Privacy Notice

Last updated: July 5 2021

We are committed to protecting your privacy and your right to informational self-determination. We kindly ask you to take a moment and read this Privacy Notice. The information provided here will help you understand how we process your personal data. Depending on the specific case it is possible that other privacy notices of ours may apply additionally, in which case we will inform you about this additional application (e.g. by providing you with a short version of the privacy notice and a reference to this Privacy Notice, or here by referring to such privacy notice). If you have any questions regarding our use of your personal data, please feel free to contact us over the channels provided below.

When we refer to “you” in this Privacy Notice, we refer to you as data subject. If you are interacting with us on behalf of others (e.g. you are a team manager or other personnel associated with a team and you are signing up others), please make sure all affected people receive the information stated in this Privacy Notice.

Table of Contents

I. Who Are We?

If we speak of “we” or “us” in this Privacy Notice, we refer to ourselves as controller, as defined below. Our contact details are:

Dreamhack AB
Telefonvägen 30
126 26 Hägersten
Sweden
 

Company Registration Number: 556845-8763
Email: privacy@eslgaming.com
about.dreamhack.com

 

Our email address for all privacy matters is: privacy@eslgaming.com

Our data protection officer (“DPO”) is:

Dr. Christian Rauda
GRAEF Rechtsanwälte Digital PartG mbB
Jungfrauenthal 8
20149 Hamburg
email: dpo@dreamhack.com

II. Our Relationship with Companies of the same Group

1. ESL Group

What does joint controllership mean?

We, Dreamhack AB, are part of the ESL Group (as defined below):

We, our parent company ESL Gaming GmbH (“ESL”), and our sister companies (each of them a “Subsidiary” and together with the parent company, “ESL Group”) cooperate closely together regarding the provision of our products and services. This means that we, ESL and the respective Subsidiaries may jointly determine if and how personal data of yours is processed or may act as data processors of ours. The ESL Group is comprised by us and the following entities:

 


ESL Gaming GmbH (parent company)

Schanzenstrasse 23

51063 Köln

Germany


ESL GAMING POLSKA SP. Z O.O.

ZELIWNA 38 STREET, 40-599

Katowice, Poland


ESL Gaming France S.A.S.

Le HQ, 1 impasse du Palais
37000 TOURS, France


ESL Gaming UK Ltd.

2nd Floor

64 Mansfield Street

Leicester

LE1 3DL

UK


ESL GAMING AUSTRALIA PTY LTD

Unit 4 / 199 Parramatta Rd,

Auburn, NSW, 2144

Australia


ESL SEA Pte Ltd.

56A Boat Quay

Singapore 049845


ESL Gaming America Inc.

1212 Chestnut St, Burbank

CA 91506

USA


NY office: 

286 Fifth Ave, 5th Floor, New York

NY, 10001

USA


ESL Gaming Online Inc.

1212 Chestnut St, Burbank

CA 91506

USA


ESL Gaming España S.L.U. 

C/Vereda de los Barros 2B Bis 209-210

Pol. Ventorro del Cano. 

28925 Alcorcon, Madrid,

Spain


ESL Gaming Malaysia SDN. BHD.


Suite A­23­9, Level 23, Mena-ra Uoa Bangsar, No. 5, Jalan, Bangsar Utama 1, 59000, Kuala Lumpur W.P., Kuala Lumpur, Malaysia.


Dreamhack Inc.

1944 Pacific Avenue, Tacoma, WA 98402

USA


Dreamhack Canada Inc.

78 Boulevard Brunswick, Dollard-des-Ormeaux, QC, H9B 2C5

Canada


Implicator Holding AB

Telefonvägen 30, SE-126 26, Hagersten, Sweden



 

Is there a contract between us and the ESL Group?

Yes. We and the ESL Group have concluded an Intercompany Data Protection Agreement that legitimizes any data flows between us and ESL, and between us and the Subsidiaries or between the Subsidiaries and ESL. It also contains rules for joint controllerships between us as well as the Standard Contractual Clauses provided by the European Commission to legitimize data flows from us, ESL, and Subsidiaries established within the EU to Subsidiaries established outside of the EU or the EEA.

Who processes data and why?

We cooperate with the ESL Group and jointly process personal data with them in the following cases:

 

  • We and ESL Gaming America Inc. jointly administer HR matters and process personal data related to this (e.g. regarding job applications);
  • Depending on the specific case, we, ESL and the following Subsidiaries may jointly plan, administer and execute Dreamhack owned and operated esports festivals, tournaments and events as well as esports tournaments, festivals and events which we conduct jointly with third party partners of ours (indistinctively “Tournaments” or “Events”). The Subsidiaries are: ESL Gaming España S.L.U.; ESL GAMING POLSKA SP. Z O.O.; ESL Gaming France S.A.S.; ESL Gaming UK Ltd.; ESL GAMING AUSTRALIA PTY LTD; ESL SEA Pte Ltd.; ESL Gaming America Inc.; ESL Gaming Online Inc., Dreamhack Inc., Dreamhack Canada Inc. and ESL Gaming Malaysia SDN. BHD.

 

For this we, ESL and those Subsidiaries can jointly process personal data such as:

    • personal data of freelancers involved in the Tournament (e.g. names and travel information);
    • personal data of participants of a Tournament or Event (e.g. names, nicknames, platform IDs, birth dates, email addresses, addresses, photos, videos and financial data, travel data, game data);
    • personal data of visitors of the venue where a live Tournament or Event takes place (e.g. image and spoken word captured on photos and videos);
    • personal data (e.g. email addresses and names) of employees of partners involved in the Tournament or Event (e.g. brand partners);
    • marketing data (e.g. analytical data from a website of a Tournament or Event, personal data of users from a social media page).

 

  • We share IT services that are provided and administered by ESL Gaming GmbH and through this, process personal data such as personal data of consumers/users that interact with ESL products and services as well as personal data of employees of partners who are involved in cooperations with us and/or the ESL Group. 
  • We and the ESL Group jointly market ESL products and services. For this purpose, we and the ESL Group may process personal data, such as user data (e.g. e-mail addresses for sending newsletters), as joint controllers. We and the ESL Group may jointly decide whether and how personal data is used for marketing purposes.
  • We share the services of ESL Gaming GmbH’s legal department for any legal questions and for administering and cooperating in intercompany matters. Through this we and ESL jointly process personal data such as names and other personal data provided in connection with a legal assessment or proceeding.
  • We and ESL share the system that allows us to respond to your requests when you exercise one of your rights under the GDPR (as further described below) or when you have any questions or comments regarding the protection of your personal data. Through this, we and ESL jointly process certain personal data, depending on the request, such as your email and name. 
  • ESL operates the shop where our products are offered and sold. Therefore, our website redirects you to the ESL Shop, and the privacy notice that applies to the shop is the one available there and not this one.

 

You can find further details on how we and the ESL Group jointly process your data in the respective section below (see Sections VII. and VIII. that inform about the specific processing activities).

 

Who is responsible for what? 

If not expressly stated otherwise in this Privacy Notice, we (Dreamhack AB) are responsible for safeguarding the rights of yours set out in this Privacy Notice, when processing your personal data. Therefore, we are your primary contact point for all requests you may have relating to data protection. You can at any time, of course, also contact ESL or the respective Subsidiary to exercise your data subject rights. We, ESL and the Subsidiaries can assist each other to comply with the obligations set out in the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) we may have towards you and will inform each other about matters of significance to a joint controllership. Irrespective of this, the GDPR grants you the possibility to exercise your rights in respect of, and against each of the joint controllers.

 

Contact:

If you want to exercise your rights against us or if you have any questions for us regarding the data processing, you can contact us via email at privacy@eslgaming.com

 

Depending on your request, it is possible that your request will be forwarded to ESL or to a Subsidiary, to help each other out to answer your request or to get directly in touch with you for this purpose. In case of a forward of your request, we, ESL and the Subsidiary inform each other about the matter to the extent necessary for answering your request.

III. Meaning of Terms

The meaning of certain terms we use in this Privacy Notice is defined by the General Data Protection Regulation (the “GDPR”), a data protection law of the European Union. All definitions set out in Art. 4 GDPR apply to this Privacy Notice. We would like to explicitly mention the meanings of the following commonly-used terms:

  • personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

 

  • processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

 

  • controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

 

  • processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

IV. Legal Basis

As a controller we need a legal basis to process your personal data lawfully, according to Art. 6 para. 1 GDPR.
If:

  • you have given your consent to the processing of your personal data for one or more specific purposes, this forms a legal basis according to Art. 6 para. 1 let. a) GDPR;
  • you have given explicit consent to the processing of special categories of personal data (e.g. data concerning health) for one or more specified purposes, and such consent is possible according to applicable law, this forms a legal basis according to Art. 9 para. 2 let. a) GDPR;
  • the processing is necessary for the performance of a contract between you and us or in order to take steps at your request prior to entering into a contract, the legal basis for this is Art. 6 para. 1 let. b) GDPR;
  • the processing is necessary for compliance with a legal obligation to which we are subject, the legal basis for this is Art. 6 para. 1 let. c) GDPR;
  • the processing is necessary to protect our legitimate interests or legitimate interests of a third party and such legitimate interests are not outweighed by your interests or fundamental rights and freedoms, the legal basis for this is Art. 6 para. 1 let. f) GDPR.
  • the data is processed for employment-related purposes, e.g. for hiring, the legal basis for this is Art. 88 para. 1 GDPR in connection with applicable labor and social security laws.

V. Security

We have implemented physical, technical and organizational measures to ensure a level of security ap-propriate to the risk presented by the data processing, in accordance with Art. 24 and 32 of the GDPR.


In case of a personal data breach and if this breach is likely to result in a risk to your rights and freedoms, we will, without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the competent supervisory authority. Should such breach likely result in a high risk for your rights and freedoms, we or – where required by article 34 of the GDPR – ESL or the corresponding Subsidiary will inform you about the personal data breach without undue de-lay.

