PRIVACY POLICY

The terms of this Privacy Policy apply to the use of www.ottaplay.com and related Services offered by FOOKSTAR TECH PTE. LTD. (hereinafter the “OTTA”, “Our”, “We” or “Us”).

OTTA values the privacy of its online visitors to the Website and users of its Services and complies with applicable data protection legislation to safeguard your privacy in accordance with the Personal Data Protection Act 2012 (PDPA) of Singapore.

We are committed to ensuring that your personal data is protected and handled responsibly. Our Privacy Policy outlines how we process (collect, use, disclose, share, and manage) your personal data when you interact with our Website and Services. By accessing or using our Website and Services, you consent to the processing of your personal data as described in this Privacy Policy.

Your registration or authorization on the Website signifies your acceptance of this Privacy Policy. If you disagree with this Privacy Policy, please refrain from using the Services and Website.

SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to all Services provided by OTTA and extends to all pages of the Website. Additionally, any other Services created by OTTA that provide a link to this Privacy Policy are bound by the regulations outlined herein.

TERMS AND DEFINITIONS

Personal Data–means any information relating to an identified or identifiable individual person–“Data Subject”.

Data Subject–means the individual person whose personal data is processed (hereinafter: “Data Subject”, “You” or/and “User”).

Processing–means any action or set of actions with personal data.Profiling – means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

Controller–means an individual or legal entity (and others) that determines the purposes and methods of personal data processing.

Processor–means an individual or legal entity, who processes personal data on behalf of the Controller.

Recipient–means an individual or legal entity, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not.

Third Party–means any other person, except the Subject of personal data, the Controller or Processor, and the Data Protection Authority to whom the Controller or Processor transfers personal data.

Consent of the Data Subject (hereinafter “Consent”)–means any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Personal Data Breach–means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Co-Controller–means an individual or legal entity (among others) that, in collaboration with another Controller, defines the purposes and methods of processing personal data.

Data Protection Authority–means a public organization or governmental body that safeguards Data Subjects from unauthorized processing of their data.

Legal Basis for Processing–means one of the legally stipulated reasons for which the processing of personal data is permissible.

Cookies–means small text files that contain any data. Cookies are stored on the PC of the Data Subject to provide access to various features. Cookies facilitate the operation of the Website and allow the Website to recognize the Data Subject’s device and store specific information about the Data Subject’s preferences or past actions.

Website–means a set of interconnected web pages crafted using different programming languages. It is accessible on the Internet through the address https://www.ottaplay.com and is supervised by the Controller.

Service–means any paid and free existing and future services and offerings created by the OTTA team and provided on the Website for use, including those that may be added, updated, or modified.

Platform–means the Website and Services together.

Social Features–means the social networks that OTTA owns: Facebook, X, YouTube, Instagram, Discord, TikTok, Faceit.

PRINCIPLES RELATING TO THE PROCESSING OF PERSONAL DATA

We handle your personal data responsibly and ensure compliance with data protection laws, making every effort to do so. Below, we outline the principles that guide us in processing your personal data.

Principle of Lawfulness, Fairness, and Transparency.

OTTA confirms that your personal data is processed lawfully, fairly, and transparently in accordance with the principle of "lawfulness, fairness and transparency".

Principle of Purpose Limitation.

OTTA is committed to the principle that your personal data must be collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes.

Principle of Data Minimization.

OTTA strives to ensure that your personal data remains adequate, up-to-date, and limited to what is necessary for the purposes for which it is processed.

Principle of Accuracy.

OTTA is dedicated to ensuring that personal data is accurate and, when required, regularly updated.

Principle of Integrity and Confidentiality.

OTTA strives to ensure that your personal data is processed in a manner that guarantees appropriate security, including protection against unauthorized or unlawful processing, as well as accidental loss, destruction, or damage.

WHAT PERSONAL DATA DOES OTTA PROCESS?

OTTA processes various types of your personal data as part of providing our Services on the Website. This personal data may include, but is not limited to:

Types of Personal Data Collected:

- Name and Surname, Date of Birth, Country of Residence, Registered Address or Actual - Place of Residence;

- Personal Photos;

- Email Address;

- Information about your social connections and contacts, including friends, followers, and subscriptions;

- Payment Card Data, Bank Account Information, Payment Amounts and Payment Methods Used, Data on Purchases, Transaction History;

- Device Type, Unique Device Identifiers;

- Network Data, Internet Connection Characteristics, IP Address, Browser Data;

- Operating System Version;

- Profile Information on the Website;

- Login Frequency, Achievements, Match Statistics, Gaming Activity History on the Platform, Preferences and Interests Regarding Gaming Content;

- Other Personal Data required to achieve the purposes described herein and not prohibited by applicable legislation.

