Groov Esports Platform LLC – Group Privacy Policy 

Effective Date:  September 11, 2025 Last Updated: September 11, 2025

1. Introduction: Our Commitment to Your Privacy

Welcome to Groov! This group privacy policy (the “Privacy Policy”) explains how Groov Esports Platform LLC ("Groov", "we", "us" or "our") collects, uses, stores, shares, and protects your personal information when you use our mobile applications, website (accessible via the URL: Groov.gg), APIs, Seeder platform, and related services (collectively, the "Platform").

Groov Esports Platform LLC is a company incorporated in mainland Dubai, the United Arab Emirates (“UAE”) (UAE Licence No.1364388, with its registered office at 128-246, Al Khabeesi Building, Al Khabeesi, Dubai, United Arab Emirates. For the avoidance of doubt, we are the data controller for the personal information we process, unless otherwise stated.

We are committed to protecting your privacy and ensuring that your personal information is handled securely, transparently and responsibly. This Privacy Policy predominantly complies, and is to be construed in accordance with the UAE’s Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“PDPL”), but it also compliant the European General Data Protection Regulation (“GDPR”), the UK Data Protection Act 1998 (“UK DPA”), the Singaporean Personal Data Protection Act (“PDPA”), the California Consumer Privacy Act (“CCPA”), and other applicable privacy laws and regulations.

We are also committed to making this Privacy Policy easy to interpret, clear and accessible. If you have trouble accessing or understanding this Privacy Policy, please contact us using the contact details prescribed in Paragraphs 17 and 18 of this Privacy Policy (as applicable).

By using and/or accessing our Platform, you acknowledge and agree that you have read and understood this Privacy Policy and agree to be bound by its terms. 

2. What Is Personal Information

Personal information means information about an identified or identifiable natural person who can be identified, directly or indirectly with reference to an identifier. Identifiers may include your name, identification number, location data, an online identifier, address, email, phone and other items prescribed under either the PDPL, GDPR, UK DPA, PDPA, CCPA or other applicable laws (as the case may be).

3. What Information We Collect About You

We collect information in a few different ways to provide and improve our Platform, ensure security, and comply with legal obligations. You acknowledge and agree that if we do not collect personal information directly from you, we may obtain it from third-party sources including but not limited to through third party providers, social media platforms, marketing partners or other third parties as prescribed in Paragraph 3 of this Privacy Policy below (as the case may be).

3.1. Information You Provide Directly to Us:

  • Account Registration: When you create an account, we collect information such as your chosen username, email address, password, and date of birth (for age verification purposes as our Platform is intended for users strictly aged 16 years and older). If you register using OAuth (Google/Apple), we receive basic profile information from those services as authorized by you (e.g. your full name, email address and profile picture).

  • Profile Information: You may choose to add more information to your public profile, including a profile picture, bio description, linked game accounts, your team affiliations, your created avatar and any equipped avatar sets, and other details you wish to share. Certain information, such as your username and avatar will be public by default. You can typically review and update your profile information through your account settings on our Platform. 

  • User-Generated Content (“UGC”): We collect the content you create, generate, upload, or share on the Platform. This includes:

    • videos you upload to Showcase;

    • content you stream or shared during ‘Hangouts’;

    • messages you send in chats and voice call metadata (see Section 3.2 for more on chat data);

    • tournament assets, rules, and descriptions if you are an ‘Organizer’; and

    • comments, likes, and other interactions over our Platform. 

  • Know Your Customer (“KYC:) Information: For certain features, such as processing prize payouts for tournaments or complying with our applicable legal and regulatory obligations, we (or designated tournament ‘Organizers’) may require you to provide identity verification documents. This may include a copy of your government-issued ID, proof of address, or other relevant documents. We will clearly inform you when this information is required.

  • Communications with Us (Support, Feedback, Reports): When you contact our support team (e.g. via email at legal@Groov.gg or in-app help & support), participate in surveys, provide us with feedback regarding our services, or report another user or specific content on our Platform, we collect the information you provide in those communications, including any descriptions or attachments pertaining thereto.

  • Financial & Transaction Information (Limited):

    • When you purchase ‘Pro Subscriptions’ or ‘Crystals’, these transactions are processed by third-party payment gateways (e.g. Apple In-App Purchase, Google Play Billing, PayPal). We do not directly store your full credit card details; however, we receive transaction confirmations, subscription status, and limited information necessary to manage your purchases and subscriptions. For the avoidance of doubt, under no circumstances whatsoever are we responsible for any privacy practices of such third-party payment gateway providers, and hereby direct you to refer to their respective privacy policies for further information concerning the way they collect, use, store and share your personal information. 

