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We, Allstars Fantasy Company Limited (‘Allstars, ‘we’, ‘our’ or ‘us’), are committed to protecting your privacy. This Privacy Policy (‘Privacy Policy’ or ‘Policy’) applies to all persons using our services on the Platform (defined hereinbelow), playing the game or when you otherwise do business or make contact with us. This Policy governs our personal data collection, processing and usage practices. It also describes your choices regarding use, access and correction of your personal information.
By using our website www.allstarsfan.com (‘Website’ or ‘Platform’, as the context requires), you (‘user’ ‘you’, ‘your’) consent to this Policy and to the personal data practices described in it, in addition to consenting to it explicitly when using the Platform. If you do not agree with the personal data practices described in this Policy, you may choose to stop using our services and the Platform immediately. We periodically update this Policy. We encourage you to review this Policy periodically. Any terms, words, or phrases not defined in this Policy, have the meaning prescribed to them in the Allstars’ Terms and Conditions (available at www.allstarsfan.com/privacy-policy).
This Policy has been developed for purposes of compliance with the Data Protection Act 2021 (‘DPA’) of the British Virgin Islands ('BVI’), and other data protection-oriented provisions within applicable regulations. The Policy shall serve as part of your initial customer relationship with us and our ongoing commitments to you.
When you are asked to provide personal information, you may decline, but if you choose not to provide data that is necessary to enable us to make the game available to you, you may not be able to sign up for or play the game, and/or certain game features may be limited. If you fail, neglect and/ or refuse to, or are unable to provide us any personal Information which we necessarily need to provide you with services, or which we need to collect by law (for example: identification information for KYC/AML obligations), we may not be able to provide you services. In this case, we have the right to discontinue the provision of services to you and/or close your account. In such a situation, we will notify you at the earliest.
Allstars collects certain personal information to enable us to operate the game effectively, and to provide you with the best experiences on our website and our game. We pride ourself on transparency and as such, you have choices about the personal information we collect. Some of the information we obtain is collected to comply with applicable laws and regulations, including anti-money laundering laws. This Policy explains:
This Policy has been developed with the objective to promote transparency and accountability in the processing of Personal Data.
From time to time, we may revise, amend, or supplement this Policy to reflect necessary changes in law, our Personal Data collection and usage practices, the features of our offerings, or certain advances in technology. If any material changes are made to this Policy, the changes may be prominently posted on the affected or relevant Platform. However, the onus is also on you to occasionally familiarize yourself with the contents of this Policy, for your own information, and particularly to do so every time you access our Platform or make use of our services.
Changes to this Policy are effective when they are published.
Your Personal Data is collected and processed in accordance with the relevant data protection principles, including: lawfulness, fairness and transparency; purpose limitation; collection limitation; data minimization; accuracy; rectification measures; storage limitation; integrity and confidentiality (security); with all relevant laws and regulations considered; and however applicable. The other data protection principles that we follow are:
You provide consent to your Personal Data (whether provided directly by you, whether collected by us, or received by us from third parties or otherwise) being processed to satisfy all legal obligations arising from any contracts entered into/ with/ involving you or to deliver any services to you which you have contracted with us to provide to you; or to take steps at your request prior to entering into a contract with you.
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By applying or signing up for our services, you authorize and consent to our obtaining from, and disclosing to, third parties any information about you or processing of the Personal Data in connection with identity or account verification, fraud detection, or collection procedure, or as may otherwise be allowed or required by applicable law.
You can request the access to your Personal Data retained with us and can further request for correction in the retained Personal Data. If you wish to submit the request, please contact us at admin@allstarsfan.com.
You can withdraw such consent to your Personal Data. Such withdrawal will not affect the lawfulness of processing based on previously recorded consent. Such withdrawal will take effect within 30 calendar days of submission of request. If you wish to submit such a request, please contact us at admin@allstarsfan.com.
The specific information we collect, the method by which we collect such Personal Data, the purposes for which we collect such Personal Data, how we share such Personal Data, and how long we retain such Personal Data is explained individually, specifically for your clear, simple and withdrawable consent below in this Policy.
