Privacy policy

Updated: 01 January 2024

Welcome to GoodGame Limited’s (“GeeGee”, “we”, “us” or “our”) website and mobile application (“Platform”).

This PrivacyPolicy sets out our, and your, rights and obligations in relation to personal information (as defined in the Privacy Act 1993) provided through the use of our Services. By using our Services, you agree to follow and be bound by the terms and conditions of this Privacy Policy and the User Agreement.

If you have any concerns about providing personal information to us or having such information displayed on our Service or otherwise used in manner permitted in this PrivacyPolicy and the User Agreement then you should not become a Member and you should not use our website, mobile application or use any of our otherServices. Capitalised terms used in this Privacy Policy have the same meaning as set out in the User Agreement (unless otherwise defined in this PrivacyPolicy).

1. Collection of personal information

Personal Information is collected in the following ways:

1.1. Registration Information

When you create an account with GeeGee we collect information including your name and phone number. You may provide additional information during the registration process including your location, sports you are interested in and any other information that we request. Collectively, this information that you provide is the “RegistrationInformation”.

To create an account on GeeGee you must provide the RegistrationInformation and agree to the User Agreement and this Privacy Policy which govern how we treat your Registration Information. This RegistrationInformation is used to help you build your GeeGee profile and to provide you with more customized services, updates and notifications. You understand that by registering as a Member, we and other Members will be able to identify you by your GeeGee profile.

If you choose to link your social network (such as Facebook, Instagram or Google) accounts, we may collect information from these social media services, including your contact lists for these services and information relating to your use of the Platform in relation to these services.

1.2. Other Personal Information

We collect personal information when you fill out your GeeGee profile. You can complete or edit the GeeGee profile at any time after registration. You may choose to populate your profile with additional information which can be provided as a mix of textual or visual (photographic and video) content.

We collect this information to simplify and enhance the quality of your experience on the Platform..

We may also provide recommendations to you about other users to engage with and follow, Microsports that we consider match your criteria and other updates and notifications. Providing additional information enables you to derive more benefit from our Services.

1.3. Customer Services

We collect personal information when you contact our customer support team.

When you contact our customer support services, we may have to access your account to respond to your questions and if applicable, investigate any breach of the GeeGee User Agreement or this Privacy Policy. We also use this personal information to track potential problems and trends and customise our support responses to better serve you. We do not use this personal information for advertising.

1.4. Using GeeGee

We collect personal information when you supply user-generated content including comments, photographs, videos and virtual item videos that you choose to upload or broadcast on the Platform (“User Content”).

For example, we collect personal information when you install our applications onto mobile devices, and create and or participate in a Microsport. If you are logged into your GeeGee account or one of our cookies on your device identifies you, your usage information and log data (described below) such as your IP address, will be associated by us with your account even if you are not logged into a Service or your GeeGee account. We log information about devices used to access our Services, including IP addresses.

1.5. Cookies

We use cookies and similar technologies that can identify details of your IP address, device platform (e.g. Windows, Mac OS, iOS or Android),browser (e.g. Internet Explorer, Edge, Safari, Chrome or other, plus the version of the browser), domain (whether you are accessing the Services fromNew Zealand or elsewhere) and other user information (e.g. your username) to collect information.

We use cookies and similar technologies, including mobile application identifiers, to help us recognize you across different Services, learn about your interests both on and off our Services, improve your experience, increase security, measure use and improve the effectiveness of ourServices. You can control cookies through your browser settings and other tools. By visiting our Services, you consent to the placement of cookies and beacons in your browser and HTML-based emails in accordance with this PrivacyPolicy. You can choose to refuse cookies by turning them off in your browser and/or deleting them from your hard drive. You do not need to have cookies turned on to use the Services but you will need them to log on to the Services and to access personalised or secure content on the Services. Some pages may not function properly if the cookies are turned off.

1.6. Using Third-Party Services andVisiting Third Party Websites

GeeGee collects information about you when you use your account to sign in to other websites or services and when you view pages that include our plugins and cookies.

We receive information about your visits and interaction with the sites and services of our partners that include our cookies and similar technologies, unless you disable such technologies.

1.7. Log Files, IP Addresses and information about your computer and mobile device

We collect personal information from the devices and networks that you use to access our Services.

When you visit or leave our Services (whether as a Member or aVisitor) by clicking a hyperlink or when you view a third party site that includes our plugin or cookies (or similar technologies), we automatically receive the URL of the website from which you came from or the one to which you are directed.

1.8. Other

We are constantly innovating to improve our Services and your experience which means we may create new ways to collect information on theServices in the future. Our Services are a dynamic, innovative environment and we are always improving  the Services we offer you. We often introduce new features, some of which may result in the collection of new information. Furthermore, new partnerships or corporate acquisitions may result in new features, and we may potentially collect new types of information.

