Privacy Policy

1. Data Controller

The data controller responsible for your personal information is:

AnotherTurnTonight Inc.
200 Bay Street, Suite 1800
Toronto, Ontario M5J 2J1
Canada

Email: [email protected]
Phone: +1 (416) 555-0192

AnotherTurnTonight Inc. is a corporation incorporated under the laws of the Province of Ontario and is subject to Canadian federal and provincial privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA).

2. Information We Collect

We collect personal information from you in several ways depending on how you interact with our Services. The categories of information we may collect include:

Account Information

• Name, username, and display name
• Email address and password (stored in hashed form)
• Date of birth (used for age verification)
• Profile photo or avatar you upload
• Country and province/territory of residence
• Team affiliations and player rank data

Usage Data

• Pages viewed, features used, and time spent on the platform
• Tournament registrations, match histories, and bracket interactions
• Stream viewing activity including titles watched and duration
• Search queries entered on our platform
• Referral source (e.g., social media link, search engine)
• Device information: browser type, operating system, screen resolution, IP address
• Log data including access timestamps, error reports, and click paths

Payment Data

• Billing name and billing address
• Payment method details (processed and tokenized by our third-party payment processors; we do not store raw card numbers)
• Transaction history and order records
• Interac e-Transfer or PayPal account identifiers where applicable

Cookies and Tracking Technologies

We use cookies, web beacons, and similar tracking technologies to recognize your browser, maintain session state, measure traffic, and personalize content. Please see our Cookie Policy for full details on the specific cookies we deploy and how to manage your preferences.

Communications

• Messages sent to our support team via email or contact forms
• Newsletter subscription records and email engagement data
• Discord or social media interactions related to our official channels

3. How We Use Your Information

We use the personal information we collect for the following purposes, each supported by a legitimate basis under PIPEDA:

• Service Delivery: Creating and managing your account, processing tournament registrations, fulfilling shop orders, and providing customer support.
• Platform Improvement: Analyzing aggregated usage data to improve features, fix bugs, and optimize the user experience across all games and services.
• Communications: Sending transactional emails (order confirmations, tournament reminders, password resets) and, where you have opted in, marketing emails including our weekly newsletter.
• Personalization: Tailoring content recommendations, stream suggestions, and shop promotions based on your activity and preferences.
• Security and Fraud Prevention: Monitoring for suspicious activity, enforcing our Terms of Service, and protecting the integrity of competitive tournaments.
• Legal Compliance: Meeting our obligations under Canadian law, including tax record-keeping, responding to lawful government requests, and enforcing our agreements.
• Analytics and Research: Understanding how our community uses the platform to guide product strategy and content decisions.

We will not use your personal information for purposes incompatible with the above without obtaining your fresh consent.

4. Third-Party Sharing

We do not sell your personal information. We may share your information with third parties only in the following circumstances:

• Service Providers: We engage trusted vendors to help us deliver our Services, including payment processors (Stripe, PayPal), cloud hosting providers (AWS Canada regions), email delivery services (SendGrid), and analytics providers (Google Analytics, Plausible). These vendors are contractually bound to process your data only for the purposes we specify and to maintain appropriate security standards.
• Tournament Partners: When you participate in co-hosted or sponsored tournaments, limited profile data (username, rank, team name) may be shared with the relevant tournament co-organizer for bracket and results management purposes.
• Legal Requirements: We may disclose your information if required by law, court order, or other legal process, or where we believe disclosure is necessary to protect the rights, property, or safety of AnotherTurnTonight, our users, or the public.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of our assets, personal information may be transferred to the acquiring entity, subject to equivalent privacy protections.
• With Your Consent: We will share your information with third parties not listed above only with your explicit consent.

Any third parties we engage are required to safeguard your data to at least the standard set out in this policy and applicable Canadian law.

5. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our general retention periods are:

• Account Data: Retained for the duration of your active account plus 2 years after account deletion, to allow for dispute resolution and fraud investigations.
• Transaction Records: Retained for 7 years in accordance with the Canada Revenue Agency's requirements for financial record-keeping.
• Usage and Log Data: Typically retained for 13 months in aggregated or pseudonymized form, then deleted or further anonymized.
• Marketing Data: Email subscription records are retained until you unsubscribe; engagement data is retained for up to 3 years.
• Support Communications: Retained for 3 years after resolution of the relevant support ticket.