VI. Your Rights

You have certain rights concerning the processing of your personal data by us, which are the following:

  • Right of information: You have the right to be provided information regarding the processing of your personal data by us.

 

  • Right of access: You have the right to obtain confirmation as to whether or not we are processing your personal data and, if this should be the case, access to the personal data.

 

  • Right to rectification: You have the right to obtain rectification of inaccurate or incomplete personal data concerning you.

 

  • Right to erasure (“right to be forgotten”): Under certain circumstances you have the right to obtain the erasure of personal data concerning you.

 

  • Right to restriction: Under certain circumstances you have the right to obtain the restriction of processing.

 

  • Right to data portability: Under certain circumstances you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit this data to another controller.

 

  • Right to object: Under certain circumstances you have the right to object to the processing of personal data concerning you.

 

  • Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of the EU of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

 

  • Right to withdraw consent: If a processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. Such withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

 

  • Right to not be subject to a decision based solely on automated processing: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

 

We provide certain options for you to control your personal data, for example, when we send you a marketing communication, you can click on the ´unsubscribe´ button or link to request not to receive more marketing emails from us, or if you have created an account, you can at any time delete it via your profile.

 

In addition to the above, If you want to exercise your rights or if you have any questions for us regarding the processing, you can contact us via email at: privacy@eslgaming.com.

VII. Recipients / Categories of Recipients

The personal data we process can also be either processed by other parties on our behalf (data processors) or transferred to and processed by other controllers or third parties. When data is processed according to this Privacy Notice, in principle, it is done so by the respective internal employees and freelancers of ours that are responsible for pursuing our purposes for the processing.

 

Especially the following main providers of ours may be recipients of your personal data:


HR services:


Bamboo HR LLC

335 South 560 West Lindon

UT 84042

USA (“Bamboo”)


Office tools (Workspace, formerly GSuite), advertising and analytics tools:


Google Ireland Limited, register number

368047, Gordon House, Barrow Street,

Dublin 4, Ireland (“Google Ireland”)


and


Google LLC

1600, Amphitheatre Parkway Mountain View, CA 94043

USA (both together: “Google”)


Ticketing and related tools:


Atlassian Pty Ltd

Level 6, 341 George Street Sydney

NSW 2000

Australia (“Atlassian”)


Tixr Inc. 

1337 3rd Street

Promenade, Suite 200, 

Santa Monica, CA 90401


Social media platforms and analytics tools:


Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (“Facebook”)


and


Twitter International Company

One Cumberland Place, Fenian Street

Dublin 2, D02 AX07 Ireland (“Twitter”)


and


Google Ireland (Advertisements and Analytics)


Newsletter software:


The Rocket Science Group, LLC

675 Ponce de Leon Ave NE

Suite 5000

Atlanta, GA 30308 USA (“Mailchimp”)


Survey tools:


SurveyMonkey Europe UC

2nd Floor, 2 Shelbourne Buildings,

Shelbourne Road, Dublin, Ireland


and


SurveyMonkey Inc.

1 Curiosity Way San Mateo,

CA 94403, USA (both together: “SurveyMonkey”)


Raffle tools:


Crowd9 PTY LTD

16 Jacaranda Crescent

Mornington, VIC 3931

Australia (“Gleam”)


Customer support tools:


Go Squared Ltd.

3 Barn Hawe

High Street

Edenbridge

Kent

United Kingdom

TN8 5AQ (“Go Squared”)


and


Zendesk, Inc.

1019 Market Street

San Francisco, CA 94103

USA (“Zendesk”)


Host providers:


PlusServer GmbH

Hohenzollernring 72

50672, Köln (“Plusserver”)


and


Pantheon Systems, Inc.

717 California Street, 3rd Floor,

San Francisco, California (“Pantheon”)


CRM tools:


Salesforce.com, Inc.

The Landmark @ One Market Street,

San Francisco, CA 94105

USA (“Salesforce”)


Messaging software:


Slack Technologies, Inc., 500 Howard Street, San Francisco, CA 94105

USA (“Slack”)


Video and photo platforms:


Google Ireland (YouTube)


and


Twitch Interactive, Inc.

350 Bush Street, 2nd Floor

San Francisco, CA 94104 (“Twitch”)


Forum software:


Vanilla Forums, Inc.

388 St Jacques, Suite 800

Montreal, QC H2Y 1S1

Canada (“Vanilla Forums”)


Contract signing:


JN Projects, Inc.

1800 Owens St
San Francisco, CA 94158

USA (“HelloSign”)



Some of these recipients are established outside of the European Union. These recipients are either located in a third country for which the European Commission has recognized that it provides an adequate level of data protection – here Israel and Canada – or we have concluded the EU Standard Contractual Clauses for transfers of personal data to processors established in so called third countries, meaning countries that are not part of the European Union or the European Economic Area, which provide adequate guarantees to ensure data protection at European level.

 

Apart from this, the following categories of recipients process data either on our behalf or with us as joint controllers or as individual controllers: financial and IT services; media; partners that statistically and analytically process sports data; website analytics providers; messaging systems; Subsidiaries of ESL; other players of the played game; companies involved in travel bookings; providers of ticketing platforms; partners of ours that are dedicated to broadcasting, coverage or other commercial engagements connected to an esports tournament; providers of raffle solutions; forum software providers; sponsors of prizes, airlines and transportation companies, and authorities.

 

You can find further information on which recipients and categories of recipients are involved in the processing of personal data under Section VII.

VIII. General Data Processing

In the following lines we would like to inform you about how we process your personal data. These are the general processing activities that can apply when you interact with us. Every processing activity is broken down into 5 parts:

 

(a.) What: What personal data is processed?
(b.) Who: Who receives the personal data?
(c.) Why: For what purpose is the personal data processed?
(d.) Legal Basis: What law allows us to process the personal data?
(e.) How Long: How long do we keep the personal data?

 

1. Communication via Email, Phone and Messaging Systems

a. What
If we communicate with you via email, mail or telephone (or similar), we process all personal data you disclose to us during our conversation (e.g. your name, email address, the reason why you are contacting us etc.).

Apart from this, it is also possible that we use other online messaging systems to communicate with you, if you wish to contact us over these channels. Please note that if you wish to contact us via such messaging systems, it is possible that the respective companies that offer these communication services may also process your personal data and that their privacy notices apply. We have no influence over such data processing by third parties. For further information on how these services process your personal data, please view their privacy notices.

b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes for the processing (e.g. someone from a department that you are contacting with a request). Possible further recipients: the providers of the respective messaging systems; Google (Workspace); Go Squared; Slack; Zendesk.

Depending on the specific topic of the conversation as well as the circumstances (e.g. a certain Tournament you participate in) it is possible that ESL and the Subsidiaries jointly process personal data with us according to Sect. II.1. as well as third-party partners of ours according to Sect. II.2.

c. Why
Depending on the specific conversation with you, the personal data can either be processed in order to take steps, at your request, to enter into a contract with us or to perform a contract you have concluded with us. Also, the processing can be necessary for us to comply with legal documentation obligations, or for the purposes of our legitimate interest to respond to your questions, requests, or complaints, or to respond to your mails and calls when you contact us and are not our contractual partner. We may also process your personal data to have proof regarding substantial content of our conversation, including but not limited to cases of potential legal claims on our or your side.

d. Legal Basis
The legal basis for processing the personal data in order to take steps at your request prior to entering into a contract with us or to perform a contract you have concluded with us is Art. 6 para. 1 let. b) GDPR. The legal basis for processing the data for compliance with our legal obligations is Art. 6 para. 1 let. c) GDPR. The legal basis for processing the data due to our legitimate interest is Art. 6 para. 1 let. f) GDPR.

e. How long
The personal data is stored at least for the time until our contract with you is fully performed. If the personal data has been stored in order to take steps at your request prior to entering into a contract with us, we will store the data for as long as reasons objectively exist to believe that the respective conversation will be continued within the foreseeable future. If your communication is considered a commercial or business letter or is required for compliance with tax regulations, then the storage period will be that necessary to comply with applicable laws or equal to the statute of limitations of the actions that could arise in connection with the processing.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

2. Visiting our Websites

a. What
When you visit our websites, we process personal data of yours, such as your IP-address, the time of your visit, what browser type you use, which pages on our websites you visit, if applicable, and also the website from where you were referred to our website.

We also use third party tools to analyze the use of our websites and services, however, specific information on this is provided under section “Third Party Analytics Tools & Consent Management” of this Privacy Notice.

b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: IT service providers and host providers.

c. Why
We process this data to display the website correctly in your browser, so you are able to make use of the full functionality of the services and the website content. We also process the data for troubleshooting, should the website not work correctly as well as for security purposes (e.g. to prevent malicious attacks on our website). These are legitimate interests of ours.

d. Legal Basis
The legal basis for processing the data is Art. 6 para. 1 let. f) GDPR.

e. How long
The data is stored for as long as our legitimate interest is given. For this, the data is stored for the time that we reasonably need to ensure our systems have not been subject to malicious use and to be able to effectively respond to any potential bugs or other malfunctions of the website.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

3. Dreamhack Account (Dreamhack ID)

a. What
When you register for a Dreamhack Account, we collect and process the following personal data of yours: nickname, email address, password, and confirmation that you are older than 16 years.

In addition to this required personal data, you have the option to upload further optional personal data to your account, such as your full name. Also, depending on your activity, we may process information related to the purchase of tickets, other purchases you make, events you attend, your seat at events, details of your visits to your account, including traffic data or other communication data and the resources to which you have access.

When you play games while logged in to your Dreamhack Account, your performance in games (e.g. match scores etc.) is saved or linked to your account.

Within your account there are options (e.g. “Manage personal data”), that allow you to decide how we use your personal data, or to control what you want to do with it. You may, as well, exercise your rights, for example, you have access to the personal data in the account and can update or correct any incorrect data.

b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours and any joint controllers that are responsible for processing the personal data. Possible further recipients: IT service providers and host providers.

c. Why
We process the required data to enter into and perform a contract with you (account contract) so you can use our service (e.g. participate in Events and Tournaments through your Dreamhack ID, purchase tickets or reserve your place in our Events). Game-related data is processed to perform the contract with you and also based on the legitimate interest of ours.

