PRIVACY & COOKIE POLICY

    1. Introduction

    2. We are committed to safeguarding the privacy of our website visitors and service users.
    3. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
    4. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
    5. In this policy, "we", "us" and "our" refer to Insider Analytics GmbH, In der Beichlen 6, 8618 Oetwil am See, Switzerland, Registration CHE-440.740.832, which operates and owns https://rl.insider.gg and its services. We can be contacted at the above address, via e-mail at [email protected] or through our Discord community at https://rl.insider.gg/discord.
    1. How we use your personal data

    2. In this Section 2 we have set out:
      1. the general categories of personal data that we may process;
      2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
      3. the purposes for which we may process personal data; and
      4. the legal bases of the processing.
    3. We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
    4. We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent.
    5. We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
    6. ‌We may process information that was posted for publication by third parties on our website or through our services, in particular security services to prevent future fraud and scams in trading communities associated with our website and services ("report data"). The report data may include IDs and usernames in trading communities (including but not limited to Steam user ID64, Sony Playstation Network usernames, and Discord IDs), as well as recorded conversations and trades with the third party providing the report data, and otherwise relevant trading activity in the form of images, video, or other media. The source of the report data is the report publisher. The report data may be processed for the purpose of enabling such publication and administering our website and services. The report data may further be processed where necessary for the establishment, exercise of defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this data collection and processing is the public interest in the availability of the data, as well as our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
    7. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
    8. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
    9. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
    10. Please do not supply any other person's personal data to us, unless we prompt you to do so.
    1. Providing your personal data to others

    2. We may disclose your personal data to any organisation officially associated with our security services. You can find the complete list of our associated organisations in our Discord community at https://rl.insider.gg/discord.
    3. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others. ‌
    4. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
    5. Financial transactions relating to our website and services may be handled by our payment services providers, namely www.PayPal.com. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://www.paypal.com/en/webapps/mpp/ua/privacy-full.
    6. In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
    1. Retaining and deleting personal data

    2. This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
    3. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
    4. We will retain your personal data as follows:
      1. Usage data according to 2.2 will be retained for a minimum period of 36 months, and for a maximum period of 60 months following the collection of the data.
    5. In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
      1. the period of retention of correspondance data will be determined based on the necessity for its purpose; and
      2. the period of retention of report data will be determined based on the public interest in its availability, as well as the necessity for its purpose which may include the establishment, exercise or defence of a legal claim.
    6. Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
    1. Amendments

    2. We may update this policy from time to time by publishing a new version on our website.
    3. You should check this page occasionally to ensure you are happy with any changes to this policy.
    4. We may notify you of significant changes to this policy by means of public service announcements on the website as well as through the according channels in our Discord community at https://rl.insider.gg/discord.
    1. Your rights

    2. In this Section 6, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
    3. Your principal rights under data protection law are:
      1. the right to access;
      2. the right to rectification;
      3. the right to erasure;
      4. the right to restrict processing;
      5. the right to object to processing;
      6. the right to data portability;
      7. the right to complain to a supervisory authority; and
      8. the right to withdraw consent.
    4. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
    5. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
    6. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
    7. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
    8. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
    9. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
    10. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
    11. To the extent that the legal basis for our processing of your personal data is:
      1. consent; or
      2. that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
      and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
    12. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
    13. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
    14. You may exercise any of your rights in relation to your personal data by notice to us in our official Discord community at https://rl.insider.gg/discord, in addition to the other methods specified in this Section 6.
    1. About cookies

    2. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
    3. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
    4. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
    1. Cookies that we use

    2. We use cookies for the following purposes:
      1. personalisation - we use cookies to store information about your preferences and to personalise the website for you.
        This may include your preferred platform (Steam, PSN, Xbox) and how you want to sort our price tables;
      2. analysis - we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: Google Analytics); and
      3. advertising - we use cookies to help us to display advertisements that will be relevant to you (cookies used for this purpose are: infolinks);
      4. cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.
    1. Cookies used by our service providers

