Pryze Privacy Policy

Effective Date: June 7, 2024

OUR APPROACH TO PRIVACY

Frontier Esports (Private) Limited ("Pryze", "We", "Our", or "Us") is committed to protecting and respecting your privacy. This privacy policy sets out how We collect, store, process, transfer, share, and use data that identifies or is associated with you ("personal information") and information regarding our use of cookies and similar technologies. Frontier Esports (Private) Limited operates the Pryze application (collectively, the "Service"). This privacy policy applies to Our Service. Before accessing or using Our Service, please ensure that you have read and understood how We collect, store, use, and disclose your personal information as described in this privacy policy. We are the data controller of the personal information We hold about you. This means We determine and are responsible for how your personal information is used. We are committed to protecting the privacy of our users and the personal information they provide to us.

1. COLLECTION AND USE OF PERSONAL INFORMATION

1.1 Voluntary collection - We collect personal information that you voluntarily submit directly to Us when you register and use Our Service. This can include information you provide to Us when you register for an account, fill in a form on Our Service, create or edit your user profile on Our Service, correspond with Us by phone, e-mail, or otherwise, or subscribe to Our mailing lists, newsletters, or other forms of marketing communications, respond to a survey, post comments in discussion groups, enter a promotion, or use some other feature of Our Service.

1.2 Voluntary collection required for the Service - We will indicate to you where the provision of certain personal information is required in order for us to provide you with certain features of the Pryze Service, in particular, if you wish to credit your account/balance and/or withdraw all or part of your gains. If you choose not to provide such personal information, We may not be able to provide those parts of the Pryze Service to you or respond to your other requests.

1.3 Voluntary collection categories - Annex 1 sets out the categories of personal information We collect about you and how We use that information, as well as the legal basis on which We rely to process the personal information.

1.4 Automatic collection - We also automatically collect personal information indirectly about how you access and use Our Service and information about the device you use to access Our Service.

1.5 Automatic collection details - Annex 2 sets out the categories of personal information We collect about you automatically and how We use that information. Annex 2 also lists the legal basis on which We rely to process such personal information.

1.6 Combination of collections - We may link or combine the personal information We collect about you and the information We collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us.

1.7 Anonymization - We may anonymize and/or aggregate any of the personal information We collect (so that it does not directly identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving Our Service, and developing new products and features. We may also share such information with others.

1.8 Storage - We will store the personal information We collect about you for no longer than necessary for the purposes set out in Annex 1 and Annex 2, in accordance with our legal obligations and legitimate business interests. Please note that financial data may be kept for up to 10 years to comply with applicable anti-money laundering and counter-terrorism financing policies.

2. RECIPIENTS OF PERSONAL INFORMATION

2.1 Personal information sharing - In addition to the recipients listed in Annex 1 and Annex 2, We may also share your personal information with the following (as required in accordance with the uses set out in Annex 1 and Annex 2):

• Service providers and advisors: We may share your personal information with third-party vendors and other service providers that perform services for us or on our behalf, which may include providing mailing, email, chat services, payment services, identification verification services, fraud prevention, web hosting, or providing analytic services;
• Third parties through technology integrated with Our Service: We may collect certain personal information through software provided by our partners, such as third-party analytics services which We integrate into Our Service. This software may collect data that relates to tracking, installations, and downloads on the device you use by collecting mobile identifiers. These partners may have access to the personal information collected in this way in order to maintain this software and provide us with services, such as calculating usage analytics in relation to the Pryze Service;
• Affiliates: Other companies owned by or under common ownership as Frontier Esports (Private) Limited, including our subsidiaries (i.e., any organization We own or control) and our ultimate holding company (i.e., any organization that owns or controls us), and any subsidiaries it owns. These companies will use your personal information in the same way as We can under this Privacy Policy;
• Purchasers and third parties in connection with a business transaction: Your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control, or acquisition of all or a portion of our business; and
• Law enforcement, regulators, and other parties for legal reasons: We may share your personal information with third parties as required by law or if We reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Use; and/or (iii) exercise or protect the rights, property, or personal safety of Frontier Esports (Private) Limited, its Affiliates, its ultimate holding company, its users, or others.

3. STORAGE AND TRANSFER OF PERSONAL INFORMATION

3.1 Security - We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change, or damage. All personal information We collect will be stored on secure servers.

