Effective Date: 7 February 2020
The provision of personal data is a requirement of creating a Mogul account and will be processed on the legal basis that consent is given by a user when creating a Mogul account. We collect, use and disclose information for the purpose of and based on the legitimate interest of administering, monitoring, and improving the Mogul Sites, the features and content, to provide and improve the Services and verify that users of the Services meet the criteria required to process their requests. We do this so as to improve user experiences for Mogul Site visitors, customers, and users of our Services.
Mogul will store your personal data for up to 3 years after your account is last active after which time it will be deleted. You have the right to withdraw consent at any time, however if you do, your Mogul account will be deleted. You have the right to request access to, rectification of erasure of hour personal data at any time, as well as to request the restriction of processing. Please note that there may be legal or other reasons for us to retain your personal information, in which case we will provide you with written notification. You also have a right to data portability. To exercise a right, please contact Mogul at email@example.com or Mogul's Data Protection Officer (currently Jamie Skella, at firstname.lastname@example.org).
How We Collect Information; Kinds of Information We Collect
You consent to us collecting information by using "log data" and "cookies," by obtaining information from your usage of our Services, and by asking for information when you buy a product, register for and/or use a Service, or do various other things, as described below.
Log Data. You agree that when you visit the Mogul Sites, whether as a non-registered visitor just browsing or as an individual who has registered via the Mogul Sites (any of these, a "Mogul User"), our servers may automatically record information that your browser sends whenever you visit a website ("Log Data"). This Log Data may include information such as your computer’s Internet Protocol ("IP") address, browser type, the webpage you were visiting before you came to a Mogul Site, pages of the Mogul Sites that you visit, information you search for on our Mogul Sites and other statistics.
Cookies. Like many websites, we use "cookies" -- small data files transferred to your computer’s hard disk – to collect information. We use two kinds of cookies. First, we utilize session ID cookies to enable certain features of the Mogul Sites, to better understand how visitors interact with the Mogul Sites, to monitor aggregate usage by Mogul Users, and to monitor web traffic routing on the Mogul Sites. Second, we utilise persistent cookies for persons who have registered with Mogul to save their login information for future logins to the Mogul Sites. While session cookies are deleted from your computer when you log off from the Mogul Sites and then close your browser, persistent cookies remain. You can set your browser to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Mogul Sites or all functionality of the Services.
Pursuant to GDPR and the ePrivacy Regulations, below is a listing of cookies that exist on the Mogul platform.
|Cookie or Pixel||Usage||Expiration|
|AWSALB, AWSALBCORS||Amazon AWS – Used for server selection and load balancing while serving content for the Mogul platform.||7 Days|
|_ga, _gat, _gid||Google Analytics – Used for internal business intelligence and data analytics tracking on the Mogul Platform.||2 Years|
|userLanguage||Mogul – Stores the set language for use on various Mogul services.||1 Year|
|pusherTransportTLS||Pusher – Used to configure the realtime data provider, Pusher, for dynamic updates of content on Mogul.||1 Year|
|hubspotuk, _hssc, _hssrc, _hstc, _ptq.gif||HubSpot – Enables user activity logging and constant contact with users on Mogul.||1 Year|
|JSEDSSIONID||Adyen – Establishes a secure session with our payment provider, Adyen, for payments of subscriptions on Mogul.||Immediately|
|fs_uid||Fullstory – Records user activity and mouse movements within the Mogul user interface so that we may refine the display of elements on our platform.||1 Year|
|_fbp, fr, ft||Facebook – Used for marketing and platform activity with Facebook Business and Ad Manager.||90 Days|
|personalization_id, i/adsct||Twitter – Used for user activity tracking and activity within Mogul and Twitter.||Immediately|
|_gcl_au, ads/ga-audiences, pagead/1p-user-list/#||Google AdSense – Used for user activity tracking and marketing management within Google.||Immediately|
|IDE, test_cookie||Google DoubleClick – Used for marketing management of the DoubleClick advertising network.||Immediately|
You may manage your cookie consent at any time, or remove any existing cookies from your browser by following the browser-specific cookie deletion method.
