and store your personal data for the duration of our business relationship, which also includes, for example, the initiation and execution of a contract.

In addition, we are subject to various storage and documentation obligations, which result from the minimum statutory retention periods among others. The retention and documentation periods specified there are up to 6 years.

  1. How do we secure your data?

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of content or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

  1. Is data transferred to a third country or to an international organisation?

We may transfer your Personal Data to other companies and/or business partners as necessary for the purposes described in this Privacy Policy. In doing so, your personal data may be transferred to countries outside the UK and the EU. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the personal data we transfer.

  1. Special Category Data

Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.

  1. Minors

We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

  1. Automated decision-making

Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.

  1. Do Not Sell

We do not sell your Personal Data.

Your Rights and Privileges

  1. Privacy rights

Under the DPA and GDPR, you can exercise the following rights:

  • Right to information
  • Right to rectification
  • Right to object
  • Right to deletion
  • Right to data portability
  • Right to withdraw consent
  • Right to complain to a supervisory authority
  • Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

  1. Updating your information

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.

  1. Withdrawing your consent

You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

  1. Access Request

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

  1. Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the UK is: The Information Commissioner’s Office (ICO) is located at Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK www.ico.org.uk

Changes, Contact and Effective Date

We may update this policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us using the details provided above. The effective date of this policy is Friday, 2 June, 2023.