    • If you are eligible for our ‘Revenue Sharing Program’, we will require you to provide your PayPal account details (e.g. email address associated with PayPal) to process payouts. PayPal privacy statement can be accessed via the URL: https://www.paypal.com/us/legalhub/paypal/privacy-full, however do note that this link may be updated by PayPal from time to time. 

  • Address Book/Contacts (Opt-In): If you choose to use features that help you find friends on the Platform by uploading your device's address book, we will collect this information only with your express opt-in consent. You can manage or revoke this consent at any time through your account settings on our Platform.

  • Game Account Linking: If you choose to link your Groov account to third-party game accounts (e.g. Steam, Riot Games, PlayStation Network or Xbox Live), we will collect information from those platforms as authorized by you during the linking process. This may include your in-game username/ID, game statistics, achievements, and friend lists relevant to that game (as applicable from time to time). We use this information to enhance your Platform experience, for example, by displaying your game stats on your profile or verifying your eligibility for certain tournaments.

  • Information from Platform Integrations (Beyond Game Accounts): If Groov integrates with other third-party services beyond game accounts (e.g. streaming platforms such as Twitch for linking your streams, social media platforms for sharing content), we will collect information from those platforms only as authorized by you during the linking or sharing process. We will be transparent about what information is accessed and how it will be used by us or on our Platform.        

3.2. Information We Collect Automatically When You Use the Platform:

  • Usage Information: We collect information about how you use our Platform, such as the features you interact with, the content you view (“Showcases”, “Hangouts” and profiles), your activity in tournaments, teams you join or create, users you interact with, session duration, and the frequency and duration of your activities. This information is also used for calculations related to our revenue sharing program, where applicable.

  • Inferred Information: We may also infer certain information about your preferences and interests based on your interactions with the Platform (e.g. the types of games you play in tournaments and the “Showcase” content you engage with). We use this to personalize your experience, such as recommending content or features you may be interested in.

  • Device and Connection Information: We collect information about the device you use to access our Platform, including but not limited to:

    • Device attributes: Operating system, hardware and software versions, browser type and IP address.

    • Device identifiers: Unique device IDs, advertising identifiers (e.g. Google AdID or Apple IDFA (which you may reset or limit)).

    • Network and connection information: Language, time zone, mobile phone number (if provided) and mobile network information.

  • Cookies and Similar Technologies: We use cookies, pixel tags, local storage, and similar technologies to collect information about your browsing activities, remember your preferences, personalize content and ads, and analyze Platform traffic. For more information, please refer to our Cookie Policy.

  • Chat and Voice Call Data (Non-E2EE):

    • While messages and calls are encrypted in transit and at rest in our databases, they are not End-to-End Encrypted (“E2EE”).

    • We collect metadata related to your chats and calls (e.g. participants, timestamps, duration and IP addresses).

    • We store message content on our servers for up to ninety (90) days to facilitate delivery and cross-device access.

    • As these communications are not E2EE, Groov may have the technical capability to access message content if strictly required by law (e.g. by way of authorized regulatory enquiries, a valid legal warrant or court order) or for investigating severe violations of any of our policies and/or terms and conditions that threaten Platform safety or the rights of others. We shall do so in our absolute discretion, but only under strictly defined internal protocols and legal review practices.

  • Anti-Cheat Data (for Tournaments): If you participate in tournaments where anti-cheat software is used (either by Groov or designated partners), this software may collect information from your device to detect and prevent cheating. This can include device identifiers, information about running processes, game files, screenshots, match replays, or short video clips taken during gameplay. You will be notified and asked for consent before such software is activated if it's a separate installation. For the avoidance of doubt, participation in such tournaments implies consent to the anti-cheat measures described in the tournament rules and our Terms & Conditions. This data is retained for a maximum of one hundred eighty (180) days unless an investigation requires longer retention.

  • Location Information (General): We may collect general location information based on your IP address or information you provide in your profile. We do not typically collect precise GPS location data without your express consent and authorization.

3.3. Information We Receive From Third Parties:

  • OAuth Services (Google/Apple): If you register or log in using Google or Apple, these services provide us with certain information about you, including your name, email address, and profile picture, as per your privacy settings with those services and your authorization. If you wish to restrict or amend such authorizations, you can do so directly in the account settings of such third-party providers. 