We collect the following information (‘Personal Data’) about you: -
Personal data may also include information we collect about your individual preferences. We may collect the personal data in course of your signing up for our services, or in course of our identity or account verification process, or in course of your use of our services
This policy applies to your personal data when you use our Website and interact generally with us but does not apply to third-party sites. We are not responsible for the privacy policies or content of third-party sites. For the avoidance of doubt, unless stated otherwise, this policy will govern our collection of your Personal Information irrespective of the forum. Your continued usage of our website and/or services will be taken to indicate your acceptance of the terms of this privacy policy insofar as it relates to our Website. We do not knowingly collect data from, or market to, children below the legal age as established under their relevant domestic laws. By using the services, you represent that you are at least the age of majority within your respective domestic law or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the services. If we learn that personal Information from users who are less than the age of majority has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.
When you register for your account, we collect Personal Data about you. Depending on the services you choose, we may require you to provide us with your name, postal address, telephone number, email address and identification information to establish an account. As a registered user you may also upload data or post various queries. You can share with us additional information as your Personal Data such as details of your interest and other related details. We usually collect and store information including in paper, the physical and electronic forms provided by you when you communicate with us by telephone, email, web-based form, letter, facsimile, or other means, including when:
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We also may receive and store certain Personal Data about you and your device(s) automatically when you access or use our services. This information may include:
While we do not use some of this information to identify you personally, we may record certain information about your use of our Websites such as which pages you visit and the time and date of your visit, and that information could potentially be used to identify you.
It may be possible for us to identify you from information collected automatically from your visit(s) to our Website. If you have registered an account with us, we will be able to identify you through your user name and password when you log into our Website. Further, if you access our Website via links in an email we have sent you, we will be able to identify you.
We collect Personal Data of the User from third party partners who have your consent to provide us this Personal Data, and if you have given us consent to collect such Personal Data. We will gather such Personal Data from third parties and service providers who you have authorized to collect, process and share your Personal Data with.
We do not sell, exchange or give to any other person your Personal Data, whether public or private, for any reason whatsoever, without your consent, other than for the express purpose of providing our services to you.
We collect, process, and use your Personal Data for the following purposes:
We may also create, process, collect, use and share aggregated, anonymized or de-identified Personal Data such as statistical or demographic data for any purpose which may be derived from your Personal Data. We may use your Personal Data to comply with legal or regulatory obligations. The Personal Data shall be processed with the Retention, Data Integrity and Access Principles provided in Clause 4 of this Policy. We may share such Personal Data with members of our group, service providers and our key partners. Some of these third parties may be in a jurisdiction outside the laws as stated in this Policy, in which case we will take all necessary steps to ensure that your Personal Data is treated securely with adequate protection safeguards and that such transfers are permitted under the applicable data protection laws. We may also use any or all of the Personal Data above to administer and manage our business in general, to detect and prevent misuse of our services (including fraud and unauthorized payments), and to enforce our Terms and Conditions or any other contract to which we may be a party to.
We may collect and process some of your Personal Data without your knowledge or consent; and only where this is required or permitted by law. We may be compelled to surrender your Personal Data to legal authorities without your express consent, if presented with a court order or similar legal or administrative order, or as required or permitted by the laws, rules and regulations of any nation, state or other applicable jurisdiction. Other situations where your Personal Data may be processed without your express consent include without limitation:
We may have to share your personal information with a selected and trusted group of third party/parties to fulfil our obligations under our contract with you, to meet government, regulatory and law enforcement requests, and to continue providing you with the services. We shall ensure any such third party is aware of our obligations under this Policy and we enter into contracts with such third parties by which they are bound by terms no less protective of any Personal Data disclosed to them, than the obligations we undertake to you under this Policy or which are imposed on us under applicable data protection laws. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
In case of termination of our business relationships with such third parties we shall ensure that all your Personal Data is either retrieved from such third party or is destroyed. We shall also confirm in our contracts with such third parties that the third party does not have the right to use such Personal Data for unauthorized purposes.
We may share or transfer your personal Information in the specific circumstances hereinbelow:
In the event of a proposed restructure or sale of our business (or part of our business) or where a company proposes to acquire or merge with us, we may disclose personal data to the buyer and their advisers without your consent subject to compliance with the applicable regulations. If we sell the business and the sale is structured as a share sale, you acknowledge that this transaction will not constitute the ‘transfer’ of personal data.
Your Personal Data is stored and transferred in compliance with the applicable legislation or regulations of every jurisdiction in which we operate.
If you are based in the UK, the EU or the EEA, any storage, processing and transfer of your Personal Data outside these territories will adhere to the relevant legal requirements, particularly the GDPR, as and however applicable and/or required.