Purpose of Collection:

- To identify the User, provide personalized services, and ensure account security;

- To analyze User behavior, improve Website functionality, and provide personalized content and Services;

- To process payments for Services and maintain financial records;

- To ensure the security and functionality of the Platform, as well as prevent fraud and abuse;

- To enhance social interaction within our Platform, provide recommendations, and personalized content;

- To analyze the audience, personalize Services, and direct marketing efforts;

- To adapt content and Services to specific devices, ensure compatibility, and analyze resource usage;

- To provide functionality related to gaming and other interactive services on the Platform;

- To organize and conduct gaming events, contests, and promotions;

- To detect and resolve Service functionality issues and improve product development;

- To address and resolve User inquiries, technical issues, and feedback.

Source of Collection:

- Through your personal provision of such data during registration or profile activation;

- Through server logs or cookie files;

- Through your personal input of payment data during payment processing;

- Through your interaction with our social media accounts;

- Through automatic transmission of such data by your device to our servers;

- Through third-party sources and publicly available information.

PROCESSING OF PERSONAL DATA FROM THIRD PARTIES

We may receive personal data about you from third parties, including partners with whom we collaborate on joint services or marketing initiatives, as well as from publicly available sources such as social media platforms and public databases. This information is combined with the personal data we already hold to enhance our services, update and expand our records, and better understand your preferences and interests. This allows us to tailor our offerings and provide you with more personalized and relevant products and services. We may also use this personal data to optimize our advertising and commercial initiatives in line with your interests and preferences.

Legal Basis:

- Your explicit consent to the processing of such information through registration or use of our Website or Services;

- Based on legitimate interest;

- Based on the performance of necessary contractual obligations;

- Based on the need to comply with legislative requirements.

Retention of Personal Data:

The retention periods for the above information and personal data are fully regulated and comply with the applicable legal requirements for personal data processing.

HOW DOES OTTA SHARE PERSONAL DATA WITH OTHERS?

OTTA adheres to high standards of privacy and data protection. In this section, we explain how we process and make personal information available provided by or collected through the use of our Services and Website.

Partnerships.

We may share your personal data with partners we collaborate with to enhance our Services and Website or provide additional features. These partners may include payment systems, analytics companies, and other service providers.

Legal Requirements.

In the event of receiving requests or other written inquiries from various government authorities—judicial, law enforcement, investigative, supervisory, and others—in accordance with applicable law, we may provide access to your personal data.

Marketing and Advertising.

We use personal data for marketing and advertising purposes, including joint actions with advertising partners for more accurate targeting of advertising campaigns.

Analytics and Research.

Your personal data may be used for analytical purposes, such as studying user behavior and improving our Services and Website.

Payment Processing and Transactions.

Your personal data may be transmitted to third-party payment systems and financial institutions for processing payments and transactions.

Transmission in Specific Situations.

We may transfer your personal data by default to countries recognized by relevant authorities as providing an adequate level of protection. We take all necessary measures to ensure the security and confidentiality of your personal data when transferring it to third parties.

Because we provide our Services worldwide and our Website is accessed through servers located in different regions, the personal data of a particular Data Subject may be processed in a country other than where that Data Subject resides. Regardless of where your personal data is processed, we adhere to all necessary security measures and legal requirements governing the processing of personal data.

By using our Website and/or Services, you agree to the terms of this Privacy Policy. Your continued use of the Website and/or Services indicates your ongoing consent to the processing of your personal information as outlined herein.

HOW DOES OTTA PROTECT PERSONAL DATA?

OTTA takes the protection of your personal data very seriously and adheres to high standards of confidentiality. To protect your personal data on our Website, OTTA employs various methods and technologies including:

• Data Encryption.All data transmitted through the Website, including your personal data, is encrypted using modern encryption methods. This helps prevent unauthorized access to personal data.

• Server Protection.OTTA maintains high security standards for its servers to prevent unauthorized access to stored personal data.

• Monitoring and Detection Systems.The Website is equipped with monitoring and detection systems that constantly track activity and identify any suspicious or anomalous actions.

• Employee Training.All employees receive training on data security and confidentiality to ensure the proper handling and protection of your personal data.

• Access Controls.Access to personal data is restricted to employees on a need-to-know basis, ensuring that only those required to perform their job duties have access.

• Data Storage.Personal data is stored across multiple databases to enhance data resilience and minimize the risk of data loss.

• Third-Party Integrations.Integration with third-party software is conducted through official APIs, ensuring secure data exchange and minimizing unauthorized access.

HOW DOES OTTA DELETE PERSONAL DATA?

When it comes to deleting personal data, OTTA follows a rigorous process to ensure compliance with data protection regulations and to respect your privacy. The steps involved include:

Identification.

We identify the specific personal data to be deleted, ensuring accuracy and completeness in the process.