Optional data is processed based on our legitimate interest of providing you a service that serves you better, and that lets you individualize your public appearance, connect with friends, and enjoy a personalized experience with the esports community.

d. Legal Basis
The legal basis for processing the data to enter into or perform a contract we concluded with you is Art. 6 para. 1 let. b) GDPR.

The legal basis for processing data based on our legitimate interest is Art. 6 para. let. f) GDPR.

e. How long
Your Dreamhack Account data is stored for as long as you maintain your account which can be closed at any time at your request, or it will be closed automatically after four years of inactivity. Closed accounts will be permanently deleted after a period of 60 days.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

4. Account Linking

a. What
You have the possibility to link certain accounts you may have with third-party platforms to your Dreamhack Account. This grants you the possibility to:

verify your identity when you want to join matches on that platform with your Dreamhack ID;
sync tournaments you participate in that take place on a third-party platform;
integrate Dreamhack functions into functions of services of the respective third-party platform and vice versa. Functions vary from platform to platform, as well as the personal data that may be shared by us and the third-party platform. Please check the respective information page for this; or
automatically fill in fields of your Dreamhack Account profile when you first register for an Dreamhack account and chose to register with a third-party account.

When you link an account that you may have with a third-party platform, we can view certain profile information of the linked account (e.g. your name, account nickname, email address) and use this data to offer you Dreamhack services. The same applies to cases in which you link your Dreamhack Account to a third-party account and the platform provider can view information of yours in your Dreamhack Account.

We encourage you to read the privacy notice of each third-party platforms you use prior to linking them and providing any personal data to them.

b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for processing the data. Possible further recipients: IT services; host providers; the third-party platform provider may receive the information you share with it by linking your Dreamhack Account to its service.

c. Why
We process the data to enter into a contract with you at your request, if you chose to register to your Dreamhack Account with an account you may have with a third-party platform. It is also a legitimate interest of ours to provide you the possibility of easily setting up your account by transferring data you have already entered for another account into your new Dreamhack Account.

When we process the data to provide you features (e.g. syncing tournaments, verifying your identity), we do so to perform the contract we have concluded with you when you registered for your ESL Account. We also have a legitimate interest to process and transfer the data to the platform provider of the linked account, since you can freely choose to use this possibility and easily combine service features of ours and of the third-party platform.

d. Legal Basis
The legal basis for processing the data to enter into or perform a contract we concluded with you is Art. 6 para. 1 let. b) GDPR.

The legal basis for processing data based on our legitimate interest is Art. 6 para. let. f) GDPR.

e. How long
If you have linked your Dreamhack Account to another account, you can at any time unlink them under “Linked accounts”. Please note, that data you have shared during the linkage is stored by the third-party platform provider according to its retention periods. Please check that provider’s privacy notice for further information.

Your Dreamhack Account data is stored for as long as you maintain your ESL Account which can be closed anytime at your request or it will be closed automatically after four years of inactivity. Closed accounts will be permanently deleted after a period of 60 days.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

5. Ticketing System

a. What
When you purchase a ticket through one of the available ticketing platforms certain personal data is collected. When you buy the ticket using a third-party platform, the privacy notice of such third-party platform applies. We encourage you to read the applicable privacy notice prior to purchasing a ticket.

If you buy a ticket using the Dreamhack account, we will collect your email and ticket information, as well as information regarding your use of any promotion or discount codes, and all purchases will be part of your purchase history. We may also link the purchase of your ticket with personal data included in your account.

b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: Ticketing platforms.

Depending on the respective Tournament you participate in, it is possible that the Subsidiaries of ours jointly process personal data with us according to Sect. II.1.

c. Why
The personal data is processed to allow you to purchase tickets for Events and to send you the receipt of the ticket. Additionally, the personal data is processed to help us understand better your interaction with our services and products, and to improve them and serve you better.

d. Legal Basis
The legal basis for processing the personal data is our legitimate interest, in accordance with Art. 6 para. 1 let. f) GDPR.

e. How long
The personal data will be stored for as long as you do not withdraw your consent. You can at any time withdraw your consent. If you want to declare your withdrawal, please let us know under the

 

6. Tournament Sign-Up

a. What
When you sign-up for a tournament, we will process personal data of yours, including your name, nickname/gamer tag, age, in-game race, battletag, team or organization, Twitter handle, email, country, Discord ID, phone number, and ticket order number.

b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: Google.

Depending on the respective Tournament you participate in, it is possible that the Subsidiaries jointly process personal data with us according to Sect. II.1.

c. Why
The personal data is processed to allow you to participate in the tournaments, and to administrate and operate the tournaments, e.g. to broadcast the tournament, to issue press releases, to make seating arrangements, for payment of prize money, to see who is eligible to participate in certain Dreamhack tournaments, etc.

d. Legal Basis
The legal basis for processing the personal data is the performance of our contract with you, in accordance with Art. 6 para. 1 let. b) of the GDPR, as well as to comply with legal obligations, for which the legal basis is Art. 6 para. 1 let. c) of the GDPR.

e. How long
The personal data will be stored for the duration of the tournament, and for the statute of limitations of any actions that could arise in connection with the data processing. Tournament participation data can also be kept in your Dreamhack Account.

 

7. Prize Money & Other Payments

a. What
We process your bank details (e.g. IBAN, BIC etc.) together with your first and last name to be able to pay you a remuneration you might be entitled to due to a contract with us or to pay out prize money when you are the winner of a Tournament of ours and have a claim to such prize money according to the respective rules and to comply with legal obligations (e.g. tax laws). Without this personal data we are not able to make the respective payment.

If you have not given us the data yourself, we would like to inform you according to Art. 14 para. 2 let. f) of the GDPR that the sources of the mentioned data can be another person that acts on your behalf (e.g. you are a player or other personnel of a participating team and a team manager with power of attorney hands in your data to us).

b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: financial and IT services; Atlassian; Google (Workspace); SAP.

Depending on your contract or the respective Tournament you participate in, it is possible that the ESL Group jointly process personal data with us according to Sect. II.1. as well as third-party partners of ours according to Sect. II.2.

c. Why
The personal data is processed to perform our obligations of our contract with you, namely the payment of a remuneration or prize money. If a payment is made, the data is processed to comply with legal obligations, such as bookkeeping and taxes.

d. Legal Basis
The legal basis for processing the personal data for the performance of our contract with you is Art. 6 para. 1 let. b) of the GDPR. The legal basis for processing the data for compliance with our legal obligations is Art. 6 para. 1 let. c) of the GDPR.

e. How long
The data is stored at least for the time until our contract with you is fully performed. If a payment is made, the data will be stored for as long as the legal obligations we need to comply with require us to store the data or for as long as required to respond to legal claims.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

8. Compliance Checks for Prize Money Payments

a. What
We process personal data of yours, such as your name and bank account number and share this information with our bank to pay out your prize money. To fulfill certain financial and economic regulations, our bank can require us in specific cases to gather and transfer to it the following information of yours: your full name, birth date, place of birth, address and bank information (e.g. bank account number). It is possible that we will additionally require a copy of your ID (e.g. passport) to provide it to our bank. Should a copy of your ID be necessary, please mark it clearly as a copy before sending it to us (e.g. insert in capital letters “COPY” across the scan of your ID). If you have not provided us the data yourself, we would like to inform you according to Art. 14 para. 2 let. f) of the GDPR that the sources of the mentioned data can be another person that acts on your behalf (e.g. you are a player or other personnel of a participating team and a team manager with power of attorney hands in your data to us, or if your name appears on a public list).

b. Who
Recipients of the processed personal data are the respective internal employees of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: Financial and IT providers, especially our bank, can be the recipients of the data.

c. Why
We process your personal data and share it with our bank for the purpose of paying out your prize money and complying with financial and economic regulations (e.g. prevention of profits from criminal activities) that apply to money transfers. Should a legal obligation to process your data for compliance reasons apply to our bank (e.g. compliance with international sanctions lists to prevent terrorism and other criminal activities), as well as to us to assist the bank, we will cooperate accordingly with our bank, to ensure that you can receive your payment and that this happens in a lawful way. Our bank can be obliged to do such checks, e.g. according to Art. 2 para. 3 of the regulation (EG) Nr. 881/2002 and its amendments, Art. 3 para. 2 of the regulation (EU) Nr. 753/2011 or other applicable sanctions and regulations. Also, it is a legitimate interest of ours to cooperate accordingly with our bank, to ensure that you can receive your payment and that this happens in a lawful way, even if a legal obligation to process your data for compliance reasons should only apply to our bank (e.g. compliance with international sanctions lists to prevent terrorism and other criminal activities).

d. Legal Basis
The legal basis for processing the personal data for paying out the prize money as part of our contract with you is Art. 6 para. 1 let. b) GDPR. The legal basis for processing the data for compliance with the legal obligations of our bank is Art. 6 para. 1 let. c) GDPR. Should another regulation form the basis for an obligatory cooperation of ours with the bank, the legal basis is Art. 6 para. 1 let. c) of the GDPR in connection with the respective regulation. The legal basis for processing the data to comply with other compliance obligations based on our legitimate interest, is Art. 6 para. let. f) of the GDPR.

e. How long
We store the data at least for the time until our contract with you is fully performed. If a payment of prize money is made, the data will be stored for as long as the legal obligations we need to comply with require us to store the information or for as long as necessary to respond or defend from claims. Should a copy of your ID have been required by us for the payment of prize money, we will delete the copy after transferring it to our bank without undue delay.

 

9. Raffles

a. What
When you participate in a raffle that we conduct, we process the personal information required for such participation and for sending you your prize if you won. What data specifically is processed depends on the individual raffle you are participating in but commonly includes contact information of yours, such as your name, email address or social media account name. Should you win a prize we will process your contact details (name, address, email address). In some cases, we may require your age to make sure you meet our minimum age requirements.