3.2 International Transfers of your Personal Information - The personal information We collect may be transferred to and stored in countries outside of Pakistan where We and our third-party service providers have operations. In the instance of such a transfer, We ensure that either:

• the personal information is transferred to countries recognized as offering an equivalent level of protection; and
• the transfer is made pursuant to appropriate safeguards. If you wish to inquire further about these safeguards used, please contact us using the details set out at the end of this privacy policy.

4. MARKETING AND ADVERTISING

4.1 Marketing and advertising communications - From time to time We may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.

4.2 Communication channels - Most marketing messages We send will be by email or text message to your phone. For some marketing messages, We may use the personal information We collect about you to help us determine the most relevant marketing information to share with you.

4.3 Opt-out - If you receive unwanted marketing communication from us or one of our business partners, you can use the unsubscribe link included in such communications to opt out of receiving future messages. Note that you will continue to receive emails regarding the transactions of products or services you have requested. We may also send you certain non-promotional communications regarding Our Service, and you will not be able to opt out of those communications (e.g., communications regarding potential evolutions of Our Service or updates to our Terms or this Privacy Policy).

5. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

In accordance with applicable privacy law in Pakistan, you have the following rights in respect of the personal information that We hold about you:

5.1 Consent withdrawal - You can withdraw your consent or refuse further data collection at any time. Withdrawing your consent will allow you to block the collection of data for these purposes and will de facto prevent the sharing of information with our analytics and/or advertising partners.

5.2 Right of access - You have the right to obtain:

• confirmation of whether, and where, We are processing your personal information;
• information about the categories of personal information We are processing, the purposes for which We process your personal information, and information as to how We determine applicable retention periods;
• information about the categories of recipients with whom We may share your personal information; and
• a copy of the personal information We hold about you.

5. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION (Continued)

5.3 Right of portability - You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

5.4 Right to rectification - You have the right to obtain rectification of any inaccurate or incomplete personal information We hold about you without undue delay.

5.5 Right to erasure - You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

5.6 Right to restriction - You have the right, in some circumstances, to require us to limit the purposes for which We process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

5.7 Right to object - You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and We will assess and inform you if that is the case. You can object to marketing activities for any reason.

5.8 Right exercise - If you wish to exercise one of these rights, please contact us at support@pryze.io.

5.9 Response delay - We will seek to respond to any request relating to your rights within one month of receipt of such request.

Where, given the complexity of the claim or the number of requests received, the above deadline cannot be met, We will inform you of the extended deadline in which We will respond to your request. Such extension may not be more than two months from the date on which We notify you that an extension is required.

5.10 Abusive requests - We are entitled to object to requests which are clearly abusive in their number or in their repetition. Where We do not follow up on your request, We will inform you within the one-month deadline of the grounds on which We have based our decision and of your right to refer a complaint to your national data protection authority.

6. LINKS TO THIRD PARTY SITES

Our Service may, from time to time, contain links to and from third-party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

7. OUR POLICY TOWARDS CHILDREN

Our Service is not directed at persons under 18 and We do not knowingly collect personal information from children under 18. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that We can take steps to remove such information and terminate any account your child has created with us.

8. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time and so you should review this page periodically. When We change this Privacy Policy in a material way, We will update the Effective Date at the start of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page.

9. NOTICE TO YOU

If We need to provide you with information about something, whether for legal, marketing, or other business-related purposes, We will select what We believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Service. The fact that We may send notices to you will not stop you from being able to opt-out of certain types of contact as described in this privacy policy.

10. CONTACT

10.1 Email - If you have any questions or concerns about our Privacy Policy, please contact us at support@pryze.io.

10.2 Data protection authority - You may lodge a complaint with a Data Protection Authority. Frontier Esports (Private) Limited being a company in Pakistan, our supervisory authority is: Pakistan Telecommunication Authority (PTA)

ANNEX 1 – PERSONAL INFORMATION VOLUNTARILY SUBMITTED

All the personal information listed below can be encrypted and uploaded to our servers with Google and/or Amazon Web Services.