Verification.

We verify the legitimacy of the deletion request to ensure it is authorized by the Data Subject or required by law.

Data Removal.

Once verified, we proceed to remove the identified personal data from our systems, databases, and any associated backups.

Permanent Erasure.

We ensure that the deleted personal data is permanently erased from our storage systems to prevent any potential retrieval or unauthorized access.

Confirmation.

Upon completion of the deletion process, we provide confirmation to the Data Subject or the relevant Data Protection Authority, acknowledging the successful removal of the personal data.

Types of Grounds for Deleting Personal Data:

• Consent.

If personal data is processed based on your consent and you withdraw that consent, OTTA will promptly delete your personal data in accordance with applicable legislation.

• Contractual Obligation.

If personal data is processed based on a contract between you and OTTA, and that contract is terminated, we will promptly delete your personal data.

• Legal Obligation.

If personal data is processed based on legal obligations, it will be deleted once such obligations cease.

• Vital Interest.

Personal data processed on the basis of your vital interest will be deleted once that interest is no longer applicable.

• Legitimate Interest.

If personal data is processed based on OTTA's legitimate interests and you object, we will delete your data after reviewing your objection.

Exceptions:

• Business Needs.Timeframes may be extended (but not exceeding 6 months) if deleting the data would interrupt ongoing services.

• Legal Requirements.The retention period may be extended if mandated by laws or governmental orders.

• Technical Impossibility.Some information may be retained if deletion is technically impractical or could compromise system integrity.

• Anonymization.Data may be further processed in an anonymized form for research or analytical purposes.

THE RIGHTS OF PERSONAL DATA SUBJECTS

OTTA is committed to safeguarding the rights of Data Subjects regarding the personal information we gather. In accordance with applicable legislation, you have the following rights:

• Right to Receive Information.You have the right to request information about the personal data we hold about you.

• Right of Access.You have the right to obtain a copy of the personal data we have collected about you.

• Right to Rectification.If your personal data is inaccurate or incomplete, you have the right to request its correction.

• Right to Erasure ("Right to be Forgotten").You may request the deletion or restriction of processing of your personal data if you deem it necessary.

• Right to Restrict Processing.You have the right to limit how your personal data is processed.

• Right to Data Portability.You have the right to receive your personal data in a structured, commonly used, and machine-readable format and transfer it to another controller.

• Right to Withdraw Consent.If you have consented to the processing of your personal data, you may withdraw your consent at any time without affecting the lawfulness of processing prior to the withdrawal.

• Right to Object.You have the right to object to the processing of your personal data under certain circumstances.

• Right to Not Be Subject to Automated Decision-Making.You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects.

• Right to Lodge a Complaint.You have the right to lodge a complaint with the relevant Data Protection Authority if you believe your personal data is not being processed in accordance with applicable laws.

COOKIES POLICY

Please review this Cookies Policy to learn more about the cookies we place and the information we collect when you use our Website. Our Cookies Policy applies solely to our Website; we recommend reviewing the cookie policies of other websites you visit.

User Settings Related to Cookies:

Please note that refusing cookies will not affect the use of essential cookies required for the operation of the Website. You can disable cookies at the browser level.

Cookies Used on Our Website:

We use cookies on our Website to enhance your browsing experience. These cookies serve various purposes such as remembering your preferences, facilitating navigation, and ensuring the proper functioning of essential features. Our cookies include:

• Essential Cookies:

These are indispensable for the operation of our Website, enabling secure access and authentication processes.

• Performance and Analytics Cookies:

These gather data on your usage of the Website, including pages visited and errors encountered, to help us assess and improve website performance.

• Functionality and Customization Cookies:

These remember your preferences and customizations (e.g., language, currency settings).

• Security Cookies:

These support security features and help identify and mitigate malicious activity.

Third-Party Cookies:

We may also utilize third-party cookies from trusted service providers (e.g., Google Analytics) to analyze usage patterns and deliver content from third-party sources.

Privacy Policy Updates

OTTA reserves the right to amend this Privacy Policy at any time. We will notify you of any changes by updating the "Effective Date" and publishing the revised Privacy Policy on our Website. Your continued use of the Website and/or Services signifies your acceptance of the updated Privacy Policy. If you do not agree to the changes, please discontinue using our Website and/or Services.

Applicable Law

This Privacy Policy is designed to comply with applicable laws, including the Personal Data Protection Act 2012 (PDPA) of Singapore.

Confirmation of Acceptance

By using our Website and/or Services, you confirm that you have read, understood, and accepted the terms of this Privacy Policy, and you consent to the processing of your personal data as described herein.

Data Controller Details

The Controller of personal data is FOOKSTAR TECH PTE. LTD. More details about the Data Controller are specified in the relevant section of our Terms of Use.