PRIVACY NOTICE

1. INTRODUCTION AND GENERAL TERMS

These terms apply to the use of products and services developed by Zenos Interactive Limited (“Zenos / we / us’). Our registered office is at 71-75 Shelton Street, London, Greater London, United Kingdom, WC2H 9JQ. We are a company registered in England, with company number 12603895.

We are a developer and provider of Zenos Stadium, a virtual Esports Stadium (the “Stadium”). The Stadium offers professional esports organizers, teams or individual creators (together, “Hosts”) the ability to host a virtual stadium and run virtual esports events. Registered users of the Stadium (“Users”) can then experience the esports events in virtual reality. We also operate the website: https://www.Zenosstadium.com/ and various other domains that lead to the same site (the “Website” and together with the Stadium, Zenos’s “Online Services”). This privacy notice (“Privacy Notice”) describes how we will process your personal data when you use the Online Services.


If you have any questions or comments about this Privacy Notice, please contact us at info@Zenosstadium.com

We are committed to protecting and respecting your privacy. We seek to limit the personal data we handle to only that which is necessary to provide our Online Services and support our Hosts, Users and Website visitors.

This Privacy Notice explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through the Online Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679 and the UK GDPR.


Please read this Privacy Notice carefully as it contains important information about the following:

  • What information we may collect about you;
  • How we will use information we collect about you;
  • Whether we will disclose your details to anyone else; and
  • Your choices and rights regarding the personal information you have provided to us.

The Stadium is made available to Users through third party application and/or games stores including, without limitation, Steam, Oculus and Epic Games (each a “Store”) and the Stadium makes use of their cloud saving and achievements functionality. That means you need a Store account to use the Stadium. Each Store acts as an independent controller of your personal data, and your use of each Store is subject to the terms of use and privacy policy applicable to that Store (as may change from time to time).

In addition to the Stores, the Online Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit, or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services or the Stores and your use of these is at your own risk.

We may make changes to this Privacy Notice in future, which will be posted on this page. Where appropriate we will notify you of changes through your Stadium account.

2. INFORMATION WE MAY COLLECT ABOUT YOU

We may collect and process the following information which may include your personal data.

Information provided by you when you set up a Stadium Host account

(“Host Account Information”)

We require certain information from you when you set up your Host Account. This may include:

  • Name
  • Email address;
  • The organisation you work for (if you are setting up a Host account on an organisation’s behalf);
  • Details of your requested Stadium set up; and
  • Details of the event you wish to run through the Stadium.

If you do not provide this information, we may not be able to set up your Host account and / or facilitate your event.

Information provided by you when you set up a Stadium User account

(“User Account Information”)

We require certain information from you when you set up your User Account. This may include:

  • Name
  • Email address;
  • SteamID, OculusID or EpicID (as appliable); and
  • Country.

If you do not provide this information, we may not be able to set up your User account and / or facilitate your attendance at Stadium events.

Information from your Stadium User profile

(“User Profile Information”)

When you register for, and set up, your Stadium User account, we will automatically generate a Stadium User profile for you which includes your User Account Information. You may then choose to further populate your User profile with additional information which may include:

  • profile picture (generated from your profile picture on your Store account);
  • username (generated from your username on your Store account); or
  • links to your third party accounts such as your account on Discord, Twitch, YouTube or other social media platforms.

As you use your Stadium account and attend Stadium events, the following information may be processed, and you can choose to add this to your User profile:

  • user badges you earn through competitions or similar in-event experiences;
  • avatars you choose to purchase and use to attend Stadium events; or
  • other virtual profile enhancers,

Please be aware that your Stadium User Account profile is viewable by Hosts and other Users of the Stadium.

