Privacy Policy

Last updated version: November 07th, 2024.

I. INTRODUCTION

Prodigy Agency's mission through this Website is to meet the objectives of transparency required by the regulations regarding the Data collected about you, define their use and the entities with which we share them and this, in accordance with the Regulation of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter "GDPR").

As such, this Privacy Policy applies whenever we collect Data that allows us to identify you and after you have expressly agreed to it or to use our Services (described below).

This Privacy Policy applies to the Website and any related applications and communications, excluding those services explicitly provided under another privacy policy.

We collect your Data when you do any of the following actions on our Website: Contact and information requests Newsletter subscriptions Any other section in which you are asked for Personal Data.

II. DEFINITIONS

"Personal Data" or "Data": meaning information relating to a natural person identified or identifiable, directly or indirectly, by elements that are specific to her/him.

"Prodigy Agency": meaning the Company that holds and publishes all the rights (including those relating to intellectual property) of the Website and makes available to all Users said application. Prodigy Agency, a simplified joint stock company with a share capital of 85,000 euros, registered with the Trade and Companies Register of Toulouse under the number RCS 890 673 965 and whose headquarters are located at 3 rue Dieudonné Costes, 31700 Blagnac.

"Services": meaning all the functionalities offered by the Website as well as the other websites, applications and communications linked to it, offered under this Contract.

"User": meaning any natural person who accesses the Website, on their own or on behalf of a third party, regardless of where they are and how they connect to the Website.

"Website": meaning the website https://prodigy-agency.gg/ designed by Prodigy Agency.

III. CONTROLLER AND CONTRACTING PARTIES

The person in charge of the processing is PRODIGY AGENCY, bearing the SIREN number 890 673 965 also referred to as the "Company", whose registered office is located at 3 rue Dieudonné Costes, 31700 Blagnac (France).

As a User of our Services, the collection, use and sharing of your Personal Data is subject to this Privacy Policy and its updated versions.

The Company may change this Privacy Policy and, if the changes are material, we will notify you via the Services or other appropriate means to give you an opportunity to review the changes before they take effect. If you object to any of the changes, you may close your account, notify the Controller or the Data Protection Officer of the Subcontractor.

You acknowledge that your continued use of our Services after we post or notify you of changes to our Privacy Policy means that your collection, use and sharing of Personal Data is subject to the updated Privacy Policy.

IV. COLLECTED DATA

You will find in this Privacy Policy the details of the Data we collect, process and the purpose of such processing.

a. Data you provide to us

The Personal Data we collect are collected through forms and through information submitted directly to our Website.

The types of Data that you may be asked to provide according to the contact forms, are the following:

  • Last name
  • First name
  • Nationality
  • Country of residence
  • E-mail address
  • Date of birth
  • Player nickname
  • Twitter account
  • HLTV Profile
  • Company name
  • Position in your company
  • Phone number (landline or mobile)
  • Postal code
  • Highest degree
  • Specialty and year of graduation
  • Mother tongue
  • English level
  • French level
  • Other spoken languages
  • Number of years of experience in a given job
  • Employed or not

b. Data collected from third parties

We do not collect Data from any third parties.

c. Data that we deduce

We may create deduced Data from the Personal Data you provide to us through the various forms on the Website. The types of deduced Data will be as follows:

  • The form(s) you have completed (such as event registrations, satisfaction surveys or contests)
  • The campaign proposals that you have sent us
  • The partnership/sponsorship proposals that you have sent us
  • The application form to join our teams

d. Cookie

Our Website does not use cookies to recognize you and/or your devices, when you log in/out or move from one Service to another. We do not allow third parties to use cookies. You can control cookies through your browser preferences and other tools.

e. Evolution of Collected Data

Because our Services are dynamic, we may offer new functionalities that may require the collection of new Data. If we collect Personal Data of a substantially different nature or make material changes in our use of your Data, we will notify you and will also amend this Privacy Policy.