Please note that your name and/or nickname can be made public over our media channels (e.g. our social media channels) and channels of a potential partner with whom we cooperate for the raffle (e.g. a sponsor) if you are a winner of a raffle (e.g. if you participate in a raffle that has an official announcement at the end).

b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes of processing your data. Possible further recipients: Google (Workspace); the partner with whom we may cooperate to conduct the specific raffle in which you participate; providers of raffle solutions, especially Gleam.

Depending on the specific raffle, it is possible that ESL and the Subsidiaries jointly process personal data with us according to Sect. II.1 as well as third-party partners of ours according to Sect. II.2.

c. Why
The purpose of processing your personal data for conducting the raffle and, if necessary, sharing your personal data related to the raffle with the sponsor, is making sure that you can participate properly in the raffle and we perform potential contractual obligations we may have towards you. We also have a legitimate interest in cooperating with our partners and sharing the information with them to enable your participation in the raffle (e.g. sharing your contact details with them so the partner can organize the shipping of your prize, should you not receive it from us directly or so we and our partner can publicly announce you as a winner).

If you do not conclude a contract with us when participating, but instead with our partner, we have a legitimate interest in receiving specific personal data of yours related to the raffle from our partner and using it to properly conduct the raffle (e.g. to be able to send you your prize we will need your contact details).

d. Legal Basis
If you conclude a contract with us regarding the raffle, the legal basis for processing and, if necessary, sharing your personal data with our partner is Art. 6 para. 1 let. b) GDPR. Insofar as the processing is based on our legitimate interest, the legal basis is Art. 6 para. 1 let. f) GDPR.

e. How Long
If you receive a payment from us as a prize, your data is stored for as long as the legal obligations we need to comply will require us to store the information for, as well as for as long as necessary to respond to or to defend from legal claims.

If you receive a non-monetary prize from us, we store your information for 3 years beginning with the end date of the raffle.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

10. Surveys

a. What
You can participate in surveys we may offer. Such surveys can either be accessible directly on our website or we may contact you via email or direct message to participate in a survey. In this case we process your IP address and the data you enter when answering the survey (e.g. a comment you make in a comment section, or a choice of a multiple choice question) and if we contact you via email or direct message to participate in a survey we process your email address and your name to address you personally.

b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes of processing your data. Possible further recipients: SurveyMonkey, Mailchimp, Google (Workspace).

c. Why
The purpose of processing your personal data for conducting the survey is improving the customer and user experience by respectively improving our products and services according to the answers of the survey. Such surveys can be considered as conducted for advertising purposes of ours.

d. Legal Basis
For advertising purposes, we will only use your e-mail address without your consent if we have received it from you in connection with a purchase of products or services of ours, and in accordance with applicable laws and on the basis of Art. 6 para.1 lit. f) GDPR. We have a legitimate interest in offering small surveys for the services and products of ours that are similar to products and services of ours you have purchased or made use of so we have information about your purchasing or user experience and can offer you even more attractive products and services in the future. You can at any time object to receiving such information that is not related to a newsletter subscription of yours free of charge.

For other surveys than these, we will ask you for your consent to process the data when conducting the service. In such case the legal basis is your consent according to Art. 6 para. 1 let. a) GDPR.

e. How Long
Data that we have obtained from surveys based on our legitimate interest is stored for as long as our legitimate interest applies. This depends on the number of participants and importance of the survey.

Data that we have obtained from surveys based on consent are stored until you withdraw your consent. You can at any time withdraw your consent. If you want to declare your withdrawal, please let us know under the following email-address: privacy@dreamhack.com. Please note that the withdrawal does not affect the lawfulness of processing of the data based on the consent before its withdrawal. If you are under the age of 16, the holder of parental responsibility for you (e.g. your parents) must give his/her/their consent or authorize your consent. Please contact us regarding this in such a case.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

11. Newsletters

a. What
You can request the receipt of our email newsletter which includes information about products, services, special offers or invitations to participate in various programs. To send you the newsletter we process your email address and name and statistical information on the reception of the newsletter by you. Additionally, we may add information on your interests to our newsletter database to personalize the newsletter you receive (e.g. if you have signed up for a newsletter in connection with a specific event we will add the information to our database that you are interested in such events).

We may also offer you the possibility to sign up for the newsletter of a partner of ours on a website that we manage for our partner (e.g. tournaments which we jointly conduct with a partner). In such case we collect and share the relevant personal data of yours that our partner requires to send you its newsletter.

Apart from a newsletter subscription we may send you information regarding Dreamhack and ESL products and services if we have received your email address or direct messaging in connection with products or services of ours (e.g. you have ordered products in the ESL shop or are a user of ESL Play) and we advertise products or goods of ours that are similar to such you have already purchased or used.

Included in a newsletter is a so-called “web-beacon”, a pixel-sized file which is retrieved from our server when the newsletter is opened or from its server in the case of the use of a mailing service provider. As part of this, technical information, such as information about the browser and your system, as well as your IP address and time will be collected. This information is intended to improve the technical performance of the service based on the technical data or the target groups and your reading behavior based on locations (which can be determined with the help of the IP address) or the access times. Likewise, it is determined if and when the newsletters are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. This is based on recognizing the reading habits of our users and adapting our content to them or sending different content according to the interests of our users.

b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes for the processing. Our newsletter is jointly maintained by us, DreamHack AB, ESL Gaming GmbH, and ESL Gaming Online, Inc. (“EGO”). Regarding the joint controllership between Dreamhack, ESL and EGO, please view the respective information under Sect. II.2. Possible further recipients: Mailchimp.

If you sign up for the newsletter of a partner over a website we manage for such partner, the partner is a recipient of your data. Possible further recipients: Mailchimp.

c. Why
The purpose of processing the personal data is to keep you updated on our products, services, special offers or invitations to participate in various programs or tournaments via email, according to your wish to receive the newsletter and improve your user experience with our services and products. This purpose also applies to information we may send you that is not part of a newsletter subscription when we advertise products or goods of ours that are similar to such you have already purchased or used.

We also have a legitimate interest in providing you the opportunity to receive a newsletter with information about events, services and products offered by Dreamhack, ESL or EGO (e.g. content related to ESEA, a service of EGO), since we, EGO and ESL cooperate together for esports events, and are all part of the ESL Group.

The purpose for collecting and sharing your information with our partner, should you sign up for partner’s newsletter over a website we manage for the partner, is to comply with your wish that the partner can send you its newsletter.

d. Legal Basis
The legal basis for processing your personal data for the newsletter you subscribed to is your declaration of consent, in accordance with Art. 6 para. 1 let. a) GDPR.

For information we may send you that is not part of a newsletter subscription, we will only use your e-mail address and name without your consent if we have received it from you in connection with a purchase of products or services of ours, and in accordance with applicable laws on the basis of Art. 6 para.1 lit. f) GDPR. We have a legitimate interest in informing you about attractive offers for you and to win you over as a customer or user or to receive information about your purchasing and user experiences regarding services and products of ours that are similar to products and services of ours you have purchased or made use of so we can offer you even more attractive products and services in the future. You can at any time object to receiving such information that is not related to a newsletter subscription of yours free of charge.

As far as consent is not a legal basis for the cooperation between us, ESL and EGO, the joint processing of the data is based on our legitimate interest and therefore on Art. 6 para. 1 let. f) GDPR.

The legal basis for sharing data with a partner, should you sign up for its newsletter over a website we manage for a partner of ours is Art. 6 para. 1 let. a) GDPR.

e. How long
Data that we use to send information based on our legitimate interest will be stored as long as our legitimate interest exists, and you have not objected. In case of an objection, your data will be blocked for such use and kept only as long as necessary to comply with our legal obligations.

The personal data will be stored for as long as you do not withdraw your consent. You can at any time withdraw your consent. If you want to declare your withdrawal, please click on the “unsubscribe” button included in all our communications or let us know under the following email-address: privacy@dreamhack.com. Please note that the withdrawal does not affect the lawfulness of processing of the data based on the consent before its withdrawal. If you are under the age of 16, the holder of parental responsibility for you (e.g. your parents) must give his/her/their consent or authorize your consent. Please contact us regarding this in such a case.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

12. Videos & Photos at Live Events

a. What
At our live events (e.g. e-sports tournaments or in person events) videos may be made and photographs may be taken. If you visit one of these events (e.g. as part of the audience, as a player or personnel of a team), it is possible that you will appear in such videos and photographs. Videos and photographs are published by us over our websites (e.g. the website of the specific event), or over other public media channels (e.g. Twitch).

In such case, we process your personal data (visual image, spoken word) by storing and using the videos and photos (e.g. publicly broadcasting the event live on TV or online-platforms or making videos and/or photos publicly accessible on demand online after the event) that include this data.

b. Who
Recipient of the processed personal data can be anyone that watches the event or views the videos and/or photos, either live or over media channels (e.g. online video streams) and platforms that provide these channels (Twitch, Google (YouTube)).

c. Why
The data is processed to conduct the event as a broadcasted live event (linear and digital), for marketing/advertising purposes, for protecting the photographer’s artistic expression, to ensure a reasonable quality standard of the event and a good viewer experience (e.g. capturing the reaction of the audience) and through this fulfilling the interest of fans and the general public in esports, and for the internal and external documentation and communication of the event. These are our legitimate interests.

d. Legal Basis
The legal basis for processing the data is Art. 6 para. 1 let. f) GDPR.

e. How Long
Your personal data will be stored by us as long as it is covered by our legitimate interests. The storage period is determined by the necessity of the establishment, exercise or defense of legal claims (Art. 17 para. 3 let. e) GDPR), especially regarding our intellectual property rights in the video and photo material (e.g. copyrights). Please note that we have no influence on the storage of public available data by other third-party controllers (e.g. other websites unrelated to us).