Information about your access to and use of the Stadium

(“Stadium Analytics”)

When you use the Stadium, we may automatically collect the following information:

  • timed positional data – i.e., where in the Stadium you spend the most time;
  • the country from which you have logged in;
  • how long you have been registered as a User;
  • your preferred User settings such as: for audio, screen, graphic quality, mode of movement (for example teleporting vs. smooth locomotion), and voicechat;
  • average frames per second (fps) connected to positional data within the app (such as 90fps in Stadium_Echo or 100fps in Lobby - Lounge Area). This allows us to track how the Online Services are performing in different locations for our users.
  • information relating to any crashes or similar issues you experience;
  • events relating to your use of the Stadium, such as achievement of User badges, or which events you choose to attend;
  • device ID;
  • device operating system & version;
  • device make and model, together with details regarding your device’s CPU, GPU and RAM (this allows us to see the most common components used by our users to aid in performance optimization);
  • stadium session time start, end and duration

Where you access the Stadium though a Store or third party distribution platform, these third parties may conduct their own analytics. This will be explained in their own respective privacy policies.

Information provided by you when you interact with other Users

(“Interactions Data”)

You may provide us with information about you when you use the interactive functionality within the Stadium, which allows you to speak to other Users. Whether you use this functionality and the information you provide in this respect is entirely up to you. Please do not share personal data about third parties or any sensitive personal data about yourself.

In order to create a safer, more inclusive experience for our Users, we use community moderation software, Toxmod, provided by a third party partner, Modulate.ai. Modulate.ai monitors and moderates Users’ interactions when using the Stadium, on Zenos’s behalf. In order to do this, Modulate.ai may process the following information:

  • Modulate ID – a unique user-specific identifier created against which the following data points will be recorded;
  • Language preference information;
  • Predicted demographics – predicted age and other demographic information;
  • Past instances of flagged behaviour within the Online Services – where Modulate.ai identifies inappropriate behaviour whilst using the Online Services, a record of such behaviour will be recorded against your Modulate ID;
  • Operations Data;
  • Audio logs, together with algorithmic predictions of the transcription, emotional character of the speech, type of audio (speech, laughter, crying etc) and other estimates derived from the audio;
  • Conversation participants and timeline; and
  • In-service events such as attendance at an esport event or earning of badges – to the extent you choose to share this with Modulate.ai.

Modulate.ai may also:

  • Anonymise data collected via its software (so that it is not possible to identify any individual from such data) and use the data to improve its services; and
  • Aggregate data (i.e., compile data in such a way that it becomes impossible to identify a particular User from the aggregated data set) in order to provide Zenos with statistics related to events across the Online Services like how many instances of inappropriate behaviour have occurred within the Stadium, how many instances there have been of the use of specific keywords, and how many actions Zenos takes in relation to instances of poor behaviour. Modulate.ai may also use these aggregated statistics for its own efforts to improve its services, for further information please refer to its privacy policy here:

https://www.modulate.ai/privacy-policy

Information about your access to, and use of, the Website

(“Website Analytics”)

When you visit our Website, we collect technical information about your use of the Website through the use of Google Analytics Cookies (see more on cookies in the section of this Privacy Notice on cookies below). Read Google’s overview of privacy and safeguarding data here.

The Google Analytics cookies are used to collect information about how visitors use our Website. We use the information to compile reports and to help us improve our services. The cookies collect the following data points from visitors: average pages per Website session, where our visitors come from, visitors’ device and operating system, time of day that the Website is used, general location, average time on a Website page, button clicks, number of views on a Website page, depth of scroll down a Website page, and whether a visitor is a new or returning visitor.

Information provided by you when you contact us with enquiries or for support

(“Enquiry and Support Information”)

We provide our support services via a form on the Website, or via email info@Zenosstadium.com

We will therefore process the following data when you contact us:

  • Name;
  • Email address; and
  • Details of your enquiry, including anything you choose to provide us with.

In responding to your enquiry, we may ask for further information from you, which may include:

  • The device model on which you are trying to access the Stadium; and / or
  • A precise description of the issue you are experiencing.

If you don’t provide this information, we may not be able to help or respond to your enquiry.