V. USE OF YOUR DATA

We use your Personal Data to provide and personalize our Services so that they are more relevant and useful to you and other Users.

a. Services

We collect your Data to enable you to:

  • Access the Website;
  • Obtain information about Prodigy Agency and its business activity, the Players it represents and its environment;
  • Contact us through forms;
  • Access third party websites on all the Players we represent.

b. Services development

We use Data to conduct research and development related to our Services (Newsletter, various promotional offers, information on events, etc.), to provide You and other Users with a better, more intuitive and personalized experience.

c. Support service

We use the Data to investigate, respond to and resolve complaints and problems with the Services (such as bugs). You can contact our support service by email at the following email address: data-protection@prodigy-agency.gg

d. Aggregated information

We use your Data to produce and share aggregated information that does not allow to identify you.

e. Security and investigations

We use your Data when necessary for security purposes, or to investigate suspected fraud and other violations of Prodigy Agency's Terms of Use or this Privacy Policy and/or attempts to cause harm to our Users.

VI. PURPOSES AND LEGAL BASIS

We may process your Personal Data in connection with the Services offered by the Company for the purposes listed below:

  • To provide you with informational content,
  • To contact you and offer you, directly or indirectly, our products and Services or partnership,
  • To improve the Services that we offer you or that we may offer you.

We only collect and process Personal Data about you for which we have a legal basis. These include your consent (where you have given it to us). When the processing of your Personal Data is subject to your consent, you have the right not to consent or to withdraw your consent at any time.

If you have any questions about the legal basis on which we rely for the collection and use of your Personal Data, please contact our Data Protection Officer whose contact information is set out in Article X.

The Data Controller further reserves the right to delete your Personal Data on the basis of or because of:

  • The irrelevance of the information we send you in relation to your User profile,
  • An error relating to the email address you provided,
  • Exceeding the maximum retention period of the Data since their last collection (Article IX).

This unilateral deletion will be implemented, in addition to these criteria, provided that you have not subscribed to our newsletter.

VII. SHARING OF YOUR DATA

a. Our Services

Only the Data Controller will have full access to your Personal Data in accordance with the above provisions. Your Personal Data will not be visible or available to third party Users or persons (such as users of third party search engines).

b. Service providers and subcontractors

We use third parties and subcontractors to provide our Services (e.g., for hosting, maintenance, malware and virus detection, application development, internal processing of Data). They have access to your Data to the extent necessary to perform some tasks on our behalf, and are required not to disclose it or use it for any other purpose.

Authorized subcontractors are:

  • Our US lawyers: Odin Law & Media, 4208 Six Forks Rd., STE 1000, Raleigh, NC 27609, USA.
  • Host of the Website: OVH, 2 rue Kellermann, 59 100 Roubaix, France
  • CRM: Hubspot, 25 First Street, 2nd Floor Cambridge, MA 02141 United States
  • Our commercial partners with whom we sign a specific contractual appendix for the respect of Data processing.

c. Legal disclosures to authorized third parties

We may be required to disclose information about you when we are required to do so by law, court order or other legal process, or if we believe in good faith that such disclosure is reasonably necessary to:

  • Investigate, prevent or take action regarding known or suspected illegal activities or to assist law enforcement agencies;
  • Fulfill contracts with you;
  • Investigate and defend against allegations and complaints from third parties;
  • Ensure the security and integrity of our Services (for example, by sharing with partner companies facing similar threats);
  • Exercise or protect the rights and safety of our Company, our Users, our staff or third parties.

If we deem it appropriate, we will endeavor to notify Users who are subject to a lawful request for disclosure of their Personal Data, except in cases of emergency or where prohibited by law or court order. We may challenge such requests where we believe, in our sole discretion, that they are excessive, vague or not properly authorized, but we do not undertake to challenge all such requests.

d. Unauthorized third parties

Your Personal Data is only intended for use by the Company and only accessible by the persons authorized to manage it, according to the purposes of the collection and the authorizations of each person and within the limits of their respective attributions in accordance with what has been previously stated in the Contract.

e. Acquisition of control or sale of the Company

We may share your Personal Data in connection with, or in preparation for, a sale, merger or takeover of our Company. Any third party entity that acquires all or in part of our Company will be permitted to access your Data, but only in accordance with this Privacy Policy, unless you tell us otherwise.