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

13. Social Media Presences

a. What
We have presences on social media platforms such as Facebook, Instagram and Twitter that help us connect to our fans and the esports community. We may also cooperate with some of our partners and maintain social media presences for games they publish or tournaments they host.

When you interact with a social media presence of ours (e.g. you comment a post of ours or write on our timeline), we process your name/nickname, profile picture and other personal data that your account may publicly display as well as personal data that you provide e.g. in a comment or post of yours.

b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for processing the data. Possible further recipients: the provider of the social media platform (Facebook, Twitter, Google (YouTube)); a partner of ours with whom we may cooperate for its social media presence.

c. Why
Your personal data is processed by us to effectively communicate with you within the social media platform (e.g. respond to posts and comments). This is a legitimate interest of ours and, if applicable, of our partner with whom we cooperate for its social media presence.

d. Legal Basis
The legal basis for processing data based on our legitimate interest is Art. 6 para. 1 let. f) GDPR.

e. How long
The data is stored for as long as we maintain the respective social media presence and you do not decide to delete your account or the respective post, comment or other interaction with us on the social media presence.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

14. Data of Minors

a. What
If you are the legal guardian of a minor who is under the age of 16 we may require that you consent to the processing of the minor’s personal data or authorize that the minor consents him/herself to the data processing. In such a case we process your name and email address together with the personal data of the minor to have proof that we obtained your consent as legal guardian.

b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for obtaining the consent. Possible further recipients: Atlassian; Google (Workspace).

c. Why
We process the data to be able to prove that we have complied with applicable data protection rules that require the legal guardian to consent to/authorize the processing of personal data of a minor.

d. Legal Basis
The legal basis for processing the data is Art. 6 para. 1 let. c in connection with Art. 8 para. 1 GDPR.

e. How long
The data is stored until you withdraw your consent/authorization. In the case of a withdrawal, we store the data for 3 years and one month starting with the end of the year in which you withdrew your consent.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

15. Job Applications

a. What
We process the personal data you provide when applying for a job or to work together with us or as a freelancer (e.g. your name, date of birth, address, your CV, etc.).

b. Who
Recipients of the processed personal data are the respective employees of ours that are responsible for pursuing our purposes for the processing (e.g. HR employees, your potential line manager and management). Possible further recipients: Bamboo; Google (Workspace).

Depending on the respective job you are applying for, it is possible that the ESL Group jointly process personal data with us according to Sect. II.1.

c. Why
The data is processed to decide if a contract with you will be concluded or, if you already have a contract with us, to perform our obligations or terminate the contract.

d. Legal Basis
The legal basis for processing the personal data is Art. 88 para. 1 GDPR in connection with the Swedish Discrimination Act (for applicants applying for an employment) or Art. 6 para. 1 let. b) GDPR (for applicants applying as freelancer).

e. How long
If we work together with you, your data is stored for the applicable statutory storage periods.
Should we not decide to work together with you, we will delete your application after the statute of limitations of claims that could arise, so we are able to defend ourselves against potential claims.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

16. Travel Bookings

a. What
Under certain circumstances it is possible that we offer assistance to you regarding the planning of your participation in the Tournament. This can include helping you book your travel to the Tournament. In such a case we process the personal data you provide us to book your travel (e.g. flights, hotel, shuttles) for you (e.g. your name, address, other information stated on the required identification documents, ID where needed). In some cases, it might be necessary to share your phone number or email so airlines and hotels can contact you directly should your booking change, or if they need to notify applicable health requirements.


If you have not given us the data yourself, we would like to inform you according to Art. 14 para. 2 let. f) GDPR that the sources of the mentioned data can be another person that acts on your behalf (e.g. you are a player or other personnel of a participating team and a team manager with power of attorney hands in your data to us).

b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes for the processing as well as companies that require the personal data to book your travel (e.g. hotels or airlines). Possible further recipients: Atlassian; Google (Workspace).

Depending on the respective Tournament you participate in, it is possible that the ESL Group jointly process personal data with us according to Sect. II.1. as well as third-party partners of ours according to Sect. II.2.

c. Why
The personal data is processed to help you plan your participation in the Tournament in consideration of your individual preferences and needs regarding your travel and to perform our contractual obligations by doing so, which we could not do without processing the data.

d. Legal Basis
The legal basis for processing the data for the abovementioned purpose is Art. 6 para. 1 let. b) GDPR.

e. How long
We process data that we need for the conclusion or the execution of a contract at least as long as it is necessary to take steps at your request to conclude a contract or to fulfill a contract between you and us. This depends on the duration of your contract or your team’s contract with us or on whether we are still in contact with you to conclude a potential contract. In case of claims that could arise in connection with the contract, we will store the personal data for as long as it is necessary to be able to defend ourselves against such claims, especially according to the respective limitation periods.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

17. Videos and Photos

a. What
During the Tournament we process your personal data (e.g. name, nickname, nationality) by publicly displaying the information. If you are a player or other associated personnel of a participating team that publicly acts for the team (e.g. in interviews), we additionally publicly broadcast and, if applicable, present live on a stage your visual image and spoken word to the audience of the Tournament during and after the Tournament (e.g. in recaps) in videos and photos.

b. Who
Recipient of the processed personal data can be anyone that watches the Tournament, either live or over media channels (e.g. online video streams) and platforms that provide these channels (Twitch, Google (YouTube)).

c. Why
The data is processed to conduct the Tournament as a broadcasted live event and to ensure a reasonable quality standard of the Tournament, e.g. by displaying information such as your name, nickname or nationality for the Tournament.

d. Legal Basis
The legal basis for processing the data is Art. 6 para. 1 let. b) GDPR and Art. 6 para. 1 let. f) GDPR. Broadcasting your image and spoken word during your performance in the Tournament is part of our performance of our contract with you as a participant and without such processing of the respective personal data we could not publicly conduct the Tournament. Also, it is a legitimate interest of ours to ensure a good experience of the live and online esports audience by broadcasting your image and spoken word and to make the content available to such an audience.

e. How long
Data that is processed based on Art. 6 para. 1 let. b) GDPR is stored at least for as long as it is necessary to perform the contract between you and us. This can be determined by the term of your contract. Personal data that is processed based on our legitimate interest, will be stored as long as it is covered by such legitimate interest. The storage period in such cases is determined by the necessity of the establishment, exercise or defense of legal claims (Art. 17 para. 3 let. e) GDPR), especially regarding our intellectual property rights in the video and photo material (e.g. copyrights).

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

18. Anticheat Software

a. What
Certain information regarding your computer and the software it contains is required for effective operation of our anticheat software. If you run an anticheat software that is required by us for participation in the Tournament on your device, information from it is collected and analyzed that is required to identify and prevent the use of cheat software, files used to gain an unfair advantage, and to enforce bans. Its installation and use on your device can be a requirement for participating in a Tournament. This information collection is not strictly limited to when you are logged into the anticheat software. Information analyzed or collected by the anticheat software may include hardware, network and software identifiers; running programs; system configuration information; files or data suspected of being used to cheat or gain an unfair advantage.

b. Who
Recipients of the processed personal data are the respective internal employees of ours or of the ESL Group when we work as joint controllers, that are responsible for pursuing our purposes for the processing. Possible further recipients: IT-services.

c. Why
The personal data is processed to ensure a fair and rule-compliant Tournament for you, the other participants and the audience and through this ensuring the integrity and credibility of our Tournaments as well as esports itself as a fair competitive sport. These are legitimate interests of ours. If competitions lack fairness and security, competitive games will lose players as well as audiences. Without processing the data, we cannot provide an anticheat software with the same effectiveness.

Also, if the use of anticheat software is required for a Tournament participation, the processing of data is done to perform the contract you conclude with us by participating in the Tournament as well as the contract regarding the use of the respective anticheat software itself by agreeing to the terms and conditions for its use.

d. Legal Basis
The legal bases for processing the data for the abovementioned purposes are Art. 6 para. 1 let. f) GDPR and Art. 6 para. 1 let. b) GDPR.

e. How long
We process the data as long as it is necessary to perform the contract between you and us. This can be determined by the term of your respective contract. Without the data we could not perform our contractual obligations with you. If entitlements to claims arise from the contract we store the data for the respective limitation period according to the applicable law. Personal data that is processed based on our legitimate interest, will be stored as long as it is covered by such legitimate interest. The storage period in such cases is determined by the necessity of the establishment, exercise or defense of legal claims (Art. 17 para. 3 let. e) GDPR), e.g. to have proof for a defense against unjustified claims by participants or teams who have verifiably cheated for prize money or rankings within the respective statute of limitations or according to the tournament rulebook.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

19. Integrity Partner

a. What
We work together with the Esports Integrity Commission Limited, Suite 129, 14 Chertsey Road, Woking GU22 5AH, United Kingdom (“ESIC”). Should we receive a request from ESIC that based on objective indications or evidence that you may have either violated our terms & conditions, tournament rules, or statutory laws of a country (e.g. through fraudulent behavior) we will provide ESIC personal data related to you that is required to make a conclusive assessment if such violation is given. The transfer of data will be strictly limited to only the purpose of making such an assessment.

b. Who
Recipients of the processed personal data are the respective internal employees of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: ESIC.

c. Why
Data transfers to ESIC are made to ensure fair and rule-compliant Tournaments for you, the other participants and the audience and through this ensuring the integrity and credibility of our Tournaments as well as esports itself as a fair competitive sport. These are legitimate interests of ours. If competitions lack fairness, competitive games will lose players as well as audiences. Without working together with ESIC, we cannot ensure the integrity of our Tournaments and esports in general with the same effectiveness.

d. Legal Basis
The legal basis for processing the data based on our legitimate interests is Art. 6 para. 1 let. f) GDPR.

e. How long
The data will be stored as long as our legitimate interests exist. This depends in particular on criteria such as the duration of the investigation of a rule violation on your part by us and ESIC.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

20. Press Releases

a. What
We may process personal data of yours when issuing press releases in connection with a Tournament that contain information about you and your performance in the Tournament. This can include especially your first and last name, nickname, nationality, picture, quotes and information about your performance in the Tournament (e.g. scores etc.).

b. Who
Recipient of the processed personal data can be anyone that reads or watches the media channels on which the press releases are issued (e.g. our website, updates for journalists), either live or over media channels (e.g. online video streams) and platforms that provide these channels.

c. Why
Since our Tournaments are events of public interest, the data is processed for the purpose of issuing press releases about your participation in our Tournaments over media channels and for editorial purposes connected to this.

d. Legal Basis
The legal basis for processing the data is Art. 6 para. 1 let. f) GDPR. It is a legitimate interest of ours to ensure a good experience of the esports audience and the general public to report on Tournaments as well as participants of and events in connection with such Tournaments. If reporting about you is part of an obligation in your contract with us, the legal basis for the data processing can additionally be Art. 6 para. 1 let. b) GDPR. Without the processing of the data we could not fulfill such an obligation.

e. How long
If data is processed to perform the contract between you and us, the storage period can be determined by the term of your contract. Personal data that is processed based on our legitimate interest, will be stored as long as it is covered by such legitimate interest. The criteria to determine this are especially the importance of the Tournament and events connected to it in the esports community, the public interest in the Tournament and events connected to it. The storage period can also be determined by the necessity of the establishment, exercise or defense of legal claims (Art. 17 para. 3 let. e) GDPR), especially if the press releases are protected by intellectual property rights of ours (e.g. copyrights).

