Privacy Policy

Effective: August 28, 2019

PURESKILL.GG, THE FIRST PRODUCT OF FPS CRITIC, LLC, IS A NORTH CAROLINA LIMITED LIABILITY COMPANY (“PURESKILL.GG,” “COMPANY”, “WE,” “US,” OR “OUR”) provide the websites https://pureskill.gg/, https://csgo.pureskill.gg/ , and  https://pureskill.app as (collectively, the “Website”) and an automated service that analyzes a purchaser of our products and services (each, a “User”) game replay file and provides a skill assessment as well as tailored feedback on opportunities for improvement.  Depending on the products purchased and/or services provided, Users may also receive additional commentary, statistics, and tables to reflect comparison to other players. (the “Game” and, with the Website, the “Services”).

This privacy policy (“Privacy Policy”) sets forth our policy about what information we collect from users when they use the Services and how we use, maintain, and disclose such information. This privacy policy does not apply to other websites or services not operated or controlled by us (e.g. your Steam account administered by Valve Corporation). Under applicable law, Pureskill.gg is the “data controller” of personal data collected through the Services.

Please read this Privacy Policy carefully to understand our practices regarding the collection and treatment of your information. Do not use the Services unless you consent to our collection, maintenance and use of your information as described in this Privacy Policy.

For our data collection practices regarding children, please see the Children’s section later in this Privacy Policy.

Personal information

We may collect some personal information from you in accordance with this Privacy Policy and applicable law. The ways in which we collect personal information and our policies governing its maintenance, use, destruction and disclosure are described in this Privacy Policy. “Personal information” means any information that can be used to personally identify you, such as your name, postal address, email address, telephone number, voice, social security number, IP address, “personal data” (as that term is defined Article 4(1) of the General Data Protection Regulation), other identifiers by which you may be contacted online or offline, and other similar types of information under applicable law. Additionally, “Personal information” may include some non-personal information when it is linked with other types of personal information or non-personal information

HOW WE COLLECT YOUR INFORMATION

When you use the Services, we may collect information from you in the following ways:

Information from Third Party Platforms. We may automatically receive your personal information from third parties (e.g. Valve, other game developers, etc.). Personal Information collected by the third-party platform that you use to access (e.g. your Steam account administered by Valve Corporation) is subject to the applicable third-party terms of use and/or privacy policy (for more information, please see Steam’s Privacy Policy Agreement). Our use of your personal information collected through the Game is limited to the purposes described in the “How We Use Your Information” section below.

Registration. If you “register” an account with us, you will be required to provide personal information. To register, you may be prompted to provide us with an email address and a password. When you register, we will send you an email to verify your email address and complete the registration process. Users should not pick a password that is easy to guess and should not share their password.

Direct communications with us. If you send us or one of our representatives an email or otherwise correspond with us directly, we will have access to any information that you provide to us in such correspondence. Please limit any personal data to a minimum (i.e. only so much as is necessary to respond to your request). Our Terms of Service (available at http://www.pureskill.gg/terms-of-service) (the “Terms of Service”) also govern our use of and ownership of information that you provide to us in direct communications.

Cookies. We may use cookies in connection with automatic data collection through the Website. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system may issue cookies when you access the Website.

WHERE INFORMATION IS PROCESSED

We’re based in the United States of America. All information that you provide to us is stored on secured servers located in the United States of America using firewalls. No matter where you are, you consent to the processing and transferring of your information, including personal information, in and to the United States of America and other countries. Laws that apply to the collection, maintenance and use of information in the United States of America (or any other country) may not be as comprehensive or strict as the laws of the country where you’re located.

OUR BASES FOR HANDLING YOUR PERSONAL DATA

Some jurisdictions may require us to describe our legal bases for using or disclosing personal data that we may possess. Where such laws apply, our legal bases for processing personal data are as follows:

  • Fulfillment of any purpose for which you have provided your consent;
  • Compliance with applicable law;
  • Exercise of our legitimate interests in:
    • Endeavoring to provide an experience for Users to improve their gaming skills;
    • Responding to customer service inquiries and providing customer service;
    • Making our Services better and improving our business overall; and
    • Addressing legal issues.
  • Fulfillment of our contractual obligations to our Users; and
  • Working to protect you and other users.

