PRIVACY POLICY

EFFECTIVE 

November 20, 2021

 

LAST UPDATED

November 20, 2021

In this Privacy Policy, terms such as ‘we’, ‘us’, ‘our’ or similar expressions shall mean Eleven.

 

We take your privacy very seriously and are committed to protecting your personal data. This Privacy Policy explains what personal data we collect when you access: our website eleven-game.com (regardless of where you visit it from), engage with Eleven’s Instagram account play.eleven (or we engage with your content) on social media platforms (including our Instagram account and Facebook page), play the game via the selected platform (including Jotform) , purchase something from us via our third-party payment processor (including Stripe) and/or when you otherwise interact or communicate with us. Please read it before using Eleven’s Services because it will tell you how we collect, store, use, disclose, and otherwise process, your personal information when providing these Services to you. This Privacy Policy is not, however, a contract and does not create any legal rights or obligations.

 

If you have questions, comments, or concerns regarding our Privacy Policy or practices, please Contact Us.

TABLE OF CONTENTS

 

Introduction 

Personal Data We Collect About You

How We Collect Your Personal Data

How We Use and Store Your Personal Data and Our Legal Bases for Processing It

How We Share Your Personal Data

Transferring Your Personal Data Outside the UK and EU

Your Rights and How to Access, Update, and Manage Your Personal Data

Privacy Policies of Linked Third-Party Services and Advertisers

Our Policies Concerning Children 

International Operations and Transfers Out of the UK or   European Countries               

How Long We Keep Your Personal Data

Changes to Our Privacy Policy 

Contact Us

INTRODUCTION

 

Eleven is an online game. This Privacy Policy describes how Eleven (‘the Company’), collects, uses, and discloses certain personal information obtained through our public website https://www.eleven-game.com/and/or whenever you use our Services through our Instagram account play.eleven and/or our Facebook page Eleven. It describes the ways we use your personal data and your rights and options concerning your personal data. 

 

We are the Data Controller of your personal information. We will refer to countries in the European Union (EU) and the European Economic Area (EEA), and Switzerland collectively as the European Countries in this Privacy Policy. 

 

This Privacy Policy applies whenever you use our Services, which means our game, products, services, content, website eleven-game.com, and/or other domains, websites or engage with social accounts operated by Eleven such as our Instagram account play.eleven. It describes how we collect, store, use, disclose, and otherwise process your personal information when providing these Services to you, and your rights and choices concerning your information. The Privacy Policy’s sections are listed and hyperlinked in the Table of Contents above for easier navigation.

 

If you do not want Eleven to collect, store, use, or share your information in the ways described in this Privacy Policy, you may not play Eleven’s games or use Eleven’s other Services.

 

PERSONAL DATA WE COLLECT ABOUT YOU

 

We will collect and store any information that you provide to us, including:

Identity and Contact Data: To access and use some elements of the Services you must provide us with the information which is identified on the relevant game page: Instagram username and email address. When we want to communicate with you, or you with us, we use your email address and/or your Instagram username.

 

Media Data: We use image from photographs and video footage of players and crowds and other media content created by us (or on our behalf) when providing you with various gifts and rewards, after asking for your consent to be featured on our Instagram account and/or website. 

 

User Data: We collect your usage and preference details related to your use of the Services such as language, game-play statistics, scores, rankings, time spent playing, preferences, survey and/or Direct Message responses, feedback, and other data that you provide to us as part of playing the game.

Marketing and/or Communication Data: We retain your preferences in receiving marketing messages from us, and your communication preferences.

 

Technical Data: Certain data is automatically generated and collected by us when you use the Services such as your IP address, MAC address and other device identifiers; your clickstream to, through and from the Services (including date and time); pages you viewed or searched for; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); methods used to browse away from the page.

 

Payment Information: We will collect information related to any purchases you make. If you purchase our Premium package, our third-party payment processor will collect the billing and financial information it needs to process your charges. This may include your postal address, email address, and financial information. Our payment processors do not share your financial information with Eleven but they may share non-financial information with us related to your purchases, like your name, billing address, and the items purchased. Any purchases you make will be processed by that third-party processor and subject to that third-party processor’s terms of service and privacy policy. For these purchases our third-party payment processor is Stripe.