If you are based in the British Virgin Islands, the storage and protection of the Personal Data will be in compliance with DPA. The protection measures for your Personal Data shall be taken in accordance with this Policy.
Some of our external third-party service providers may also be based outside of the UK, EU, EEA, or BVI so their processing, storage and transfer of your Personal Data will involve the transfer to and from and storage of data outside such jurisdiction. We reiterate that by using our services you accept the terms of their individual privacy policies, cookies policies, as well as terms and conditions.
Some of the international organizations and countries to which your Personal Data may be transferred do not benefit from an appropriate data protection regulatory framework. For such international organizations and countries, we shall transfer your Personal Data, only upon ensuring that a suitable degree of protection is afforded to it through the implementation of the necessary safeguards, such as an adequacy decision by the relevant authority, adequate binding corporate rules or through the inclusion of standard contractual clauses in our agreements with such organizations and countries.
Without prejudice to Section 5 of this Policy, you should be aware that we transfer your Personal Data outside BVI, to the following third-party service providers (albeit, the same shall not be construed as a closed list):
Allstars is a fast-growing company with various global partnerships. You should be aware that certain third-party service providers, such as payment gateways and other payment transaction processors, may be located in, or have facilities that are located in, outside BVI in a different jurisdiction than either you or us. If you wish to procure specific information about the third-party service providers with whom your Information has been shared, please contact us at admin@allstarsfan.com. Therefore, if you elect to proceed with a transaction that involves the services of a third-party service provider, then your Personal Data may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. For example, if you are located in the BVI and your transaction is processed by a payment gateway located outside of the BVI, then your Personal Data used in completing that transaction may be subject to disclosure under that jurisdiction’s data-specific legislation. For these providers, we recommend that you read their respective privacy policies, so you can understand the manner in which your Personal Data will be handled by these providers.
We may allow third-party service providers to deliver content and advertisements in connection with our services and to provide anonymous site metrics and other analytics services to promote and improve our Services. These third parties may use cookies, web beacons, and other technologies to collect Information, such as your IP address, identifiers associated with your device, other applications on your device, the browsers you use to access our services, webpages viewed, time spent on webpages, links clicked, and conversion information (e.g., transactions entered into). This information which could be your Personal Data may be used by us and third-party service providers on our behalf to analyze and track usage of our services, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand how you use our services.
The third-party service providers that we engage are bound by confidentiality obligations and applicable laws with respect to their use and collection of your Personal Data.
This Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third parties to learn about their privacy practices.
Our Platform or communications may contain links to other third-party websites which are not owned or operated by us and are regulated by their own privacy policies. If you click on a third-party link, you will be directed to that third party’s platform. We strongly advise you to review the privacy policy of every platform you visit.
This Policy does not apply to, and we are not responsible for the privacy policies of these third-party websites regardless of whether they were accessed while using links from our Platform or communications.
You have the following rights with respect to your Personal Data:
You have a right to know:
This is your right to see what personal data is held about you by us. Particularly you have the right to request and obtain the following information:
We may refuse your demand if request is excessively repeated, is in contravention of judicial proceeding or investigations, negatively impacts our endeavors to maintain Personal Data security, or relates to the privacy of a third party.
If the User is from BVI, we can refuse to provide the access to Personal Data upon the fulfillment of any of the following conditions:
You have the right to rectify any inaccurate Personal Data about you retained with us and to complete any incomplete Personal Data about you, provided however, the requisite procedures as outlined within the DPA are adhered to.
You have the right to demand erasure of your Personal Data with us if:
You have the right to restrict processing of your Personal Data if:
You have the right to object to our processing of your Personal Data and stop the processing of said Personal Data in the following cases:
You have the right to Personal Data portability to the extent that:
Yo have the right to receive your Personal Data from us in a structured, commonly used and machine- readable format. Where technically feasible, you may also request us to transmit your Personal Data directly to another entity.
You have the right to object to automated decision making (if any) if it has legal or serious consequences that affect you. Such requests may refused by us if such automated processing is performed in accordance to any contract between you and Allstars, is necessary for compliance with other legislation, or you have specifically provided consent for such practices.
If you are an EU, UK or EEU citizen, you have the right to lodge a complaint with the supervisory authority of the member state in which you are habitually resident, or with the supervisory authority of the member state in which you work or in which your rights under the GDPR have been infringed if you believe such infringement has taken place.
If you are a citizen of BVI, you have the right to raise complaint in writing to the Information Commissioner regarding your breach of right under the DPA or you believe that such infringement has taken place.