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

21. Press Mailing List

a. What
If you are a journalist, you can sign up to our press mailing list to be updated by us on news regarding Dreamhack and esports. When you sign up, we collect your first and last name, email address and the name of the press outlet (e.g. magazine, news website, YouTube channel) you work for or operate yourself and store this information in our press mailing list.

b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: Google (Workspace).

c. Why
We process the data to keep you updated on Dreamhack brands, projects and products and other developments regarding Dreamhack and esports and communicate with you regarding these topics.

d. Legal Basis
The legal basis for processing your personal data for the receipt of our information through our press mailing list is your declaration of consent, in accordance with Art. 6 para. 1 let. a) GDPR.

e. How long
The data is stored as long as you have not withdrawn your consent. You can at any time withdraw your consent by sending a respective request to privacy@dreamhack.com. Please note that the withdrawal does not affect the lawfulness of the processing done prior to your withdrawal.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

22. Data Subject Requests

a. What
When you contact us to make use of your data subject rights (see section “Your Rights”), we process your name, email address and any additional information you provide us in your request or that we may need to make your request effective.

To make sure we can correctly identify you we may ask you to provide a copy of your passport or other identification document (“ID”). When you upload this information, we will process the personal data of yours stated on the ID, namely: your name, birth date, address and validity of the document. Please make any other data on the copy of your ID-document unreadable (e.g. serial number of the document) before the upload and mark the document as copy (e.g. add the imprint “copy” on it).

We kindly ask you to only use the portal in which your ticket was created for you after addressing us over privacy@dreamhack.com to upload the ID. Documents provided through any other channel are not accepted and will be deleted by us.

b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours and of ESL that are responsible for answering your request. Possible further recipients: Atlassian; Google (Workspace).

ESL and us jointly process personal data according to Sect. II.1.

Only the designated employees of ours and of ESL entrusted with privacy and data protection matters, and possibly employees that maintain our IT infrastructure, will view your ID. Processor processing your data on our behalf is Atlassian.

c. Why
The personal data of your request is processed for the purpose of answering your request – if necessary also with the help of ESL and the Subsidiaries or to answer such request for the Subsidiaries should it be directed at it – as well as the purpose of proving our compliance with the GDPR by helping you as data subject exercise your rights set out in the GDPR. This is also a legitimate interest of ours.

We process the ID data to verify your identity. This is required to prevent cases of fraud committed by using false identities. We have a legitimate interest in this purpose that outweighs a potential contrary interest of yours to not disclose this information, since we have a responsibility in protecting our users’ and partners’ personal data and since we will delete your ID promptly after we have verified your identity. The ID will not be used for any other purposes.

d. Legal Basis
The legal basis for processing the data of your request and – if necessary – sharing this information with ESL and the Subsidiaries is Art. 6 para. 1 let. c) in connection with Art. 12 GDPR as well as Art. 6 para let. f) GDPR.

The legal basis for ID verifications is Art. 6 para. 1 let. f) GDPR.

e. How long
The data of your request is stored for 3 years and one month starting with the end of the year in which you made your request.

The uploaded ID will be deleted promptly after we have verified your identity.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

23. Third Party Analytics Tools, Tracking Technologies (Cookies) & Consent Management

We use third party tools to analyze the use of our websites and services, to provide a better user experience for you when you use these or to display ads that may interest you. To make it easy for you to inform yourself about these tools and to withdraw a potentially necessary consent of yours or object to a processing based on a legitimate interest of ours, we have implemented consent management tools. You will find all information on what data is processed, who the recipient is, the purpose, legal basis and storage period in the banners or pop-ups where we ask for your consent.

You can at any time of course also contact us at privacy@dreamhack.com for further details or if you want to declare your withdrawal or objection to us processing your personal data.

 

24. B2B Partnerships

a. What
When we communicate and conclude contracts with you as a business partner (B2B only), we store certain personal data of yours in our B2B database, such as your business card, business email address, name, position and signature of the legal representative of the business or of the contact person for a contract, and other business information related to our (potential) partnership or contract with you.

b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: Google (Workspace); Salesforce.

Depending on the respective business partnership between you and us, it is possible that ESL and/or the Subsidiaries jointly process personal data with us according to Sect. II.1.

c. Why
The personal data is processed to decide if a contract with you will be concluded, to negotiate a contract with you or, if you already have a contract with us, to perform our obligations or terminate the contract.

We also have a legitimate interest in processing this data of yours to be able to remain in contact with you for business purposes. We have a legitimate interest in processing the information of B2B contacts with whom we have a contractual relationship or objectively likely will have a contractual relationship with in the future, since this is not only necessary to properly perform the contract between us and them, but also to facilitate communication with them concerning their cooperation with us. We also have a legitimate interest in processing the personal data of the B2B contacts who are currently not commissioned by us and not have been commissioned in the past, since it facilitates getting in touch with them for future projects.

d. Legal Basis
The legal basis for processing the personal data to enter into or perform a contract with you is Art. 6 para. 1 let. b) GDPR. The legal basis for processing the personal data based on our legitimate interest is Art. 6 para. 1 let. f) GDPR.

e. How long
Documentation regarding B2B contacts that we have concluded a contract with which is considered a commercial or business letter may be stored to comply with legal obligations and for a period equal to the statute of limitations of the claims that could arise in connection with the data processing.

Personal data of B2B contacts with whom we have no contract and have no objective reasons to believe we will be concluding a contract with, in the near future, will be deleted from our database after 3 years of inactivity.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

25. Legal Work

a. What?
ESL legal department, including the data protection department, works with Dreamhack to assess and manage legal matters. If a matter or dispute between you and us requires relevant legal review, we and ESL process the data relevant to the matter or dispute. In particular, this may include your name, e-mail address and contact details, as well as information on the dispute or claim.

b. Who?
The recipients of the personal data processed are ESL´s legal department and our respective employees and freelancers responsible for processing the matter. Possible further recipients: Google (Workspace).

Us and ESL jointly process personal data according to Sect. II.1.

c. Why?
The purpose of the processing of the personal data by us and ESL is the effective and uniform handling of legal matters. This is a legitimate interest of ours. In addition, the data processing may serve to conclude and perform contracts with you.

d. Legal Basis
As far as the data processing concerns the conclusion or performance of a contract with you, the legal basis of the data processing is Art. 6 para. 1 let. b) GDPR.

If the data processing is based on a legitimate interest, the legal basis is Art. 6 para. 1 let. f) GDPR.

e. How Long?
The storage period for data processed for the purpose of handling legal matters or disputes is governed by the relevant limitation period, so that we can sufficiently defend ourselves against claims, or by the relevant legal obligations to retain documents, in particular regarding tax, commercial, civil and employment related disputes.

If the personal data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

26. Measures to Prevent the Spread of the Coronavirus

a. What
As we prepare to go back to live Events or Tournaments, we make our highest priority to ensure that you are safe and healthy while taking part of such Events. For this purpose, we implement appropriate measures that help us prevent the spread of the Coronavirus, in accordance with guidelines and requirements of local authorities. Some of such measures can include requesting you to show a negative COVID-19 test result no older than a certain amount of hours, showing evidence or a certificate showing you have received a vaccine against the Coronavirus, asking you questions regarding your stay in countries considered of risk, or if you have or have had any symptoms of the COVID-19 disease.

When implementing the described measures, we will try, whenever possible, not to collect any personal data of you, however, if necessary, especially if a positive test result is shown, or if needed for healthcare providers, we will process such personal data to comply with legal obligations and health authorities´ requirements.

b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: health authorities, and/or healthcare providers, in case of emergencies.

c. Why
The personal data is processed to help prevent the spread of the Coronavirus, which in the public interest, as well as to comply with legal obligations.

d. Legal Basis
The legal basis for processing the personal data is your consent in accordance with Art. 9 para. 2 let. i) GDPR.

e. How long
The personal data will be stored for as long as necessary to comply with local health requirements, and after that it will be deleted. If you have any questions, you can contact us at privacy@dreamhack.com.

 

IX. Data Processing- Professional Tournament

In addition to the processing activities described before that may also apply to the processing of your personal data, when you participate in professional tournaments (e.g. such that you need to qualify for to participate in them), your personal data can also be processed as stated in this Section. Every processing activity is broken down into 5 parts:

(a.) What: What data is processed?
(b.) Who: Who receives the data?
(c.) Why: For what purpose is the data processed?
(d.) Legal Basis: What law allows us to process the data?
(e.) How Long: How long do we keep the data?