 

HOW WE COLLECT YOUR PERSONAL DATA

 

You provide us with your personal data when you:

 

access, use or play the Services;

pay for our Services;

request information, marketing and other communications to be sent to you;

enter a competition, promotion or survey;

view our website via your browser’s cookies;

complete surveys or provide us with your feedback; and 

otherwise interact or correspond with us (including via email, social media and/or telephone).

 

We collect the Technical Data automatically as you interact with our Services by using cookies and other similar web technologies. Please refer to our Cookie Policy for more information. 

We use third party service, when you play our game via the selected forum, Jotform, to collect your answers for the game, Instagram username, email address, and package preferences (Premium or Free). 

 

We use third party service, Stripe, to process your order and collect your payment when you decide to purchase our Premium package, as well as the name on your payment card, the last four digits of your payment card, the date and the time of the transaction.

 

We also use third party tools to help us manage and analyse our social media presence, and report on comments, mentions and other content that is posted about us on social media platforms and other public channels and forums. These third parties’ activities, and their information collection and sharing practices, are subject to the terms of the relevant social media platform, channel, or forum. We will use this information in accordance with this Privacy Policy.

 

We use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to certain parts of the Services. This information is only used by us in a way which does not identify you. We do not make, and do not allow Google to make, any attempt to find out the identities df anyone visiting our website.

 

HOW WE USE AND STORE YOUR PERSONAL DATA AND OUR LEGAL BASES FOR PROCESSING IT

 

We will normally collect your personal data from you only where we need it to perform our contract with you (i.e., our Terms and Conditions), where the processing is in our legitimate interests (provided that these are not overridden by your interests and/or rights), or if we otherwise have your consent. 

 

In some cases, we may also have a legal obligation or need to collect information from you or may otherwise need the personal information to protect your vital interests or those of another person (for example, another player).

 

If we ask you to provide information to comply with legal requirements or to perform a contract with you, this will normally be clear from the context in which we are asking you to provide your information (for example, when we ask you to provide a username to access our Services, this will be to associate your Instagram username with your answers to the game and/or to process your order in accordance with our Terms and Conditions), and, if not, we will provide an explanation to you at the relevant time. We will also make clear whether providing information is mandatory. 

 

We may collect and use your personal data according to Data Protection Law for reasons of substantial public interest, including when preventing or detecting unlawful acts, in connection with legal claims, cases where you have made the data public yourself, or where you have given explicit consent. 

 

We use your information under several legal bases, including to establish and perform our contract with you (i.e., our Terms and Conditions), for our legitimate interests, to comply with our legal obligations, to establish, use and protect Eleven’s rights, or otherwise with your consent. 

 

The main use of information we collect, and store is to provide you with the Services you request from us and to improve your gaming experience, but there are other uses as well. The uses for which we collect and store your information include:

to improve and optimise our Services and our players’ experiences;

to provide technical support to play the game;

 

to communicate with you about the Services you’re using, including in-game updates, new Services, and promotional offers that we think might be of interest to you;

 

to provide technical support and respond to player inquiries;

 

to protect the safety and well-being of our players;

 

to protect Eleven’s rights and property in connection with our Services;

 

to prevent fraud or potentially illegal activities, and to enforce our Terms and Conditions; 

 

to manage and deliver contextual and behavioral advertising;

to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;

to process your order;

to comply with our legal obligations, resolve any disputes we may have with you or other players, and to enforce our agreements with third parties; and/or to conduct research.

If you are located in the UK or European Countries, our legal basis for collecting and using the information described above depends on what the information is and the context in which we collect it.

 

However, we will normally collect information from you only where we need it to perform our contract with you (i.e., our Terms and Conditions), where the processing is in our legitimate interests (provided that these aren’t overridden by your interests or rights), or if we otherwise have your consent.

 

In some cases, we may also have a legal obligation or need to collect information from you or may otherwise need the personal information to protect your vital interests or those of another person (for example, another player).

If we ask you to provide information to comply with a legal requirement or to perform a contract with you, this will normally be clear from the context in which we are asking you to provide your information (for example, when we ask you to provide a username to access our Services), and, if not, we will provide an explanation to you at the relevant time. We will also make clear whether providing information is mandatory.

 

Similarly, if we collect and use your information in reliance on legitimate interests (or those of any third party) which are not listed above, it will be made clear to you at the relevant time what those legitimate interests are (such as personalising our services and marketing, for example).