If GeeGee starts collecting substantially new types of personal information and materially change how we handle your personal information and other content you introduce to the Services, we will modify this Privacy Policy and notify you.

2. How we use, disclose and share your personal information

2.1. GeeGee using information about you

Information you provide on your profile cannot be seen by others unless you make it publicly available, but it can be seen and used by us as described in this Privacy Policy and our User Agreement.

The personal information that you provide to us may reveal or allow others to identify aspects of your life that are not expressly stated on your profile. By providing personal information to us when you create or update your account and profile, you are expressly and voluntarily accepting the terms and conditions of our User Agreement and freely accepting and agreeing to our processing of your personal information in the ways set out by this PrivacyPolicy.

You can withdraw or modify your consent to our collection and use of the personal information you provide at any time in accordance with the terms of this Privacy Policy and User Agreement by changing your account settings or your profile on GeeGee or by closing your GeeGee account in accordance with clause 3.1.

2.2. GeeGee Communications

We communicate with you through notifications published on theWebsite or partner websites, SMS, messages to your GeeGee inbox and other means available through the Service, including mobile text messages and push notifications.

We may send you messages relating to the availability of theServices, security, or other service-related issues. You agree that we may also may send promotional messages to your GeeGee inbox.

2.3. User Communications

With certain communications (for example comments on Matches or Microsports) you send on our Services, the recipient and or viewer of those communications can see your name and some network information.

Many communications and interactions that Members initiate through our Services will list your name in the primary header alone with your communication. Communications you initiate may also provide the recipient with aggregate information about you or the company you represent.

2.4. Service Development; Customized Experience

We may use personal information provided by you in an anonymised aggregated form to conduct research and development, generate reports and analytics, and to customize your experience and try to make it relevant and useful to you.

We may use personal information that you and other Members provide to us to improve our Services in order to provide you and other Members and visitors with a better and more intuitive experience, drive membership growth and engagement on our Service.

We also customize your experience on our Services. For example, when you sign into your account, we may display new Microsports or Members in your account for you to view, follow, communicate or participate (as applicable). We try to show you content that is relevant to you based on the information you have provided us in accordance with this Privacy Policy.

2.5. Sharing Information with ThirdParties

Any personal information you put on your profile, include in a Microsport or Communication, or you provide to another Member (whether in relation to a particular Microsport or not) may be seen by others.

We do not provide any of your personal information to third parties without your consent, unless required by law or as set out in this PrivacyPolicy.

Any of our affiliates may assist us with the operation of theService including the processing and storage of any information and exercising any of our rights under this Privacy Policy and the User Agreement.Accordingly, you acknowledge and agree that we may provide any of your persona linformation to any of our affiliates for that purpose.

Where any part of a profile is made public, that public profile will not be indexed and displayed through public search engines when someone searches the Member’s name.

2.6. Polls and surveys and reports

We conduct our own surveys and polls and also help third parties dothis type of research. Your participation in surveys or polls is up to you. Youmay opt in to or opt out of getting invitations to participate in surveys.

We may use your personal information in an anonymised aggregated form to generate reports as part of our Service. The reports are designed to help Members and third parties conduct research and improve their service offerings. We gather analytics and generate these reports to improve the quality of our Service. You will not be personally identifiable in reports generated by us.

2.7. Searching and searchability

Members profile information is  searchable on the Platform. Members may also be searchable if they have created, participated or included communications within a Microsport that is searchable on the Platform.

2.8. Testimonials about GeeGee

If you provide any testimonials about our Service, we may publisht hose testimonials from time to time. Testimonials may include your name (or company) and other personal information you have provided including the testimonial.

2.9. Compliance with Legal Process and other Disclosures

We may need to disclose personal information, profile information, or information about your activities as a Member or Visitor when required bylaw, subpoena, or other legal process in New Zealand, Australia, United Kingdom or other jurisdictions, or if we have a good faith belief that disclosure is reasonably necessary to:

- investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies;

- enforce the User Agreement, investigate and defend ourselves against any third party claims or allegations, or protect the security and integrity of our Service;

- Exercise or protect the rights, property of safety of Members, personnel or others.

We will attempt to notify the Member about legal demands for their personal information when appropriate in our judgement, unless prohibited bylaw or court order or when the request is an emergency. In light of our principles, we may dispute such demands at our discretion.

2.10. Disclosures to others as a result of a change in control or sale of GeeGee

If there is a change in control or sale of all or part of GeeGee, we may share your personal information with a third party, who will have the right to use that personal information in line with this Privacy Policy.

We may also disclose your personal information to a third party aspart of a sale of the assets of GeeGee, a subsidiary, a parent, or division, or as a result of a change in control of GeeGee or one of our affiliates, or in preparation for any of these events.

Any third party to which we transfer or sell our assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.

2.11. Service Providers

We may employ third parties to help us with theService.