  • Payment Processors: While we don’t store full payment card details, our payment processors (i.e. Apple, Google and/or PayPal) provide us with transaction IDs, confirmation of payment, subscription status, and from time to time, limited billing information (including but not limited to your country or postal code) to help us manage your transactions and prevent fraud.

  • Advertising Partners: We may receive information from advertising partners (e.g. Google AdMob) about your interactions with ads on our Platform to help us measure ad effectiveness and personalize your experience (where you have consented to such personalization).

4. Implied Consent and Withdrawal of Consent 

By accessing our Platform, or utilizing any of our services, you consent to us collecting, using or disclosing your information including any personal information. We assume your consent to continue to use, store and, where applicable, disclose your personal information that we have already collected, for the purpose for which the information was collected on the terms and in accordance with the practices contemplated by this Privacy Policy. 

You acknowledge and agree that without your consent to provide your required personal information (e.g. email for account creation or KYC information for prize payouts), we may not be able to provide access to certain features or register your account on our Platform, as well as provide our services to you, in whole or in part. If we rely on your consent to process your personal information, you have the right to withdraw consent at any time by contacting us via email at privacy@Groov.gg.

5. How We Use Your Information (Purposes of Processing)

We use the information we collect for the following purposes:

  • To Provide and Operate the Platform:

    • Create and manage your Account.

    • Enable you to use Platform features (i.e. tournaments, teams, ‘Showcases’, ‘Hangouts’, chat, gifting, game account linking, etc.).

    • Process your purchases of “Pro Subscriptions” and ‘Crystals’.

    • Administer and process payouts for the ‘Revenue Sharing Program’, including but not limited to tracking which user gifts content to which creator to accurately calculate and attribute eligible shares using relevant activity and UGC interaction data.

    • Facilitate Platform Promotions: To process your requests when you use ‘Crystals’ to 'Boost' your content or purchase 'Mega Banners', using your UGC's metadata to increase its visibility as requested.

    • Personalize your experience (e.g. show relevant content, suggest connections, recommend tournaments or ‘Showcases’).

  • To Communicate With You:

    • Send you service-related announcements, updates to any of our policies, terms and conditions, and other administrative information.

    • Respond to your support requests, questions, and feedback.

    • Send you marketing communications (e.g. newsletters, information about new features or events) if you have opted-in to receive them. You can opt-out at any time whatsoever via our Platform or email.

  • For Safety, Security, and Compliance:

    • Verify your identity (including for KYC and age verification).

    • Monitor and enforce compliance with our Terms & Conditions and Community Guidelines, including investigating user reports and enforcing sanctions against users who violate our policies.

    • Detect, prevent, and investigate fraud, cheating (including through anti-cheat data analysis), unauthorized access, and other harmful activities.

    • Comply with our legal obligations (e.g. responding to legal requests from law enforcement or government authorities, financial reporting and compliance with anti-money laundering (“AML”) and counter-terrorism financing (“CTF”) requirements).

    • Resolve disputes and protect the rights and safety of Groov, our users, and the general public.

  • To Improve and Develop the Platform:

    • Analyze usage trends and user behavior to understand how our Platform is used.

    • Gather feedback to improve existing features and develop new features and functionality.

    • Conduct research and testing as may be required from time to time.

  • Training of Automated Systems/AI:

    To improve our Platform, develop new features, and enhance safety and security (including our content moderation, anti-cheat capabilities, and personalized recommendations), we may collect, store and utilize data, including your personal information for the development, training and deployment of our artificial intelligence (“AI”) and machine learning (“ML”) systems. For the avoidance of doubt, we shall do so strictly in accordance with the principles of lawfulness, fairness, transparency, purpose limitation and data minimization. All processing of such data is conducted on the basis of a valid legal ground and subject to appropriate technical and organizational safeguards, including pseudonymization or anonymization where applicable. We ensure robust risk management, human oversight, and bias mitigation throughout the AI lifecycle. In line with the GDPR, PDPL, and the EU Artificial Intelligence Act (Regulation (EU) 2024/1689 of the European Parliament and of the Council (the “EU Artificial Intelligence Act)”, we apply enhanced compliance measures to high-risk AI use cases, including transparency obligations, documentation, and conformity assessments where required.