VIII. YOUR RIGHTS

In accordance with the laws and regulations relating to the protection of Personal Data in force, you have the following rights:

  • RIGHT OF ACCESS: The right to obtain confirmation as to whether or not your Data is being processed and to obtain a copy of it.

  • RIGHT OF RECTIFICATION: The right to obtain, as soon as possible, the rectification of your Personal Data in case of inaccuracy. You may also ask us to modify, update or correct your Data in certain cases and in particular if it is inaccurate.

  • RIGHT TO DELETION: The right to obtain erasure or deletion, as soon as possible, of all or part of your Personal Data where one of the grounds in Article 17 of the GDPR applies. Under this Privacy Policy, the deletion of your Personal Data may take up to thirty (30) calendar days.

  • RIGHT TO LIMIT PROCESSING: The right to have the Company cease processing all or part your Personal Data or limit our use of it for the reason referred to in Article 18 of the GDPR.

  • RIGHT TO DATA PORTABILITY: The right to receive your Personal Data held by us in a structured, commonly used and machine-readable format as well as the right to transfer such Data to another data controller.

  • RIGHT OF OPPOSITION: The right to request that we no longer process your Personal Data for a reason related to your particular situation or without reason in the case of commercial prospecting.

  • RIGHT TO WITHDRAW YOUR CONSENT: The right to withdraw your consent to the processing of your Personal Data by the Company at any time.

You may exercise these rights or ask any questions regarding the management of your Personal Data at the following address: data-protection@prodigy-agency.gg

IX. STORAGE TIME

We store your Personal Data for three (3) years from the last time the Data was collected or updated. This above rule applies to Data you have submitted to us as well as to Data generated or inferred as a result of your use of our Services.

If you wish to object to the retention of your Data, you may contact our Data Protection Officer (DPO) by e-mail in accordance with Article X.c).

X. OTHER RELEVANT INFORMATION

a. Security measures

The Personal Data we collect is kept in a secure environment. The people who work for us are required to respect the confidentiality of your Data.

To ensure the security of your Personal Data, we use the following measures:

  • HTTPS protocol
  • Access management
  • Specific staff authorizations

We regularly monitor our systems for vulnerabilities and attacks. We are committed to maintaining a high level of confidentiality to ensure the privacy of your transactions.

However, since no mechanism offers maximum security, there is always a degree of risk involved when using the Internet to transmit Personal Data. Indeed, there is no guarantee that the Data will not be accessed, disclosed, modified or destroyed by a breach of our management, technical or physical safeguards. If this should happen, we will take steps to stop the breach as soon as possible.

b. Transfer of Data outside the European Union

We process your Data in compliance with the European and French regulations on Personal Data and in particular with the General Data Protection Regulation (GDPR) n°2016/679 of the European Parliament and of the Council of 27 April 2016 and the law n°78-17 of January 6th, 1978 known as "Informatique et libertés" in its latest version.

In this context, the recipients of the Personal Data that we may collect may be located abroad, including outside the European Economic Area (EEA) in countries where the legislation on the protection of Personal Data differs from that applicable within the EEA. Any transfer of Data outside the EEA is made subject to appropriate safeguards, including contractual safeguards, in accordance with applicable data protection regulations.

c. Contact details

If you have any questions or complaints regarding this Private Policy, please contact our Data Protection Officer (DPO) either:

By postal letter at the following postal address: PRODIGY AGENCY, For the attention of the Data Protection Officer, 3 Rue Dieudonné Costes, 31700 Blagnac, France By email at the following address: data-protection@prodigy-agency.gg

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