Information collected in respect of Sales Performance of the Stadium via the Stores

(“Sales Performance Data”)

The Stores allow us to see data relating to how the Stadium (including various in-Stadium purchases) is selling in the relevant Store in different territories. This is made available to us in aggregated form, and we are not able to single out any one individual from this data.

Information processed in relation to social media channels

(“Social Media Data”)

If you post or upload any content about our Online Services on social media channels such as YouTube, Facebook, Twitter, Instagram, or Twitch, this will be under these social media platforms’ respective privacy policies which can be found on their websites.

Where you follow us or interact with our content, or choose to link your social media channels to your account with us, we may be able to see personal information from your social media profile (depending on your social media privacy settings), including your:

  • Name (and/or your social media unique username);
  • Email and/or postal address;
  • Location;
  • Telephone number(s);
  • IP or MAC address;
  • Gender and/or age;
  • Correspondence with us through those channels; and
  • General interests and preferences (e.g., Likes, Shares, Posts).

Information provided by you when you participate in playtesting our software or respond to our surveys

(“User Feedback Information”)

If you choose to participate in our playtests or user surveys, we may ask you for, or you may submit, certain information to us such as your:

• Name;

• Age;

• Email address;

• Approximate location; and

• Gaming habits and preferences.

We may, with your permission, also make video and audio recordings (together with transcripts) of your playtest session.  No identifying information will be made public from such recordings or transcripts and only Zenos personnel will have access to the original files.

Information provided by you when you respond to a job vacancy on our Website

("Job Vacancy Information”)

We may ask you for, or you may submit, certain information to us whenever you respond to a job vacancy or apply for a job through the Website. This will normally include your CV or a portfolio of your work which may contain personal and non-personal information such as your:

  • Name;
  • Date of birth;
  • Email address;
  • Qualifications;
  • Details of your previous work and/or employment; and
  • Any other information you include in your CV.

Direct marketing preferences

(“Direct Marketing Data”)

Some of our Online Services, such as our Website, may offer direct marketing subscription services for you to sign-up to (to obtain news and updates from us, for example). The personal data we may collect from you for this type of service will be clarified on the relevant Online Service (such as in sign-up or tick-box information). It may include, without limitation, your name, email address and fact that you have provided, or declined to provide, consent to receive direct marketing from us.

3. WHY WE COLLECT INFORMATION ABOUT YOU

To provide the Online Services to you

We may use Host Account Information, User Account Information, User Profile Information, Stadium Analytics, and Enquiry and Support Information in order to deliver the Stadium and relevant esports content to you under the terms of use agreed between us. The processing of information in this way is necessary for us to set up and administer your Host and/or User account and profile, and to ensure the Stadium delivers the features promised and functions properly, so that you have the best experience when using the Stadium.

Legal basis under GDPR: performance of contract.

Similarly, we may use Website Analytics and Enquiry and Support Information to make the Website available to you under the terms of use agreed between us. The processing of information in this way is necessary for us to ensure the Website delivers the features promised and functions properly, so that you have the best experience when using it.

Legal basis under GDPR: performance of contract.

To help us improve the Online Services and fix any problems

We may process information about you (including Host Account Information, User Account Information, User Profile Information, Stadium Analytics, Website Analytics Enquiry and Support Information) so that we can analyse and improve our Online Services. This may include sending information relating to any crashes or similar issues you experience to a third party for further investigation. This processing is necessary for us to pursue our legitimate interests of (i) ensuring that our Online Services function properly so that you and other users have the best experience when using the other Online Services; (ii) improving the quality of our Online Services, and the experience of our Users; and (iii) identifying and correcting any bugs in the Online Services.

Legal basis under GDPR: legitimate interests (listed above).

To manage our relationship with you

We may process Social Media Data, and Enquiry and Support Information so that we are able to properly respond to your questions, enquiries, complaints and support requests.

This processing is also necessary for us to pursue our legitimate interests of (i) ensuring that our Online Services function properly so that you and other users have the best experience when using the other Online Services; (ii) improving the quality of our Online Services, and the experience of our Users; and (iii) identifying and correcting any bugs in the Online Services.