  • For Advertising (where applicable):

    • To show you personalized or non-personalized ads on our Platform through partners such as Google AdMob. When you opt out of personalized ads, you will still see advertisements, but they will be generic or contextual rather than based on your specific inferred interests.

    • To measure the effectiveness of advertising campaigns.

    • Details on user choices regarding personalized ads will be available in your account settings and are further prescribed in our Cookie Policy.

6. Our Legal Basis for Processing Your Information (Primarily for GDPR Alignment)

If you are in a jurisdiction where the GDPR or similar laws apply (such as the PDPL in the UAE, which contains minimal departures from the GDPR), our legal basis for processing your personal information shall include the following:

  • Performance of a Contract: Our processing of your personal information is necessary to effect your access to, and the performance of our Platform and otherwise perform our contract with you as set out in our Terms & Conditions (e.g., creating your account, enabling features, processing payments and payouts).

  • Consent: We rely on your consent for certain processing activities, such as:

    • Sending you direct marketing communications.

    • Using cookies and similar technologies for non-essential purposes (as detailed in our Cookie Policy).

    • We do not intentionally collect sensitive personal data as defined under the PDPL and the GDPR, which includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health information, and data concerning a person’s sex life or sexual orientation (“Sensitive Personal Data”). If such Sensitive Personal Data is voluntarily disclosed by you through public UGC, your act of posting such content is considered to constitute explicit consent for its public display on the Platform. However, if any processing of such data extends beyond mere display, for example, if used for analytics, moderation, or profiling, we will only do so where we have obtained your explicit consent or another valid legal basis under applicable law exists. We apply heightened protections and governance measures to any processing of sensitive data in accordance with regulatory requirements.

    • Showing personalized advertising (where opt-in is the standard for such tracking).

    • Collecting data via anti-cheat software where explicit consent is sought prior to installation or participation.

    • You have the right to withdraw your consent at any time.

  • Legal Obligation: We process some information to comply with our legal obligations (e.g. complying with KYC, CTF and AML requirements, responding to valid legal requests and enquiries, complying with tax obligations, including but not limited to obligations under applicable UAE laws such as the PDPL).

  • Legitimate Interests: We process some information based on our legitimate interests (or those of a third party), provided these interests are not overridden by your rights and interests. Our legitimate interests include:

    • Providing, improving, and securing our Platform.

    • Preventing fraud and ensuring platform integrity (e.g. anti-cheat measures, content moderation in accordance with our Terms & Conditions).

    • Understanding how our users interact with our Platform to enhance their experience.

    • Showing non-personalized advertising to support our free services.

    • Enforcing our Terms & Conditions.

    • Using activity and UGC interaction data for calculating revenue shares as part of our contractual offering to ‘Pro Users’.

    • Training our automated systems and AI models with appropriately protected data to enhance platform functionality and security.

7. How We Share Your Information

We do not sell, monetize, profile or make automated decisions with respect to your personal information under any circumstances whatsoever. We may share your information with third parties in the following circumstances:

  • With Other Users:

    • Your public profile information (username, avatar, bio, team affiliations, linked game stats you choose to display) and your UGC (‘Showcase’ videos, public ‘Hangout’ participation unless anonymized) are visible to other users of the Platform by design.

    • When you interact with other users (e.g. in chats, teams, tournaments, by gifting), some of your information (including your username) will be shared as part of that interaction.

    • Tournament ‘Organizers’ may see the usernames and relevant game information of registered participants. Team ‘Captains’ may see information about their team members necessary for team management.

    • Tournament ‘Organizers’ may have access to participants’ usernames, in-game statistics, and other relevant gameplay information necessary for tournament administration. Where required for verification, logistics, or prize distribution, limited additional personal information (such as email addresses or country of residence) may be shared with ‘Organizers’, strictly on the basis of legitimate interest or contractual necessity, and subject to appropriate confidentiality obligations. Team ‘Captains’ may view information necessary for managing their team, such as usernames and basic profile data of team members. No Sensitive Personal Data is shared, and all data disclosures are governed by applicable data protection laws, including the GDPR and PDPL.

  • With Service Providers (Data Processors):

    • We engage third-party companies and individuals to perform services on our behalf (e.g. cloud hosting with providers such as AWS/Azure, data analytics with Google, payment processing (PayPal, Apple or Google), internal-customer support platforms, email delivery, advertising networks such Google AdMob, and anti-cheat technology providers (as the case may be from time to time)).

