Chess 24 Privacy Policy

Last updated 12/07/2022

Welcome to Chess24! This website is owned and operated by Logical Thinking Limited, a company registered in Gibraltar under number 107117, with its registered address at 4 Pitman's Alley, Gibraltar GX11 1AA ("Chess24", "we", "us" or "our" as applicable). We are committed to protecting and respecting your privacy. This policy (together with our Terms of Use and any other documents referred to in it) sets out the basis upon which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will process it. If this Privacy Policy is translated into any language other than English, it will be for information purposes only. In the event of any conflict between the translation and the English language version, the English language version shall prevail. For the purposes of the data protection legislation, we will act as “data controllers” (the company who is responsible for, and controls the processing of, your personal data).

If you are aged 16 or under, you must ensure that we have your parent/guardian's permission before you provide any personal information to us (including creating an account).

1 Information we may collect from you

We may collect and process the following data about you:

• Information that you provide by filling in forms on our website chess24.com and any other websites that we own containing our Chess24 pages, products and services (our “Website”). This includes information provided at the time of registering to use our Website, subscribing to our products and services, posting material or requesting further services. We may also ask you for information when you report a problem with our Website.
• Information you provide us when you contact us or make any comments on our Website or post in our forums.
• Details of transactions you carry out through our Website and of the fulfilment of your orders.
• Details of your visits to and actions on our Website including, but not limited to, traffic data, location data, weblogs, conversion data, behavioural data and other communication data.
• Information about your device, including where available your IP address, operating system and browser type.

2 How the information is used

We process your personal data for the purposes of providing the agreed services to you and for related legitimate business activities such as:

• facilitating subscriptions, and digital chess content purchases;
• billing you;
• to help us identify you and any accounts you hold with us;
• administration;
• advertising;
• fraud prevention and detection;
• customising Chess24 and its content to your particular preferences;
• to notify you of any changes to Chess24 or to our services that may affect you;
• statistical analysis; and
• improving our services.

We will ask for your specific consent if we additionally intend to use your information for any of the following purposes:

• research, and behavioural analysis;
• customer profiling and analysing your purchasing preferences;
• marketing
• customising Chess24 and its content to your particular preferences.

3 The legal basis for processing personal data

In some cases, the legal basis for the processing of your personal data is your consent. This is the case, for example, if you agree to us emailing you with marketing information. Any consent you provide may be withdrawn at any time by contacting our Customer Support Team, or following the "unsubscribe" directions that follow with each direct marketing communication.

In other cases, the processing will be necessary for the purposes of our providing you with our Website and corresponding products and services, as referred to in our Terms of Use.

Also, we may process personal data in accordance with our legitimate interest in providing and developing our Website and corresponding products and services to you and other users – provided that those interests are not outweighed by your rights and interests. If you think that your rights and interests do outweigh our legitimate interests in providing the above, please let us know by contacting our Customer Support Team.

We may also process your data where:

• This is necessary to allow us to comply with our legal obligations; or
• If you have previously given consent to us processing your data (for example, in relation to our sending you marketing information by email). Please note that you can freely withdraw such consent at any time by contacting our Customer Support Team, or following the "unsubscribe" directions that follow with each direct marketing communication. If you do withdraw your consent, and if we do not have another legal basis for processing your information, then we will stop processing your personal data. If we do have another legal basis for processing your information, then we may continue to do so subject to your legal rights. More details about your data protection rights are set out in section 7 "Your rights".

4 Where we store your personal data

All information you provide to us is stored in infrastructure that is exclusively owned by us or exclusively licensed to us and that uses state of the art techniques to restrict access from third parties. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

5 Disclosure of your information

To achieve the purposes mentioned in this Privacy Policy and Notice and to the extent necessary, we may disclose your personal data to Chess24's agents, service providers and other companies within the Chess.com Group, hereunder affiliates. These third parties may include, amongst others, financial institutions, technological and analytical service providers, advertising and marketing-related partners and other service providers.