HOW WE USE YOUR INFORMATION

Our policy is to use your information in a way that is consistent with and subject to this Privacy Policy.

Where you’ve provided information to us for a specific purpose (e.g., to help us troubleshoot an issue you’re having with the Service), we’ll use your information in furtherance of that purpose.  If you use our Services, you expressly grant us the right to make automated decisions in connection with the processing of your personal information. For all visitors to Website (i.e. who do not use our Service) we follow the laws in certain jurisdictions and do not use automated decision-making in connection with the processing of your personal information.

We, including our affiliates and subsidiaries, may also use your personal information:

  • To offer, operate, maintain, and improve the Services;
  • To present the Services to you;
  • To operate all features within the Services;
  • To investigate violations of our Terms of Service and attempt to prevent additional violations;
  • To provide you with notices about your registration;
  • To notify you about changes to the Services or any of our related products or services; and
  • For any other purpose with your consent.

Also, where you have given us permission to do so, we may use your information to send you news and updates about our products or services, including special offers and promotions. When we send you news or updates, we’ll also tell you how to opt out of receiving such notices.

DISCLOSURE OF YOUR PERSONAL INFORMATION

We do not share or otherwise disclose your personal information with or to third parties except:

  • With your consent;
  • As may be necessary to protect your safety or the safety of other users;
  • To our affiliates and subsidiaries, to the extent consistent with this Privacy Policy ;
  • To our lawyers, consultants, accountants, business advisors and similar third parties who owe us duties of confidentiality;
  • In the event of a sale, merger, reorganization, bankruptcy, dissolution or other similar event, where the information of users is among the assets to be transferred;
  • To enable us to take precautions against liability;
  • To protect the safety and security of the Services;
  • Where required to do so by law or legal process; or
  • Where it is in aggregated and/or non-personally identifiable form.

CHILDREN UNDER THE AGE OF 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal data to the Website, Service, or the Company. We do not knowingly collect personal data from children under 13. If you are under 13, do not use or provide any information on the Websites or provide any personal data or other information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal data from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at legal@pureskill.gg.

DATA SECURITY AND RETENTION

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. When you directly provide us with personal information, including through registration, we will encrypt that information using technologies consistent within our industry. We may retain data collected from you, including personal information, to support customer service inquiries and prevent violations of the Terms of Service. We may retain your information for as long as is necessary and relevant to your use of the Services and our operations, which may include retaining your information beyond the end of your use of the Services. To dispose of personal information, we may anonymize it, delete it or take other measures we deem to be appropriate. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures used in the Services.

DATA SUBJECT RIGHTS

We work to respect the privacy rights of all users, regardless of where they live. Accordingly, except as otherwise provided in this Privacy Policy , we will promptly act on Users’ requests that we:

  • Confirm that we have their personal data;
  • Provide them with access to their personal data that we possess, including in portable format;
  • Correct, update or amend their personal data;
  • Delete and “forget” their personal data;
  • Object to our use or disclosure of their personal data; and
  • Limit our processing of their personal information.

Users may withdraw any consent they have provided us to process their personal information. Exercise of any of the rights listed in this section usually doesn’t apply retroactively from the date of the request and doesn’t affect our ability to continue processing information lawfully. Note that the rights enumerated in this section have certain limitations and exceptions under applicable law.

If you’d like to exercise any of the data subject rights described in this section, please reach out to us by email at legal@pureskill.gg. To help us process your request more quickly, please put “Exercise of Data Subject Rights Notice” in the subject line of the email, and include an explanation of the right or rights intend to exercise. We may use your personal information to verify your identity before acting on your request.

Lastly, users will always have the right to lodge a complaint about our privacy practices with the appropriate supervisory authority. However, we’d much rather you contact us first at legal@pureskill.gg, so we can try to address any concerns that you have about our privacy practices.

CHANGES TO PRIVACY POLICY

We may update this Privacy Policy  from time to time, so please review it frequently. We will post any new or updated Privacy Policy  on our Website, and attempt to notify you by email using the email address provided to us through the registration process, if applicable.

The date the Privacy Policy  was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this Privacy Policy  to check for any changes.