 

27. Tournament or Event Registration

a. What
To be able to plan and realize our professional esports tournaments (“Tournaments”), we require certain information from you (e.g. team managers), when registering for a Tournament. Therefore, we process the following data we require from you (“Required Data”):

  • First and last name;
  • Position within team (e.g. player position or team manager position);
  • Platform ID(s) for the respective game (e.g. ESL-ID);
  • Nickname used by players in the respective game;
  • Birthdates of players;
  • Nationality of players;
  • Country of residence of players.

 

Required Data is necessary for us to perform our contract with you and without it we do not have the necessary information to conduct the Tournament properly.

Additionally, to Required Data, we also process optional information which you grant us voluntarily (“Optional Data”). This can include, but is not limited to information such as:

  • Name of social media accounts of teams and players;
  • Phone numbers.

Required and optional data can be collected by us via a so called “teamsheet”. In such a case you can have the possibility to access the teamsheet and view the data you have provided us after handing in the teamsheet, making the processing of data more transparent and easier for you to make use of your right of access according to Art. 15 GDPR.

If you have not given us the data yourself, we would like to inform you according to Art. 14 para. 2 let. f) GDPR that the sources of the mentioned data can be another person that acts on your behalf (e.g. you are a player or other personnel of a participating team and a team manager with power of attorney hands in your data to us) or it is already known to us e.g. if we already know you personally or we have it from public databases such as liquipedia.

b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: partners of ours that are dedicated to broadcasting, coverage or other commercial engagements connected to the Tournament; Atlassian; Google (Workspace).

Depending on the respective Tournament you participate in, it is possible that ESL or the Subsidiaries jointly process personal data with us according to Sect. II.1. as well as third-party partners of ours according to Sect. II.2.

c. Why
Required Data is processed to be able to identify you as a player, team member or other associated personnel that will take part in one of our Tournaments, identify you as a (potential) contractual party of us and perform our respective contractual duties once a contract has been concluded between you and us (e.g. to register you as a participant of a Tournament, declare you as a winner of a Tournament or to display your name for the viewers of the Tournament). If you belong to personnel associated to a team and participate in such function in the Tournament (e.g. a team manager) we have a legitimate interest in identifying you as such for communication purposes in connection with the Tournament and informing the relevant audiences about you and your function within the team. Your date of birth is specifically required to assure you meet the minimum age requirements for participating in the Tournament. Your country of residence is specifically required to check if you meet the country specific requirements to participate in a Tournament. Further, certain Required Data can be processed to ensure a reasonable quality standard of the Tournament, e.g. by displaying information such as your name, nickname or nationality during a Tournament.

Your date of birth, country of residence, first and last name are processed based on our legitimate interest to comply with youth protection law, as well as to ensure our own rules regarding the age and country of residence of participants are followed and to prevent cases of fraud committed by using false identities. Your platform-ID(s) is/are processed to verify you as a legitimate player of the game and prevent cheating.

If your team is our contractual partner, it is in our legitimate interest to process the Required Data to be able to identify you, to conclude a contract with your team and perform our contractual obligations with your team, such as the examples mentioned in the previous section.

If you provide us with Optional Data, we have a legitimate interest in processing it to provide more detailed information for the interested esports audience, a better user experience and interesting and/or interactive information (e.g. displaying social media channels of players during a Tournament) on players in connection with the Tournament.

d. Legal Basis
The legal basis for processing the Required Data is Art. 6 para. 1 let. b) GDPR and Art. 6 para. 1 let. f) GDPR. Regarding the legal basis of Art. 6 para. 1 let. b) GDPR the data is required to conclude and perform a contract with you, which would not be possible without this information. If the processing is based on Art. 6 para. 1 let. f) GDPR, our legitimate interest is to be able to identify you, to conclude a contract with your team and perform our contractual obligations with your team or we may have a legitimate interest in identifying you as associated personnel of a team for communication purposes in connection with the Tournament and informing the relevant audiences about you and your function within the team. Further, we have a legitimate interest in using certain Required Data to ensure a good experience of the live and online esports audience, e.g. by displaying information such as your name, nickname or nationality during a Tournament.

Also, the legal basis for processing your date of birth, country of residence, first and last name is Art. 6 para. 1 let. f) GDPR. It is our legitimate interest to comply with youth protection law, as well as to ensure our own rules regarding the age and country of residence of participants are followed and to prevent cases of fraud committed by using false identities. The legal basis for processing your platform-ID(s) is Art. 6 para. 1 let. f) GDPR.

The legal basis for the processing of Optional Data is Art. 6 para. 1 let. f) GDPR. It is our legitimate interest to provide a better user experience and interesting and/or interactive information (e.g. displaying social media channels of players for fans to connect with them) on players in connection with the Tournament.

e. How long
We process data that we require for entering or performing a contract at least for as long as it is necessary for taking steps at your request to enter into a contract or to perform a contract between you and us. This is determined by the term of your contract and the contract of your team with us or if we still are in contact about concluding a potential contract.

Required Data that is processed based on our legitimate interest, will be stored for as long as it is covered by such legitimate interest. The storage period depends on the individual case and is determined by criteria such as the necessity to prove that youth protection laws have been complied with and for the establishment, exercise or defense of legal claims.

Optional Data that is processed based on our legitimate interest, will be stored for as long as it is covered by such legitimate interests. We will routinely check the data stored by us once a year and request your decision if required or Optional Data should be deleted, should we find that you have not participated in a Tournament within this time period or we are certain that you do not intend to participate in a Tournament in the future and no other legal basis and purpose for the processing of it applies. Of course, you are always free to contact us if you wish to have your data deleted sooner according to Art. 17 GDPR.

If you participate in a Tournament (especially in which you can win prize money), the data will not be stored longer than for as required to comply with legal obligations and to be able to defend ourselves against legal claims.

Please note that when you participate in a Tournament, the fact of your participation and the data that is naturally made public during a publicly broadcasted or conducted Tournament (e.g. you nickname, name and nationality) becomes known to the public and the recipients involved in the coverage of such esports events. We have no influence on the storage period of such data by third parties that do not act as processors on our behalf.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

28. Processing of Verification Data

a. What
In specific cases we may ask you to provide us a copy of your ID (e.g. passport or other document of identification) so we can properly verify your identity. These cases are:

  • When you participate in certain esports tournaments as a ESL Play user, pro player or personnel of a team we may need to verify your identity and that you comply with the rules of participation regarding age and country of residence;
  • Change requests for ESL Trusted accounts;
  • You lost your ESL account login credentials and can’t reset your account via email.

In these cases we process the respective data stated on your ID-document (e.g. passport or other document of identification) that you provide us. The data required from the ID-document for the age check includes: first and last name, birth date, country of residence (your address can be required if you request the change of your address of a ESL Trusted account or account recovery). Please make any other data on the copy of your ID-document unreadable (e.g. serial number of the document) before the upload and mark the document as copy (e.g. add the imprint “copy” on it). Apart from this data, we process any additional information you enter into the upload form which we require to understand the context of your request.

In the mentioned cases we cannot comply with your request without receiving the required information from you.


For pro players and their team personnel we have installed a designated secure upload portal where the documents can be provided. We ask you to only use this portal for such uploads. Documents provided through any other channel are not accepted and will be deleted by us.

If you have not given us the data yourself, we would like to inform you according to Art. 14 para. 2 let. f) GDPR that the sources of the mentioned data can be another person that acts on your behalf (e.g. you are a player or other personnel of a participating team and a team manager with power of attorney hands in your data to us).

b. Who
Recipients of the personal data are the respective internal employees of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: host providers; Atlassian.

c. Why
Depending on your specific case, we process the data to:

  • verify your identity, age and country of residence. This is required to comply with youth protection law, as well as to ensure our own rules regarding the age and country of residence of participants are followed and to prevent cases of fraud committed by using false identities;
  • verify that you are the legitimate person requesting to apply changes to your Trusted ESL account; or
  • verify that you are the legitimate person requesting access to an account to which regular access is not possible.

We have a legitimate interest in these purposes.

d. Legal Basis
The legal basis for processing the data is Art. 6 para. 1 let. f) GDPR as the purposes for the processing are in our legitimate interest.

e. How long
The uploaded ID-document will be deleted after we have verified your identity.

 

29. Creation and Maintenance of Team Presentations

a. What
We process personal information from publicly available sources to create and maintain publicly available team presentations, such as world rankings. This can include data such as nickname, nationality, event-performance, photos and team membership of players and personnel associated with the respective esports teams.

According to Art. 14 para. 2 f) GDPR we’d like to inform you that the sources of the mentioned data can be public databases such as liquipedia or if it is already known to us e.g. if we already know you personally.

b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours and of ESL that are responsible for pursuing our purposes for the processing. Possible further recipients: anyone who accesses the ranking over the website on which it is published; IT services; host providers; Google (Workspace).

Depending on the specific circumstances (e.g. the league you participate in) it is possible that Subsidiaries of ours jointly process personal data with us according to Sect. II.1 as well as third-party partners of ours according to Sect. II.2.

c. Why
The data is processed to inform our audience, fans, users and the general public about the current teams and developments in esports.

d. Legal Basis
The legal basis for processing the data is Art. 6 para. 1 let. f) GDPR. As an esports company, we have legitimate economic but also cultural interest in informing our audience, fans, users and the general public about the current teams and developments in esports.

e. How long
The data is stored for as long as our legitimate interests persist. The length of the storage period especially depends on if the data is still relevant to our audience, fans, users and the general public in which case our legitimate interest to exercise our freedom of expression and information outweighs a potential right of erasure.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

30. Video and Audio Material

Video and Audio Material of Professional Players for Preventing and Sanctioning Cheating

a. What
We generally process your image and spoken word as set out under Sect. VII. 15 for presenting a Tournament you participate in live on stage or broadcasting it over media channels (e.g. live streams).

In addition to this we may process your image and spoken word for additional video and audio material, if you are a pro player or personnel of a pro team participating in a Tournament. This includes:

  • recordings of the team conversation (e.g. over your dedicated team channel);
  • footage of player cams (e.g. a webcam that shows you playing at your computer);
  • room footage and conversations (e.g. while you play in your team HQ).