We may also share your personal data with any corporate purchaser or prospect to the extent permitted by law as part of any merger, acquisition, sale of assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which personal data would be transferred as a Chess24’s asset.

Lastly, we may share your personal data in order to comply with Chess24's legal obligations, court orders or other legal processes, to comply with a request from our regulators, governmental requests or any other legally enforceable demand.

For service efficiency purposes, some of these affiliates and third parties are located in territories outside the EU/EEA, and from time to time we may transfer your personal data to a third country not being approved by the European Commission as a safe country for such transfer (adequacy decision). Whenever applicable Chess24 will use the Standard Contractual Clauses to ensure an equivalent level of protection as granted within the EU/EEA or other lawful grounds for carrying out said transfer.

Our Website may, from time to time, contain links to and from the sites of our partner networks, advertisers and affiliates. If you follow a link to any of these sites, please note that these sites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these sites.

6 Deletion

We delete personal data when there is no longer a need to retain these for the purposes for which they were collected, see sections 1 and 2.

Please note that certain types of data may be retained for a longer period if such retention is necessary to resolve disputes, enforce Chess24's user agreements or to comply with technical and legal requirements and constraints related to the security, integrity and operation of the Website and corresponding products and services.

7 Your rights

You have a number of rights in connection with Chess24's processing of your personal data. If you have any questions or want to enforce your rights, we encourage you to contact our Customer Support Team or our Data Protection Office at dpo@chess24.com.

Below, you can see what rights you have at all times:

• Right to access: You have the right to access to the data that is registered on the Website, and can gain access to this data through your user account. You can also request access to what personal data we have registered about you by contacting us in writing, to the extent that this right is not restricted by applicable law. We reserve the right to require the person requesting access to verify their identity, to ensure that the personal data is disclosed to the right person.
• Right to rectification or deletion: You have access to the data that is registered on the Website, and can gain access to this data through your user account. If data is incorrect or outdated you can edit them yourself through your user account. Please note that you cannot make use of the Website if you delete certain data categories. If you cannot delete or update certain data, you can request that we correct or delete them. We will, so far as possible, respond to a request to delete personal data, but we cannot do this if there are compelling reasons not to delete, for example, that we must store the information for documentation purposes.
• Right to withdraw consent: If you have consented to us processing your personal data in order to receive newsletters or other forms of marketing, you may withdraw this consent at any time. When sending out newsletters, we have arranged it so that you may easily opt out of these types of communications, by including a link to an unsubscription-form in each communication.
• Right to object or restrict a processing activity: Subject to certain conditions, you may have the right to object to, or request that we restrict our processing of your personal data. This may be the case where we process your personal data based on our legitimate interests, for example in relation to advertisement and personalization technologies.
• Right to lodge a complaint with a supervisory authority: If you disagree with the way Chess24 processes your personal data, you can lodge a complaint with the relevant supervisory authority. We hope that you choose to contact us first through our Customer Support Team.

8 Cookies

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.

Depending on your settings, 3rd parties may save your information in cookies. We may use 3rd party vendor re-marketing tracking, by means of Facebook Ads and Google Adwords tracking cookies. This means we may show ads to you across the internet, specifically on Facebook and the Google Content Network (GCN). We use Google services to display advertising that helps cover the cost of our free features. Details of how your data is handled can be found here: https://policies.google.com/technologies/ads.

9 Do not use Chess24 for private and sensitive data

We do not wish for Chess24 to be used for the processing of any sensitive data. Do not use Chess24 (including its messaging function) to share with any user any personal contact information like your phone number or street address. Do not use Chess24 to send or store any item revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

10 Changes to our Privacy Policy

We may make changes to this Privacy Policy. Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email or when logging into the Website.

11 Contact

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to our Customer Support Team, or by contacting our Data Protection Office at dpo@chess24.com.