When retention periods expire, data is securely deleted or irreversibly anonymized. You may request earlier deletion as described in Section 7 below.

6. PIPEDA Compliance

AnotherTurnTonight Inc. is subject to Canada's Personal Information Protection and Electronic Documents Act (PIPEDA, S.C. 2000, c. 5) and its associated regulations. We are also aware of and take steps to comply with applicable provincial privacy legislation, including Ontario's Freedom of Information and Protection of Privacy Act (FIPPA) where relevant.

Our privacy practices are guided by the ten fair information principles set out in Schedule 1 of PIPEDA:

• Accountability: We have designated a Privacy Officer responsible for overseeing compliance with this policy and applicable law.
• Identifying Purposes: We identify and document the purpose for which personal information is collected before or at the time of collection.
• Consent: We obtain meaningful consent for the collection, use, and disclosure of personal information, and we respect your right to withdraw consent.
• Limiting Collection: We collect only the information necessary to fulfill the identified purposes.
• Limiting Use, Disclosure, and Retention: We use and disclose information only for the purposes for which it was collected, and we retain it only as long as necessary.
• Accuracy: We keep personal information as accurate, complete, and up-to-date as necessary for the purposes for which it is used.
• Safeguards: We protect personal information with security safeguards appropriate to the sensitivity of the information.
• Openness: We make information about our privacy policies and practices readily available.
• Individual Access: We respond to requests from individuals for access to their personal information within 30 days.
• Challenging Compliance: We have a process for receiving and responding to privacy complaints and inquiries.

If you believe we have not complied with PIPEDA, you have the right to complain to the Office of the Privacy Commissioner of Canada at www.priv.gc.ca or by phone at 1-800-282-1376.

7. Your Rights

As a user of our Services, and as a resident of Canada, you have the following rights with respect to your personal information:

• Right of Access: You have the right to request a copy of the personal information we hold about you, including the purposes for which it is used and the third parties to whom it has been disclosed.
• Right of Correction: If any personal information we hold about you is inaccurate, incomplete, or out of date, you have the right to request that it be corrected or amended.
• Right of Deletion: You may request that we delete your personal information. We will comply unless retention is required by law or necessary for us to defend a legal claim.
• Right to Withdraw Consent: Where our processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent may affect your ability to use certain features of our Services.
• Right to Unsubscribe: You may opt out of marketing communications at any time by using the unsubscribe link in any marketing email or by contacting us directly.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada if you are not satisfied with our response to a privacy request.

To exercise any of these rights, please contact our Privacy Officer using the contact details in Section 11. We will acknowledge your request within 5 business days and respond substantively within 30 days. Where requests are particularly complex, we may extend this period by a further 30 days with notice to you.

We may ask you to verify your identity before fulfilling a request, to ensure we do not disclose personal information to unauthorized parties.

8. Security

We take the security of your personal information seriously and implement a range of technical and organizational safeguards, including:

• Encryption of data in transit using TLS 1.2 or higher
• Encryption of sensitive data at rest using AES-256
• Hashed and salted password storage (bcrypt)
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Regular security audits and penetration testing
• Two-factor authentication options for user accounts

Despite these measures, no method of transmission or storage is 100% secure. If we become aware of a security breach affecting your personal information, we will notify you and the Office of the Privacy Commissioner of Canada in accordance with PIPEDA's mandatory breach reporting requirements.

9. Children's Privacy

Our Services are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us immediately at [email protected] and we will take steps to delete the information promptly.

Users between the ages of 13 and 18 must have parental or guardian consent to use our full Services, including tournament registration and shop purchases.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will notify you by posting the updated policy on this page with a revised "Last Updated" date, and where appropriate, by sending an email notification to registered users.

We encourage you to review this policy periodically. Your continued use of our Services after the posting of changes constitutes your acceptance of the updated policy.

11. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact our Privacy Officer:

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada at 30 Victoria Street, Gatineau, Quebec K1A 1H3, or visit www.priv.gc.ca.