We aim to respond to all legitimate requests without undue delay and within 2 calendar months of receipt of any request from you. Occasionally it may take us longer than 2 calendar months, if your request is particularly complex, or if you have made duplicated or numerous requests. In this case, we will notify you of receipt of such request(s) and keep you updated as to the status of progress concerning such request(s).
If you are a citizen of BVI, then your legitimate request to ‘Right to Access of Personal Data’ will be responded by us within the time period of 30 days. However, the time period could be extended by Chief Executive Officer by not more than 30 days if:
We retain Personal Data on your behalf, including customer data, transactional data and other session data, linked to your account.
Your Personal Data will be processed for no period longer than as required by us for the purposes it was collected for, for the purposes of using our services, and for meeting any legal, accounting, reporting, government, regulatory or law enforcement requirements. However, all Personal Data and related documents, records and files will be securely retained for a period of 90 days, as required. Such retention period shall be calculated from the date of closing of your account.
If you are based in the UK, EU or the EEA region, then you have the right to make a complaint at any time to a supervisory or regulatory authority, within the UK, or a member state in the EU or EEA where you are habitually resident, where we may be based (if applicable), or where an alleged infringement of any data protection law has taken place.
If you are a citizen of BVI, you have the right to raise complaint in writing to the Information Commissioner regarding your breach of right under the DPA or you believe that such infringement of DPA has taken place.
However, we would appreciate the opportunity to address your concerns before you approach any such authority. Please contact us in the first instance so that we may try to resolve your complaint swiftly and satisfactorily. Please contact us via email on admin@allstarsfan.com.
We are committed to ensuring that your Personal Data is secure. To prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. We use industry-standard technical mechanisms and ensure that our affiliates or vendor entities use data encryption technology while implementing restrictions related to the storage of and the ability to access your Personal Data.
Our facilities are scanned on a regular basis for security holes and known vulnerabilities, to best ensure its security. Your Personal Data is contained behind secured networks and is only accessible by a limited number of individuals who have special access rights to such systems and are required to keep the information confidential.
We also have mechanisms in place to access your Personal Data in case of an actual or technical failure. We also ensure testing and evaluation of our technical and organizational measures at regular intervals to gauge the effectiveness of such measures.
Please note that no transmission over the internet or any method of electronic storage can be guaranteed to be absolutely 100% secure, however, our best endeavors will be made to secure data and the ability to access your Personal Data.
Without prejudice to our efforts on protection of your Personal Data, nothing contained in this Policy constitutes a warranty of security of the facilities, and you agree to transmit data at your own risk.
Please note, that we do not guarantee that your Personal Data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Please, always check that any website on which you are asked for financial or payment information in relation to our services is in fact legitimately owned or operated by us. The risk of impersonating hackers exists and should be taken into account when using our Platform
If you do receive any suspicious communication of any kind or request, do not provide your Information and report it us by contacting our offices immediately at admin@allstarsfan.com. Please also immediately notify us at admin@allstarsfan.com if you become aware of any unauthorized access to or use of your account.
Since we cannot guarantee against any loss, misuse, unauthorised acquisition, or alteration of your Personal Data, please take the necessary steps to protect your own Personal Data, including the adoption of sufficient safety measures such as your choosing of an appropriate password of sufficient length and complexity and to not reveal this password to any third parties.
Furthermore, we cannot ensure and do not warrant the security or confidentiality of data transmitted to us, or sent and received from us by internet or wireless connection, including: email, phone, WhatsApp or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your Personal Data is no longer secure, please contact us admin@allstarsfan.com.
We also aim to conduct all applicable security risk assessments to ensure the availability of risk mitigation controls, to better safeguard the integrity of your Personal Data.
Should your Personal Data be breached, and the security of your rights be at risk, we shall promptly and immediately communicate to you the nature of the breach which has taken place, the likely consequences of such a breach and shall describe thoroughly the measures we have implemented to address the breach and to mitigate any and all adverse effects to you and your rights. In the unlikely event of a breach occurring, please reach out to us at admin@allstarsfan.com for further information and for further advise on how to mitigate the potential adverse effects of such a breach.
If you have any questions about our Policy as outlined above, or if you have any complaints, please contact us at admin@allstarsfan.com.
If you have any queries or issues pertaining to your Personal Data or our Policy, then please do write to us at any time by emailing us via admin@allstarsfan.com.