We may employ third party companies and individuals, such as AmazonWeb Services (“AWS”), to facilitate our Services, including for maintenance, analysis, audit, marketing and development. These third parties have access to your personal information only to perform these tasks on our behalf and are obligated to GeeGee not to disclose or use it for any other purpose.

2.12. Data Processing outside NewZealand

We may transfer your personal information for the purpose of storage or processing outside New Zealand, wherever GeeGee, its affiliates or its service providers operate.

2.13. Storage of Information

Any personal information provided to us will be collected and held by, or on behalf of, us at AWS’ data centres used by GeeGee. We may use cloud providers or data centres (whether in New Zealand or overseas), to manage and store personal and other information we collect, and will ensure that any storage on such a platform provides adequate security measures.

Refer to https://aws.amazon.com/security/?nc1=f_ccfor more information on AWS’ compliance, security and cloud storage facilities.

3. Other rights and obligations

3.1. Rights to access, correct or delete your personal information and closing your account

You can change your personal information at any time by editing your profile, deleting your personal information that you have uploaded to, or created on the Platform, or by closing your account. You can also ask us for additional personal information we may have about you.

You have the right to:

- access, modify, correct, or delete your personal information controlled by GeeGee regarding your profile or any other personal information we hold about you;

- change or remove your content and personal information; and

- close your account.

You can request access to and/or correction of your personal information that is not viewable on your profile or readily accessible to you(such as your IP access logs) through GeeGee’s help centre or for Global DataProtection Regulation (GDPR) related enquiries set out in Clause 4 below, email our Data Protection Officer.

If you close your account, your personal information will generally be removed from the Service within 48 hours. We generally delete closed account information and will de-personalize any logs or other backup information through the deletion process within 30 days of account closure except as noted below.

Personal information you have shared with other Members (for example, personal information provided through the creation or participation in Microsports with other Members) may also remain visible after you have closed your account or deleted the personal information from your own profile by virtue of participation in Microsports or Matches with other Members.

We may not be able to provide you with access to, correct, or remove any information about you that other Members copied or exported out of ourService because this information may not be within our control. You can make such requests directly from Members to whom you have applied to, or third parties who you have supplied information to via our Services.

3.2. Data retention

We retain the personal information you provide while your account is in existence or as needed to provide you with the Services. We may retain yourp ersonal information even after you have closed your account if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between Members, prevent fraud or abuse, or enforce this Privacy Policy, our User Agreement.

We may retain personal information, for a limited period of time, if requested by law enforcement. Our Customer Service team may retain information for as long as necessary to provide support, related reporting and trend analysis only, but we generally delete or de-personalize closed account data.

4. Global Data ProtectionRegulations

4.1. Overview and compliance

The Global Data Protection Regulation (“GDPR) is a European data protection law that sets out the rules relating to the protection of natura lpersons with regard to the processing of personal data and rules relating to the free movement of that personal data.

It grants European Union residents greater control over their personal data, increases compliance responsibilities for organisations collecting and processing personal data, and gives national regulators new powers to impose fines on organisations that breach this law.

GeeGee has an international presence and is taking an international approach to compliance with GDPR. This ensures our members benefit from increased control and visibility of data, and more clarity on how we collect, process and use that data.

4.2. Data Protection Officer

In accordance with the GDPR, GeeGee has appointed a Data ProtectionOfficer (“DPO”).

Matters handled by our DPO relate to your rights under the GDPR,Personal GeeGee data and privacy concerns. GeeGees DPO can be contacted at dpo@geegeeapp.com.

When contacting GeeGee’s DPO please specify the nature of your concerns, include any contextual information to help with the enquiry (for example, screenshots, communications, messages) and contact details (name, phon eand email).

5. Third party links

Our Services may contain links to and from websites that are not controlled by us. By using our Services, you may also provide your non-public personal information to third parties such as Members receiving yourOpportunity applications or Previews. If you follow a link to any other website or provide your personal information to third parties, you should note that they have their own rules around privacy. We do not accept any responsibility or liability for anyone else’s policies or for any transactions that you enter into with them.

6. Important Information

6.1. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. If we make significant changes in the way we treat your personal information, or to thePrivacy Policy, we will provide notice to you on the Services or by some other means. Please review the changes carefully.

If you agree to the changes, simply continue to use the Service. If you object to any of the changes to our terms and you no longer wish to use ourServices, you may close your account.

Unless otherwise stated, our current Privacy Policy applies to all personal information that you provide to us. Using our Services after a notice of changes has been communicated to you or published on our Services shall constitute deemed acceptance of the changed terms or practices.

6.2. Security

We have implemented privacy safeguards designed to protect the personal information that you provide in accordance with industry standards.Access to your data on our Services is password protected, and data such as credit card information is protected by SSL encryption when it is exchanged between your web browser and the Services.

There is no guarantee that personal information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails, instant (SMS) messaging and similar means of communication with other Members are not encrypted, and we strongly advise you not to communicate any confidential information through those means.

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