 

b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours and of any joint controllers that are responsible for pursuing our purposes for the processing. Possible further recipients: IT-services; Google (Workspace).

Depending on the respective Tournament you participate in, it is possible that Subsidiaries of ours jointly process personal data with us according to Sect. II.1. as well as third-party partners of ours according to Sect. II.2.

c. Why
Processing data from team conversations, player cams as well as room cams and mics during your performance in the Tournament is based on our contract with you as a participant.

We need to prevent cheating and fraudulent actions. If competitions lack fairness and security, competitive games will lose players as well as audiences. Processing the data to prevent cheating and fraudulent actions helps to ensure a fair and rule-compliant Tournament for you, the other participants and the audience and through this ensuring the integrity and credibility of our Tournaments as well as esports itself as a fair competitive sport. Maintaining the fairness of the Tournament is a core issue of our contract with the players and teams.

d. Legal Basis

The legal basis for processing the data for fraud prevention is based on Art. 6 para. 1 let. b) GDPR.

e. How long
Data that is processed based on Art. 6 para. 1 let. b) GDPR is stored at least for as long as it is necessary to perform the contract between you and us. The data will be deleted after potential claims against you are time barred.

 

Video and Audio Material of Professional Players for Promotion

a. What
We generally process your image and spoken word as set out under Sect. VII. 15 for presenting a Tournament you participate in live on stage or broadcasting it over media channels (e.g. live streams).

In addition to this we may process your image and spoken word for additional video and audio material, if you are a pro player or personnel of a pro team participating in a Tournament. This includes

  • recordings of the team conversation (e.g. over your dedicated team channel);
  • footage of player cams (e.g. a webcam that shows you playing at your computer);
  • room footage and conversations (e.g. while you play in your team HQ).

 

b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: IT-services; Google (Workspace); anyone that watches the Tournament, either live or over media channels (e.g. online video streams, our official photo platform) and platforms that provide these channels (Twitch, Google (YouTube)).

Depending on the respective Tournament you participate in, it is possible that Subsidiaries of ours jointly process personal data with us according to Sect. II.1. as well as third-party partners of ours according to Sect. II.2.

c. Why
Processing data from team conversations, player cams as well as room cams and mics during your performance in the Tournament is based on our contract with you as a participant. The data is processed to conduct the Tournament as a broadcasted live event and to ensure a reasonable quality standard of the Tournament.

If you ask us to record your team conversation for training purposes, we have a legitimate interest in recording and providing the material to you.

Should you have agreed to it, we may use your voice recording for commercial purposes (e.g. for advertising products that are not related to Dreamhack or Dreamhack tournaments or events).

d. Legal Basis

The legal basis for processing the data to conduct the Tournament as a broadcasted live event is Art. 6 para. 1 let. b) GDPR.

The legal basis for processing the data for recordal of your team conversation for training purposes, is based on your consent according to Art. 6 para. 1 let. a) GDPR.

The legal basis for processing your voice and other recordings for commercial purposes (e.g. for advertising products that are not related to Dreamhack or Dreamhack tournaments or events) is based on your consent according to Art. 6 para. 1 let. a) GDPR.

e. How long
Data that is processed based on Art. 6 para. 1 let. b) GDPR is stored at least for as long as it is necessary to perform the contract between you and us. The data will be deleted after potential claims against you are time barred. Any material where we own intellectual property rights in (e.g. photos) will be kept until expiry of the rights (e.g. copyrights).

Should we have recorded the material solely for your training purposes (based on your consent), we will delete it after we have submitted it to you.

Personal data that is processed based on your consent (e.g. for advertising products that are not related to Dreamhack or Dreamhack tournaments or events) will be stored for as long as you do not withdraw your consent. You can at any time withdraw your consent. If you want to declare your withdrawal, please let us know under the following e-mail address: privacy@dreamhack.com. Please note that the withdrawal does not affect the lawfulness of processing of the data based on the consent before its withdrawal.

 

31. Game Statistics

a. What
If you participate in a Tournament of ours as a player or associated personnel, we process your platform-ID(s) and nickname you (regularly only players) use in the respective game together with statistical information of the game you are playing in the Tournament (e.g. scores, number of kills, deaths, character choices etc.) and information about you as a player or associated personnel relevant for public presentation of the event and/or relevant for the interested public (name, birthday, teams, professional player profile picture, nationality) (“Statistical Data”). Statistical Data can be stored together with Optional Data you provide us (see above VI.3.).

If you have not given us the data yourself, we’d like to inform you according to Art. 14 para. 2 let. f) GDPR that the sources of the mentioned data can be another person that acts on your behalf (e.g. you are a player or other personnel of a participating team and a team manager with power of attorney hands in your data to us) or it is already known to us e.g. if we already know you personally or have it from public databases such as liquipedia.

b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: partners of ours that are dedicated to broadcasting, coverage or that statistically and analytically process sports data; Google (Workspace).

c. Why
Statistical Data is processed for our legitimate business interest to provide as an esports company game and player information from our Tournament that is relevant for our audience, the general esports audience as well as the interested public or to improve the experience of players as well as these audiences.

d. Legal Basis
The legal basis for the processing of Statistical Data is Art. 6 para. 1 let. f) GDPR. Statistical Data is processed for our legitimate business interest to provide as an esports company game and player information from our Tournaments that is relevant for the abovementioned audiences or to improve the experience of players as well as these audiences.

e. How long
Statistical Data is stored for as long as it is covered by our legitimate interest. The storage period depends on the individual case and is determined by criteria such as importance of the Tournament or public interest in the Tournament in which you’ve participated in or your ranking as a player.

Please note that when you participate in a Tournament, the fact of your participation and Statistical Data is naturally made public during a publicly broadcasted or conducted Tournament and becomes known to the public (e.g. the audience can view statistics on your performance within the game) and the recipients involved in the coverage of such esports events. We have no influence on the storage period of such data by third parties that do not act as processors on our behalf.

If the data is also processed for another purpose set out in this Privacy Notice, the storage period regarding that purpose applies as well.

 

32. Dietary and Other Health-Related Information

a. What
Under certain circumstances it is possible that we offer assistance to you regarding the planning of your participation in the Tournament. This can include such questions as your preferred meals, e.g. at the location where the Tournament is held. If you have any health conditions that require you to follow a certain diet (e.g. allergies) and other health-related conditions (e.g. disabilities that require special accessibility in a venue) relevant to the participation in the Tournament and you choose to share this information with us, we process this personal data of yours.

b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: Atlassian; Google (Workspace).

Depending on the respective Tournament you participate in, it is possible that Subsidiaries of ours jointly process personal data with us according to Sect. II.1.

c. Why
The personal data is processed to help you plan your participation in the Tournament in consideration of your individual health-based needs (e.g. ordering meals that do not contain ingredients to which you are allergic).

d. Legal Basis
The legal basis for processing the personal data is your consent in accordance with Art. 9 para. 2 let. a) GDPR.

e. How long
The personal data will be stored for as long as you do not withdraw your consent. You can at any time withdraw your consent. If you want to declare your withdrawal, please let us know under the following email-address: privacy@dreamhack.com. Please note that the withdrawal does not affect the lawfulness of processing of the data based on the consent before its withdrawal.

X. Data Processing in Specific Events or Tournaments

1. Dreamhack Beyond 

a. What
Dreamhack Beyond is a free hybrid gaming festival and online game. When you sign-up to participate in the event Dreamhack Beyond (or the “Event”), you will do so with your Dreamhack Account, therefore, please read especially the sections “Dreamhack Account”, “Account Linking” and “Ticketing System” of this privacy notice.

Dreamhack Beyond is an all-digital interactive experience. Players/attendees can enjoy the festival in any way they choose, by creating and customizing their character, collecting pets and cosmetics, cheering for their favorite teams, or by visiting themed halls and booths. Players will be able to compete and there will also be fighting gaming tournaments. In the booths you can find our partners, that will aim to give you a personalized experience.

When you choose to participate in Dreamhack Beyond, we can process your IP address, operating system, date and time of access, your interaction with the platform, if you participate in tournaments, places, or parts where you spend more time in, your interaction with booths and halls, and in general, your activity throughout the Event. This information can be associated with the Dreamhack Account with which you registered for the Event.

We will aggregate some of this information, in order to have a general overview of the Event, meaning that, for example, we will know which booth had the most visitors but, we will not identify you individually.

The booths in the Event are provided by third parties, and when you go to these booths you will have the option to leave the Event by clicking be redirected to the partner´s website, or to interact with the partner. The processing of any personal data you provide to third parties is processed in accordance with the partner´s privacy notice, therefore, we encourage you to read these privacy notices before clicking to be redirected to the partner´s website. We are not responsible for the interaction you have with our partners outside of the Event.

b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: Google (Workspace), our partner Super Crowd Entertainment (with address at Papenstr. 27a, 22089 Hamburg, Germany).

c. Why
The personal data is processed to allow you to participate in the Event and to understand better what participants like or enjoy in an Event of this type, so we can improve in future events and make them more relevant to you.

d. Legal Basis
The legal basis for processing the personal data is the performance of our contract with you, in accordance with Art. 6 para. 1 let. b) GDPR. The legal basis for the processing of aggregated data is Art. 6 para. 1 let. f) GDPR.

e. How long
The personal data will be stored for the duration of the Event and for as long as you keep it in your Dreamhack Account. Aggregated data is processed for our legitimate business interest to provide, as an esports company, events and tournaments that are relevant for our audiences, for our partners, and players, and to improve the experience players and participants have in our Events.

Other retention periods mentioned in the previous sections of this privacy notice may also apply.

XI. Changes to the Privacy Notice

We regularly review our Privacy Notice to make sure is kept up-to-date and compliant with new legislation, rules or case law. We reserve the right to make any changes. You can check when the Privacy Notice was last amended by looking at the date at the end of the document.

Last Update: July 5, 2021