    • These service providers only have access to the personal information needed to perform their functions and are contractually obligated to protect your data and use it solely for the purposes for which it was disclosed to them, in accordance with our instructions. We have Data Processing Agreements (DPAs) in place with such providers where required. 

  • With Volunteer Moderators or Community Partners (If Applicable):

    • If we utilize volunteer moderators or community partners to assist with specific community areas or events, they may have access to limited user data necessary for their roles (e.g. reported content, involved user IDs etc.). Such individuals or entities will be bound by confidentiality and data protection agreements (including DPAs where necessary) with Groov.

  • For Legal Reasons and Compliance:

    • We may disclose your information if required to do so by law or in response to valid requests by competent public authorities (e.g. a court order, government inquiry, or law enforcement request), or to meet national security requirements.

    • We may also disclose your information to protect the rights, property, or safety of Groov, our users, or the public, to enforce our Terms & Conditions, or to prevent or investigate possible wrongdoing in connection with the Platform.

  • Business Transfers and Other Transactions:

    • In the event of a merger, acquisition, financing, investment activity, reorganization/restructuring, bankruptcy, receivership, sale of company assets, related party transactions, or transition of service to another provider (the “Transactions”), your personal information may be sold or transferred as part of such Transaction as permitted by applicable law and/or contract. We will notify you of any such Transactions and outline your choices pertaining thereto upon the occurrence thereof. For the avoidance of doubt, we reserve the right to effect any such Transactions in our absolute discretion. 

  • With Academic Researchers or for Public Interest Reports (Anonymized/Aggregated Data):

    • We may share data that has been anonymized (all personal identifiers removed) and/or aggregated (combined with other data so no individual can be identified) with academic researchers for studies that benefit the esports community, or for public interest reports on trends within the Platform.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies (such as web beacons, pixels, SDKs in our mobile apps, and local storage) to operate and improve our Platform, understand how you use it, remember your preferences, personalize your experience (including ads), and for security purposes. These technologies may collect information such as your IP address, browser type, operating system, referring URLs, device information, pages visited, and time spent on pages.

Our Cookie Policy provides detailed information on the types of cookies and technologies we use (e.g., essential, performance, functional, advertising), why we use them, the third parties who may set them, and how you can manage your preferences (including your consent choices for non-essential cookies and how to opt-out of certain tracking).

We also note that our Platform does not currently change its practices when it receives "Do Not Track" (“DNT”) signals from web browsers, as there is no industry-standard approach to DNT. However, you can manage your tracking preferences through our cookie consent tools and your browser/device settings.

9. Data Retention

We will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Privacy Policy, and as required by applicable laws and regulations. The criteria used to determine our retention periods include:

  • Account Activity: We keep your core account information as long as your account is active on our Platform. If you delete your account, your personal information will be deleted or anonymized in accordance with our applicable policies and standard operating procedures (typically within thirty (30) days of request processing), subject to certain exceptions outlined below.

  • Legal and Regulatory Requirements: We may retain certain information for longer periods if required by applicable law (e.g. KYC data for AML purposes (generally five (5) years from the date of collection or last transaction, financial transaction records for tax/audit purposes (generally for a period of five (5) - seven (7) years). We will inform you if such requirements prevent immediate deletion of your personal information as soon as reasonably practicable and in compliance with applicable laws.

  • Specific Features:

    • Chat messages are retained on active servers for up to ninety (90) days for delivery and access, which may be subsequently securely archived or deleted.

    • Anti-cheat data is retained for up to one hundred eighty (180) days, unless required longer for an ongoing investigation into a cheating allegation.

    • UGC is retained for as long as it is live on the Platform or until deleted by you or upon account deletion (subject to backup cycles and potential retention of moderation history for compliance as may be applicable from time to time and determined by us acting in our absolute discretion).

  • Dispute Resolution & Enforcement: We may retain information for the duration necessary to resolve disputes, enforce our agreements, or for security and fraud prevention purposes.

  • Anonymized Data: Data that has been appropriately anonymized (so it no longer identifies you) may be kept for longer periods for analytics, research, and platform improvement. We are committed to employing appropriate techniques for anonymization or pseudonymization when retaining data for such longer-term purposes.

10. Data Security

We are committed to protecting the security of your personal information. We implement and maintain reasonable administrative, technical, and physical security measures designed to protect your data from unauthorized access, use, alteration, disclosure, or destruction. These measures include:

  • Encryption: Encryption of data in transit (e.g., using TLS/SSL) and at rest for our databases.