Personal Information. We ask for and/or receive Personal Information from you. At times, we ask you for personally identifiable information – information about you that can be used to identify you by itself or together with information which we have or are likely to have access to ("Personal Information") – which includes, but is not limited to, your name, photo, phone number, email address, website URL, instant message contact information, and postal address. We may also ask for and/or obtain other information such as your age, gender, [post or zip code], country and individual preferences. We ask for Personal Information in a number of situations, including when you register a product, purchase or register for a Service, sign up for a Promotion, opt-in to receive email notifications, in connection with your request for an offering or for personalisation of the Services you use or when you contact us via the Services, or other situations. In addition, we also obtain Personal Information by collecting and maintaining data on your use of Services, such as information on frequency, time and duration of use, and similar. You do not have to provide your Personal Information, but then certain features, offerings or Services may not be available to you, or you may not be able to complete a transaction. We use your Personal Information mainly to provide the Services, complete your transactions, and verify your identity to administer or respond to your inquiries or prevent fraud, or similar. We may also anonymise your Personal Information so that you are no longer identifiable from it and aggregate it with such information collected from other Mogul Users and with log data and/or data from cookies to attempt to provide you with a better experience, to improve the quality and value of the Mogul Sites, the Services, and/or our products, and to analyse and understand how the Mogul Sites and/or Services are used. We may also use the combined information without aggregating it to serve you specifically, for instance, to deliver a product or Service to you according to your preferences or restrictions. Mogul uses automated decision-making in order to improve the user experience based on a user's interaction with the Mogul sites and tournaments.
Specific examples where we ask for or receive your Personal Information include the following:
Information Sharing and/or Disclosure
Advertising Networks and SNSs
Reviewing, Updating or Deleting Your Information
Each user may review, update, correct or have us delete the Personal Information he or she provided for or during use of the Services by contacting us at email@example.com. If you have us completely delete all such information, then your account for your use of the Services may become deactivated, as applicable, and you may no longer be able to use or access the Service. We may retain an archived copy of your Personal Information as required by law or for legitimate business purposes.
Our Policy Toward Children
The Services are not directed to persons under 18. We do not knowingly collect Personal Information from children under 15. If you as a parent or guardian become aware that your child has provided us with Personal Information without your consent, contact us at firstname.lastname@example.org. If we become aware that a child under 15 has provided us with Personal Information without the consent of a parent or guardian, we will delete such information from our files, but may retain an archived copy as required or permitted by law for record keeping purposes.
Identity theft and the practice currently known as "phishing" are of great concern to Mogul. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, ask for your credit card information, login information, or national identification numbers through use of a non-secure or unsolicited e-mail or through a telephone communication that we initiate without either a prior inquiry from you or a prior arrangement with you. For more information about phishing, visit https://www.csa.gov.sg/gosafeonline/go-safe-for-me/homeinternetusers/spot-signs-of-phishing.
Mogul is very concerned with safeguarding your information. We employ reasonable physical, technological, and administrative security measures to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to your information. It is important to understand, however, that no website, server, Internet transmission, or method of electronic or other storage is 100% secure or "hacker proof." Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your electronically stored "personal data" (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Mogul Sites in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Your information may be transferred to — and maintained on — computers located outside of your country or other governmental jurisdiction. When we send your Personal Information outside of your country, we will make sure that your information is protected to at least the same standard as that which is required by law in your country. Mogul maintains, processes and uses Personal Information in Singapore. If you submit or choose to provide information to us, you consent to such transfer, maintenance, processing and use.
Links to Third-party Sites
Our Mogul Sites contain links to other websites. The fact that we link to a website is not an endorsement, authorisation or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
If you have any concerns or a complaint about a breach of your privacy or the way we have handled your personal information, please email us at email@example.com and inform us of the nature of your complaint.
We will then investigate your complaint and endeavour to provide you with our response within a reasonable time (between 30-90 days dependent on your jurisdictional law) of receiving your request. If, after receiving our response, you still consider that your privacy complaint remains unresolved, you may then, for example, refer your concern to the privacy regulator in the country where you reside.
Mogul's details are as follows:
Name: SEA Esports PTE LTD
Phone Number: +61 3 8630 3315
Level 21, 459 Collins Street