 

If you have questions or need further information about the legal bases on which we collect and use your personal information, please Contact Us. 

 

HOW WE SHARE YOUR PERSONAL DATA

We may disclose or share your personal data in the following circumstances:

Third Party Service Providers. We engage third party businesses to provide services to us or to you on our behalf, such as support for the internal operations of our Services (and related services), payment processing, communications, the game, data storage and delivering communications (including calendar notifications). Our service providers may access, receive, maintain, or otherwise use personal data on our behalf. Where we share your information with third-party service providers and business partners, we ensure that we have appropriate agreements in place to protect your information (as required by applicable data protection laws).

Commercial Partners. We may also disclose your personal data to our commercial partners where you have consented or requested that we do so. For example, when you enter a competition or sweepstake which is a joint promotion, or you request to receive certain marketing communications. You will be given clear information in each case before we disclose share your personal data. You may always opt out at a later date. You have the right at any time to stop Our Company from contacting you for marketing purposes or giving your data to other members of Our Company. If you no longer wish to be contacted for marketing purposes, please Contact Us.

Publicity and media. We may disclose your personal data publicly via the media, social media or on the Services. For example, when sharing a comment or opinion you have, or if you win a competition or promotion, we may disclose your name online. In such cases, we will clearly notify you of the sharing, and you will have the choice not to participate or to otherwise object to such sharing, subject to our other legal obligations.

Where you allow us to, we will share your personal data with your favourite Clubs to help our Clubs interact with their fans or where for example it is necessary for the fulfilment of a competition (e.g. you have won tickets to a Club match). This Privacy Policy applies to our use of your personal data only, and you should refer to the relevant privacy policy of each relevant Club to understand how they use your personal data. A list of the Clubs and links to the respective privacy policies is available here: https://www.premierleague.com/withdrawing-consent-from-clubs/.

Legally Required. We may also disclose your personal data if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes or the enforcement of our rights where we receive evidence, we deem sufficient to justify such disclosure or in the event of a re-organisation of the legal or ownership structure of the Eleven.

Please read carefully any additional privacy notices which we may provide to you so that you are aware of and understand any other circumstances in which we may disclose or share your personal data which are specific to your use of the Services and/or your relationship with Eleven.

Notwithstanding anything else in this Privacy Policy, we may share aggregate or de-identified information with third parties for research, marketing, analytics, and other purposes, provided such information does not identify a particular individual and the individual cannot be re-identified.

TRANSFERRING YOUR PERSONAL DATA OUTSIDE THE UK AND EU

 

When you use our Services, your personal information may be sent to the United States and possible other countries. When we process personal information collected in the UK or European Countries outside of the UK or European Countries (as applicable), we comply with our legal obligations and ensure that your personal information is subject to suitable safeguards or transferred to “approved” territories.

As part of our international operations, we may transfer personal information to our business partners and service providers from time to time for our legitimate business purposes.

We store personal information about players and visitors to our sites on servers located in the United States, and we may also process this information in other countries where our business partners and service providers have their operations. Personal information collected in the UK or European Countries may be transferred to, and stored at, a destination outside of the UK or European Countries (as applicable) for purposes such as: (i) the processing of transactions and your payment details, or (ii) the provision of support services. When we transfer your personal information internationally we will take reasonable steps to ensure that your personal information is treated securely, lawfully, and in the manner we describe here. This may include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our business partners and service providers (where applicable) to protect personal information they process from the UK and the European Countries, or any other lawful solution that permits the lawful transfer of personal information from those countries. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your information is transferred to or stored, used, or processed in, may be different from the privacy laws applicable to the place where you are resident.

In addition, our business partners such as Stripe, are Privacy Shield certified. The Privacy Shield certification record for Stripe is accessible at https://stripe.com/privacy-shield-policy and is certified under the EU-U.S., UK. 

If you would like further information on the specific mechanism used by us when transferring your personal data out of the UK and the EU, you can contact us using the details provided below.

EU and UK residents should direct any questions, concerns, or complaints regarding Eleven’s handling of personal information or compliance with the Privacy Policy and privacy law at our email address email.play.eleven@gmail.com

We will attempt to answer your questions and satisfy your concerns in a timely and complete manner. If, after discussing the matter with us, your question or complains is not resolved, you may contact the European Data Protection Supervisor at edps@edps.europa.eu. PLEASE CONTACT US FIRST.