Information We collect:

• Phone number - We may use this information to operate, maintain and provide to you the features and functionality of Our Service. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract. We may also use this information to send you marketing messages and/or ask for your feedback on our products and services. This processing is based on our legitimate interest. You are able to oppose such marketing communications by using the unsubscribe link included in each message or by contacting us as instructed in section 10 of this Privacy Policy.
• Profile information - We may use Username and Avatar information to identify users. The processing is necessary for Our Service.
• Date of Birth - We will use your Date of Birth in order to determine if you are eligible to use Our Service. Our Service is solely available for users above 18 years old. The processing is necessary for Our Service.
• Precise and non-precise geolocation - We will use geolocation in order to determine if you are in a country where our services are available. The processing is necessary for Our Service and also for Us to comply with Our legal obligations.
• Financial information - We may submit your financial information, including payment methods, to our payment providers, including Simpaisa, to allow deposits and withdrawals (see our Terms for additional details). The processing is necessary for Our Service. You can review Simpaisa's privacy policy here: http://bit.ly/3VkBUlj.
• Emails, SMS, chat messages, comments, and opinions - We may use this information to:
  • Operate, maintain and provide to you the features and functionality of Our Service. The processing is necessary for our legitimate interests, namely developing and improving Our Service or certain features of Our Service.
  • Address your questions, issues, and concerns, develop new products and features available through Our Service, or otherwise improve Our Service. The processing is necessary for our legitimate interests, namely developing and improving Our Service or certain features of Our Service.
  • Recommend content and other features available through Our Service. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.
• Information about your use of our Service - We may use this information to:
  • Operate, maintain and provide to you the features and functionality of Our Service. The processing is necessary for our legitimate interests, namely developing and improving Our Service or certain features of Our Service.
  • Address your questions, issues, and concerns, develop new products and features available through Our Service, or otherwise improve Our Service. The processing is necessary for our legitimate interests, namely developing and improving Our Service or certain features of Our Service.
  • Recommend content and other features available through Our Service. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.
• All potential information and identity documents necessary to complete our Know Your Customers (KYC) and Anti-Money Laundering (AML) obligations as described in our AML policies notably include a copy of valid IDs and proof of address. The processing is necessary for Our Service and also for Us to comply with Our legal obligations.
• All personal information set out above - We may use all the personal information We collect to operate, maintain and provide to you the features and functionality of Our Service, to communicate with you, to monitor and improve Our Service and business, and to help us develop new products and services. The processing is necessary for our legitimate interests, namely to administer and improve Our Service.

ANNEX 2 – PERSONAL INFORMATION AUTOMATICALLY COLLECTED

All the personal information listed below may be shared with the following third parties:

List of personal information collected automatically:

• Approximate location information - Other than the information you choose to provide to us, We do not collect information about your precise location. Your device's IP address may however help us determine an approximate location. We may use the information you provide to us about your location to inform and plan our marketing strategy. The processing is based on your consent in the appropriate settings of the Pryze mobile application.
• Information about how you access and use the Service - For example, how frequently you access Our Service, the time you access Our Service and how long you use it for, the approximate location that you access Our Service from, whether you access Our Service from multiple devices, and other actions you take on Our Service. We may use this information to:
  • Present Our Service to you on your device. The processing is necessary for us to provide Our Service to the users;
  • Determine products and services that may be of interest to you for marketing purposes. The processing is based on your consent to be served with “personalized advertising” in the appropriate settings of Our applications;
  • Monitor and improve Our Service and business, resolve issues, and inform the development of new products and services. The processing is necessary for our legitimate interests, namely to monitor and resolve issues with Our Service and to improve Our Service generally. When such analytics services are provided by third parties, the collection and processing of your information is based on your consent to “support and analytics” in the appropriate settings of Our applications.
• Log files and information about your device - We also collect information about the computer, tablet, smartphone, or another electronic device you use to connect to Our Service. This information can include details about the type of device, unique device identifying numbers (such as your Google Advertising ID), operating systems, browsers, and applications connected to Our Service through the device, your mobile network. We may use this information to:
  • Present Our Service to you on your device. The processing is necessary for us to provide Our Service to the users;
  • Determine products and services that may be of interest to you for marketing purposes. The processing is based on your consent to be served with “personalized advertising” in the appropriate settings of Our applications;
  • Monitor and improve Our Service and business, resolve issues, and inform the development of new products and services. The processing is necessary for our legitimate interests, namely to monitor and resolve issues with Our Service and to improve Our Service generally. When such analytics services are provided by third parties, the collection and processing of your information is based on your consent to “support and analytics” in the appropriate settings of Our applications.