  • Access Controls and Authentication: Access controls and authentication mechanisms to limit access to personal information to authorized personnel who need it for their job responsibilities.

  • Assessments, Testing and Management: Regular security assessments, penetration testing, and vulnerability management.

  • Secure Development and Code Reviews: Secure software development practices and code reviews.

  • Internal Training: Staff training on data protection, security best practices, and incident response.

  • Backup and Recovery: Data backup and recovery procedures.

Notwithstanding the above, please be aware that no security system is impenetrable, and we cannot guarantee the absolute security of your information. You also play an important role in keeping your information secure. This includes choosing a strong, unique password for your Groov account, keeping it confidential, not reusing it on other services, and logging out of your account when using shared or public devices. Please notify us immediately if you suspect any unauthorized access to your account or any other security breach.

In the event of a data breach that is likely to result in a high risk to your personal, rights, entitlements, safety and security, we will take necessary steps to notify you and the relevant data protection authorities (such as the UAE Data Office and applicable European Economic Area (“EEA”) DPAs) as required by applicable laws, typically within specified timeframes (e.g. within seventy-two (72) hours as prescribed under the GDPR where reasonably practicable, and as per PDPL requirements (being without undue delay)).

11. International Data Transfers

Groov is incorporated and headquartered in the UAE. Your personal information will be primarily processed and stored on servers located in the UAE and may be from time to time processes and stores in other countries and regions where our trusted service providers operate infrastructure.

To provide our global Platform and services, we may use third-party service providers (e.g. for cloud hosting, analytics, customer support, payment processing) that are located in countries other than the UAE, including but not limited to countries located in the EEA. This means your personal information may be transferred to and processed in these countries, which may have different data protection laws and regulation than your country of residence.

When we transfer your personal information to such countries, we take steps to ensure that your data is protected to a standard comparable to that prescribed under the PDPL and GDPR. These safeguards include:

  • Ensuring the recipient country is deemed to provide an "adequate" level of data protection by the relevant authorities (e.g. European Commission adequacy decisions, or the UAE's list of adequate countries under PDPL).

  • Implementing Standard Contractual Clauses (“SCCs”) approved by the European Commission (for transfers of data from the EEA), or similar contractual clauses that provide appropriate data protection safeguards as recognized under PDPL.

  • Implementing robust DPAs with our third-party service providers that contractually require them to protect your information and process it only in accordance with our instructions and applicable laws.

  • Complying with any specific cross-border transfer requirements under the PDPL.

By using our Platform and providing us with your information, you consent to the transfer of your personal information to countries outside your country of residence, including the UAE, as prescribed in this Privacy Policy and subject to the safeguards set out in this Paragraph 11 above.

12. Your Data Protection Rights

Depending on your location and applicable data protection laws (e.g. the PDPL if you are in the UAE or your data is being processed by us in the UAE, and GDPR if you are in the EEA or your data is processed in the context of our EEA-targeted activities), you have certain rights regarding your personal information. We are committed to facilitating these rights at all times. Accordingly, you have the following rights regarding your personal information:

  • The Right to Access: You can request access to a copy of the personal information we hold about you.

  • The Right to Rectification: You can request that we correct any inaccurate or incomplete personal information. You can often update some of your information directly via your account settings on our Platform.

  • The Right to Erasure (or "Right to be Forgotten"): You can request that we delete your personal information under certain conditions (e.g. if it's no longer necessary for the purposes for which it was collected, if you withdraw consent where consent was the basis for processing, or if your data has been unlawfully processed).

  • The Right to Restrict Processing: You can request that we limit the way we use your personal information under certain circumstances (e.g. if you contest the accuracy of the data while we verify it, or if you have objected to processing pending verification of legitimate grounds).

  • The Right to Data Portability: Where our processing is based on your consent or the performance of a contract with you, and is carried out by automated means, you can request to receive your personal information in a structured, commonly used, and machine-readable format (such as CSV or JSON), and have the right to transmit that data to another controller without hindrance, refusal or obstruction from us.

  • The Right to Object: You can object to our processing of your personal information where we are relying on legitimate interests as our legal basis, or at any time to processing for direct marketing purposes (including profiling related to direct marketing).

  • The Right to Withdraw Consent: If we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. This will not affect the lawfulness of any processing carried out before you withdrew your consent.