Legal basis under GDPR: legitimate interests (listed above).

To fill any job vacancies

We may process Job Vacancy Information so that we are able to take steps prior to entering into a contract with you, including assessing your skills, qualifications and suitability for the role and/or communicating with you about the recruitment process. We may also need to process this information to enter into a contract with you.

We also have a legitimate interest in processing Job Vacancy Information during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process more efficiently, assess and confirm a candidate's suitability for employment and decide to whom to offer a job.

Legal basis under GDPR: taking steps prior to entry into contract, and/or legitimate interests (listed above).

To prevent fraud and illegal activity

We process personal data for our legitimate interests of ensuring that any use of the Online Services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, to enforce our legal rights and to comply with our legal obligations.

Where we reasonably believe that you are or may be in breach of any applicable laws or our terms of use, we may use your personal information to inform relevant third parties such as your law enforcement agencies about the content.

We work with the Stores to assist us with fraud prevention and the detection of any illegal activity.

Legal basis under GDPR: legitimate interests (listed above) and/or compliance with legal obligation.

To keep you up to date about our services and products

Where you have consented, or where it is otherwise lawful for us to do so, we may use your Host Account Information, User Account Information and Direct Marketing Data to send you emails in order to keep you informed about our news, services and products. Where we rely upon your consent to do this, you can withdraw your consent at any time by sending an email to info@Zenosstadium.com

Legal basis under GDPR: your consent.

To track sales performance

We may use Sales Performance Data in order to track sales performance and better understand the Stadium’s, and other in-Stadium purchase options’, popularity in different Stores and in different territories. This data is made available to us in aggregated form, so we are not able to identify ay one individual from this data. Nevertheless, we process this data on the basis of our legitimate interest in monitoring sales performance, and ultimately success of our business, in different regions.

Legal basis under GDPR: legitimate interests (listed above).

To moderate User interactions and ensure a safer, more inclusive User experience

We may use Interactions Data to moderate User interactions within the Stadium in accordance with our legitimate interests of: (i) creating a safe and inclusive User experience and (ii) identifying and detecting unlawful behaviour. As noted in section 3 (see “Information provided by you when you interact with other Users”) we use third party software, Toxmod, provided by a third party provider, Modulate.ai, to do this.

Modulate.ai does this by:

  • Logging audio of Users’ interactions, together with conversation participants and timelines;
  • Running automated software over such audio logs, and flagging for human review instances that appear to be inappropriate;
  • Predicting Users’ age and perceived gender identity to assess risk of gendered or age-specific offenses (such as grooming);
  • Recording instances of inappropriate behaviour of Users and flagging the same to Zenos.

Legal basis under GDPR: legitimate interests (listed above).

4. DATA SHARING

Information will only be shared between us and third parties in the ways that are described in this Privacy Notice

Group members and personnel: We seek to keep your information confidential but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006) and our personnel insofar as it is reasonably necessary for the purposes set out in this Privacy Notice.

Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, we may need to share your personal information with the counterparty as part of the negotiation. You will be notified via account message and/or a prominent notice on our Website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

Required by law: We may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of Zenos, our customers, or others.

Digital Content Stores: Where access to the Stadium is purchased through a Store, your personal information may be independently collected by the companies that run the Store (including Steam, Oculus and Epic Games). Please check their respective privacy policies for details on this. Stores share Sales Performance Data with us as set out in section 2 above.

Third Party Suppliers: We work with various third party suppliers to enable the functionality of our Online Services. We select these suppliers carefully and we only provide them with as little personal data as possible to carry out their intended function. The categories of supplier who may receive your personal data include:

  • IT service providers including:
  • Epic Online Services;
  • Microsoft Playfab;
  • AWS / Gamelift;
  • Avatar production specialists including:
  • ReadyPlayerMe / Wolf3D;
  • Voice spatialisation specialists including:
  • Vivox;
  • Community moderation software providers including:
  • Modulate.ai; and
  • Analytics technology providers.

5. OUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay, and within one month at the latest.

To make a request, please let us know by sending an email to info@Zenosstadium.com.

Ask for a copy of data we are processing about you and have inaccuracies corrected

You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.

We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).

Object to us processing data about you

You can ask us to restrict, stop processing, or to delete your personal data if:

  • You consented to our processing the personal data, and have withdrawn that consent;
  • We no longer need to process that personal data for the reason it was collected;
  • We are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Zenos or a third party, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
  • The personal data was unlawfully processed;
  • You need the personal data to be deleted in order to comply with legal obligations;
  • The personal data is processed in relation to the offer of a service to a child.

Obtain a machine readable copy of your personal data, which you can use with another service provider

  • If we are processing data in order to perform our obligations to you, or because you consented, or if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
  • If you request, we will supply you with the relevant personal data in a commonly used, machine-readable and interoperable format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

Make a complaint to a Supervisory Authority

  • If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.
  • If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority. We are registered with the UK regulator, the Information Commissioners Office (ICO).

6. COOKIES

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

The table below explains the cookies we use and why.

Overall, cookies help us provide you with better experiences in the Stadium and on the Website, by enabling us to monitor which aspects of our Online Service you like or find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. 

7. DATA RETENTION

We will hold your personal information on our systems for as long as is necessary for the relevant service, or as otherwise described in this Privacy Notice. In any event we will hold your personal data no longer than 7 years from the date of last use, except in limited circumstances where we may be required to retain your personal data for longer. For example, we may need to take into consideration any regulations that we must fulfil, such as for auditing purposes or other legitimate business purposes. 

At the end of the retention period or once you withdraw your consent, your data is securely deleted or destroyed.

8. CHILDREN

Please also remember that if you are under 18, you must get your parent’s or guardian’s permission to access the Stadium and attend esports events within the Stadium. 

If you have any questions about any of this, you should speak to your parent or guardian or ask us about it by sending us an email to the following address: info@Zenosstadium.com

9. PARENTS OR GUARDIANS 

Our terms of use prohibit users aged:

  • under 13 years from accessing and/or using the Stadium; and 
  • between the ages of 13 – 18 from accessing our Online Services without their parent’s or guardian’s permission. 

Depending on the esports event a child is seeking to access via the Stadium, and via which Store they are accessing it, such event may have an age rating. If so, this must be adhered to – a child must be at least as old as the age rating prescribed in order to access the content. 

In the event that we learn that a child is in contravention of the above, we will delete their information as quickly as possible. If your child is accessing our Online Services without your permission or in contravention of the age rating, please contact us about this as soon as possible via info@Zenosstadium.com 

In addition, the Stores may make available parental controls to help make sure children use their devices in the ways their parents/guardians want them to. Please check the relevant Store’s informational pages for more details on this. Such parental controls may enable you to block or limit specific apps and features on your child's device. We aim to work and comply with the Stores’ parental controls. 

10. SECURITY

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information.

Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches. If you have any questions about this, please email us at info@Zenosstadium.com

11. INTERNATIONAL DATA TRANSFERS

Our servers are located in different regions across the world. 

Where we transfer your information outside of the UK and/or EEA, we will have agreements in place with the recipient which include standard data protection clauses adopted by a data protection regulator and/or approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing info@Zenosstadium.com

It is possible that your personal information may be transferred outside of the UK and/or the EEA by the Stores. We recommend that you refer to the privacy policies and/or terms and conditions of these third parties if you are concerned about your data being transferred internationally. 

CONTACT INFORMATION

All questions, comments or enquiries should be directed to Zenos using the following email address: info@Zenosstadium.com

We will endeavour to respond to any query or questions within 2 business days. 

We and selected third parties use cookies or similar technologies for technical purposes and, with your consent, for other purposes as specified in our Policy Pages.

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