Your Rights and How to Access, Update, and Manage Your Personal Data

UK AND EUROPEAN COUNTRIES’ USERS’ RIGHTS

If you are located in the UK or European Countries, you have the following data protection rights:

You can access or request deletion of your personal information by submitting a request through our Personal Data and Request Portal.

 

You can correct or update your personal information, object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.

You can opt-out of marketing communications we send you by clicking ‘unsubscribe’ link.

If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority (Contact details are available here.)

To exercise your rights to access or deletion, please submit a request through our email address email.play.eleven@gmail.com. We respond to all data protection requests we receive in accordance with applicable data protection laws.

If you are located in the Republic of Turkey, you have the rights listed under Article 11 of the 6698 No. Law on Protection of Personal Data.  Contact Us for your queries and requests.

For deletion requests, we will take reasonable measures to delete your personal information from our records. If you have sent content through or posted content on the Service, we may not be able to delete it. We will keep certain records (e.g., personal information relating to payments or customer service matters) where we need (and have rights) to, such as for legal or accounting purposes. We will also keep information in order to exercise, defend, or establish our rights. 

Privacy Policies of Linked Third-Party Services and Advertisers

Our websites, Instagram account, Facebook page, and game may contain advertisements from ‘Third-Party Services’, meaning companies other than Eleven, may link to their own websites, online services, or mobile applications. We are not responsible for the privacy practices or the content of these Third-Party Services. If you have any questions about how these Third-Party Services use your information you should review their policies and contact them directly.

 

OUR POLICIES CONCERNING CHILDREN

 

We seek to ensure that we do not collect information from children.

Generally speaking, most of our Services are not intended for children under the age of 13 (or under 16 for children located in the UK or European Countries) (collectively, “Children”). Children are not permitted to use these Services, and we do not knowingly collect any personal information from Children.

 

Though our Services do not target Children as the primary audience, we may collect age information before allowing a user to proceed for certain Services. For users who identify themselves as Children in our age-gate on such Services, if we allow Children to use the Services, we will either provide a version of that Service that does not collect, use, or disclose “personal information”, except as permitted by privacy law for children, or obtain legally valid parental consent.

 

If we learn that we have inadvertently gathered personal information that is not subject to privacy law for children exception from a child, we will take reasonable measures to promptly remove that information from our records.

HOW LONG WE KEEP YOUR PERSONAL DATA

 

We will keep your information for as long as necessary to provide you with the Services, maintain our legitimate business operations, and/or exercise, defend or establish our rights. This period will usually be one week from the game you played.

 

How long we retain your personal information depends on why we collected it and how we use it, but we will not retain your personal information for longer than is necessary for our business purposes or for legal requirements.

We will retain personal information about you and/or the Services you use from us for as long as you played our game, used our Services and/or paid for a membership. We will take reasonable measures to delete this personal information if you stop playing our game and/or using our Services. However, you acknowledge that we may retain some information after you have stop playing our game and/or using our Services where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights.

Security of Your Information

 

We work hard to protect your information, but you also have a role to play. 

 

We implement reasonable and appropriate security measures to help protect the security of your information both online and offline and to ensure that your data is treated securely and in accordance with this Privacy Policy. These measures vary based upon the sensitivity of your information.

 

When you play our game or enter payment information, we and our third-party payment processor use encryption to transmit that information. 

 

While we take precautions against possible security breaches to our Services and our customer databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorised access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our Service. Any transmission is your own risk. If you have questions about the security of our websites, please Contact Us. 

CHANGES TO OUR PRIVACY POLICY

We may update our Privacy Policy from time to time. When we do, we will revise the “last updated” date at the top of the policy. If we make changes that we deem material , we will use reasonable efforts to notify (such as by placing a notice on https://www.eleven-game.com/, or by sending you a notice to the email address we have on file for you or by uploading a story on our Instagram account). We encourage you to periodically check https://www.eleven-game.com/ and this Privacy Policy for updates.

Contact Us

 

If you have any questions, comments, and concerns regarding our Privacy Policy and/or privacy practices and any other matters, please send an email to email.play.eleven@gmail.com