  • Rights Related to Automated Decision-Making and Profiling: You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you, except under certain conditions (e.g. where it's necessary for entering into or performing a contract, is authorized by applicable law, or based on your explicit consent). If we engage in such processing (e.g. for automated fraud detection that might lead to account suspension, or advanced automated content moderation with significant impact), we will provide you with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you, and ensure you can obtain human intervention, express your point of view, and contest the decision.

  • Right to Lodge a Complaint: If you have any concerns about our use of your personal information, you can lodge a complaint with the relevant supervisory authority. If you are in the UAE and believe that your rights under the PDPL have been infringed, you have the right to lodge a complaint with the UAE Data Office (“UAEDO”). Contact details for the UAEDO can typically be found on their official government website. We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority, so please contact us in the first instance.

  • Right to Non-Discrimination: You have the right to not be discriminated against for exercising your rights under either the GDPR, UK DPA, PDPA, CCPA or any other applicable laws as the case may be.

13. Exercising Your Rights

You can exercise these rights by contacting us via email at privacy@Groov.gg or through specific tools provided in your account settings where available (e.g. for updating profile information or managing communication preferences). When you make a request, we may ask for additional information to verify your identity and prevent fraudulent requests before processing your request. We will acknowledge receipt of your request promptly and will respond substantively within the timeframe required by applicable laws (typically within one (1) month, which may be extended by two (2) further months where necessary for complex or numerous requests, in which case we will inform you of any such extension and the reasons for the delay).

Exercising your rights is generally free of charge. However, as permitted by applicable law, we may charge a reasonable fee or refuse to act on a request if it is manifestly unfounded, excessive, or repetitive.

14. Children's Privacy

Our Platform is not directed to individuals under the age of sixteen (16). Our age verification process at registration is designed to prevent individuals under sixteen (16) years from creating an Account. We do not knowingly collect personal information from children under sixteen (16).

If Groov becomes aware that we have inadvertently collected personal information from a minor under sixteen (16) without verification of parental consent (where such consent might be applicable under specific local laws despite our 16+ policy), we will take steps to delete such information as soon as reasonably practicable. If you are a parent or guardian and believe your child under sixteen (16) has provided us with personal information without your consent, please contact us immediately via email at privacy@Groov.gg so we can take appropriate action. 

15. Third-Party Links and Services

Our Platform may contain links to third-party websites, services, or applications that are not operated by Groov (e.g. links shared by users in chats or profiles, links to game developer sites, or payment processor sites). If you click on a third-party link, you will be directed to that third party's site or service.

This Privacy Policy does not apply to the practices of these third parties, and we encourage you to review their privacy policies before providing them with any personal information. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

16. Amendments to This Privacy Policy

We may update, amend and otherwise replace this Privacy Policy from time to time to reflect changes in our data practices, legal or regulatory requirements, or service offerings. If we make material changes to this Privacy Policy, we will provide you with reasonable prior notice (e.g. at least thirty (30) days where feasible, or as required by law) by posting a prominent notice on our Platform, sending an email to the address associated with your account, or through other appropriate communication channels. The notice will explain the changes and when they will become effective. The "Last Updated" date at the top of this Privacy Policy will always indicate when it was last revised.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of the Platform after any changes to this Privacy Policy become effective will constitute your acknowledgment and acceptance of the revised Policy. We may also keep prior versions of this Privacy Policy archived; you can request access to these by contacting us.

17. Identity And Contact Details of the Primary Data Controller 

If you have any questions, comments, or concerns about this Privacy Policy, our data practices, or if you wish to exercise your data protection rights, please contact us. We aim to respond to privacy-related inquiries within a reasonable timeframe.

Company Name: Groov Esports Platform LLC

UAE Licence No.: 1364388

Registered Office Address: 128-246, Al Khabeesi Building, Al Khabeesi, Dubai, United Arab Emirates 

Phone Number: +971-554096767

Email: privacy@groov.gg

Data Protection Officer (DPO): We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. You can contact our DPO at dpo@Groov.gg (or the same privacy@groov.gg address)

18. Identity And Contact Details of the Data Protection Officer (DPO)

We have appointed a Data Protection Officer (“DPO”) who is responsible for addressing any questions or concerns about this Privacy Policy or about any collection, use, storage or disclosure of personal information by us. Please contact our DPO at:

DPO Name: Abhishek Agrawal

Email: abhishek@groov.gg

Phone Number: +971-554096767