    2. We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.
    3. We use services by Infolinks Media and GG Software to provide our users with personlized ads.
      Infolinks's privacy policy is available at: https://www.infolinks.com/privacy-policy/.
      GG Software's privacy policy is available at: https://nitropay.com/privacy
    1. Managing cookies

    2. You can chose not to receive personalized ads at any time, right from this page.
      Click here if you don't wish any personalized ads.
    3. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
      1. https://support.google.com/chrome/answer/95647?hl=en (Chrome);
      2. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
      3. http://www.opera.com/help/tutorials/security/cookies/ (Opera);
      4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
      5. https://support.apple.com/kb/PH21411 (Safari); and
      6. https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
    4. Blocking all cookies will have a negative impact upon the usability of many websites.
    5. If you block cookies, you will not be able to use all the features on our website.
    1. Contact details

    2. You can contact us:
      1. by email, using the email address published on our website from time to time; or
      2. in our Discord community at https://rl.insider.gg/discord.

For California Residents: CCPA Information

This Privacy Notice for California Residents supplements the information contained elsewhere in this Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Rights and Choices

The CCPA provides consumers located in the state of California with certain rights regarding their personal information and data. The following section describes those rights and explains how to exercise them:

Access to Specific Information and Data Portability Rights

You have the right to request that the company disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (as described in the section “Exercising Access, Data Portability, and Deletion Rights”), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called data portability request)
  • If we sold or disclose your personal information for a business purpose, two separate lists disclosing:
    • Sales, identifying the personal information categories that each category of recipient purchased, and
    • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained

Non-Discrimintation

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.

Any CCPA-permitted financial incentive we offer will reasonably relate to your value and contain written terms that describe the program’s material aspects.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at [email protected]

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access of data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Information We Collect

Our websites, emails (with your consent, where required by law), and other products, services and platforms collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our websites, apps, emails, and other products, services and platforms may have collected the following categories of personal information from its consumers within the last twelve (12) months:

Category Collected
A. Identifiers YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) YES
C. Protected classification characteristics under California or federal law NO
D. Commercial information. YES
E. Biometric information. NO
F. Internet or other similar network activity. YES
G. Geolocation data. YES
H. Sensory data. NO
I. Professional or employment-related information. NO
J. Inferences drawn from other personal information. YES

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a newsletter or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we or our third-party service providers will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product or service orders and requests.
  • To provide, support, personalize, and develop our websites, emails, and other products, services and platforms.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our responses.
  • To personalize your website, apps, emails, or other product, service or platform experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, apps, emails, and other products, services and platforms.
  • To help maintain the safety, security, and integrity of our websites, apps, emails, and other products, services and platforms, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our websites, apps, emails, and other products, services and platforms.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.

The Company will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

The Company may disclose your personal information to a third-party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see ‘Sales of Personal Information’ below). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales (see ‘Sales of Personal Information’ below).

We may share your personal information with the following categories of third parties:

  • Subsidiaries and affiliates.
  • Contractors and service providers.
  • Data aggregators.
  • Third parties with whom we partner to offer products and services to you.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose:

  • [Category A: Identifiers.]
  • [Category B: California Customer Records personal information categories.]
  • [Category F: Internet or other similar network activity.]
  • [Category G: Geolocation Data.]
  • [Category K: Inferences drawn from other personal information.]

Sales of Personal Information

In the preceding twelve (12) months, the company has sold the following categories of personal information collected through our ad-supported services:

  • [Category A: Identifiers.]
  • [Category F: Internet or other similar network activity.]
  • [Category G: Geolocation Data.]
  • [Category K: Inferences drawn from other personal information.]

The company and our advertising partners collect the personal information identified above (such as the cookies stored on your browser, the advertising identifier on your mobile device, or the IP address of your device) when you visit our websites, apps, and other products, services and platforms, or open our emails. We, and our partners, use this information to tailor and deliver ads to you on our websites, apps, emails, and other products, services and platforms, or to help tailor ads to you when you visit others’ sites (or use others’ apps). To tailor ads that may be more relevant to you, we and/or our partners may share the information we collect with third parties.