Privacy Policy

Privacy Policy

Last modified: 03 June, 2020

  1. Your Privacy Rights

    1. This Privacy Policy (“Policy”) describes Your privacy rights regarding Bountie’s collection, use, storage, sharing, and protection of Your personal data.

      All definitions specified in the Terms of Use shall also apply to this Policy. The terms of this Policy may occasionally be updated, therefore, You shall read this Policy periodically. Any amendments to this Policy will be published on this Site and, where appropriate, notified to You in writing. Significant changes to this Policy will always be sent to You via e-mail.

    2. In this Privacy Policy, “we”, “us”, “our”, and the “Company” means Bountie Holdings Pte. Ltd. (UEN: 201910013Z), as well as its affiliates on its behalf, including Bountie Esports Arena Pte. Ltd. (UEN: 201822010N) (collectively, “Bountie”). This Privacy Policy works hand-in-hand with the Terms of Service, which can be found at,

    3. This Privacy Policy applies to the website (hereafter the “Site”) and governs data collection, processing, and usage in compliance with the Personal Data Protection Act (Act 26 of 2012) of Singapore (“PDPA”). Our Privacy Policy is designed to help you understand how we collect, use and safeguard the information you provide to us and to assist you in making informed decisions when using our Site.

    4. This Privacy Policy applies to all “users” of the Site. This includes unregistered visitors as well as users who have registered and maintain an account on the Site. This Policy does not cover the Privacy Policies of other web sites, nor any information collected through any other website operated by third parties. Each of these web sites may have a Privacy Policy that differs from ours and we urge users to check the Privacy Policies of each website that they may visit or interact with.

    5. By accessing our Site or our Service, you accept our Privacy Policy and Terms of Service, and you consent to our collection, storage, use, and disclosure of your Personal Information as described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not participate in the Site or any of the activities or Services offered through the Site.

    6. This Privacy Policy will remain in full force and effect with respect to your Personal Information which we retain for a limited period of time after your use or participation in the Site or any particular Service, tournaments or game offered through the Site terminates or ceases, or is suspended or deactivated for any reason.

  2. Collection of Information

    1. Types of Information

      We collect two types of information from you when you visit the Site: non personally identifiable information (hereafter “Non-Personal Information”); and personally identifiable information (hereafter “Personal Information”).

      1. Non-Personal Information

        Certain technical information related to your visit to the Site may be automatically recorded. This information is anonymous and does not identify you personally. Non-Personal Information includes, but is not limited to: the Internet domain for your Internet service provider; the Internet Protocol (IP) address of the computer accessing the Site; the address of the last webpage that you visited prior to clicking through to the Site; the browser used and the type of computer operating system that your computer is using; information about your computer hardware; the date and time that you visited the Site; and a record of which pages you viewed while you were visiting the Site. Other information such as demographic information, which does not identify an individual, is also considered Non-Personal Information. Gaming Information (described below) is also considered Non-Personal Information.

      2. Personal Information

        Personal Information includes your email, date of birth, first and last name, and current country, which you submit to us through the registration process at the Site. When you register for a free user account (a “Free Account”), you consent to our collection of Personal Information, including your email address, for the purpose of validating your address, and in order to market upcoming game tournaments and email reminders and promotions regarding the activity on the platform.

      3. We collect Personal Information through our Site through the following ways:

      4. Completion of the initial user sign-up (the “Sign Up”), required for you to create a free, basic user account (a "Basic Account"):

        • Your email address for the purpose of verifying your identity, logging in the user, sending marketing notifications of upcoming tournaments to you, and emailing game results to you;

        • Your date of birth, for the purpose of ensuring that you are permitted to create an account within our age restrictions;

        • Where you currently reside, for the purpose of ensuring that you are permitted to create an account based upon your jurisdiction; (Collectively, the "Basic Information")

      5. Process a payment from you, for the purpose of allowing you to enter pay-to-enter tournaments, in addition to the Basic Information:

        • Your first name and last name;

        • The following information with respect to your credit card: type, number, expiration month, expiration year and card verification number;

        • The following billing information: your street address, city, postal or zip code, province or state and country.

      6. Process a refund:

        • Your PayPal email address;

        • Your first name and last name; and

        • Your full address including, city, postal or zip code, province or state and country.

      7. Editing a user profile, for the purpose of updating your contact information, your "site information", your password, and your communication preferences:

        • Your first name, last name, individual's street address, city, postal or zip code, province or state and country;

        • Your time zone;

        • Your avatar; and your in-game IDs and any other of your platform names for platforms supported on the Site (ex. Steam), in order for us to track your game results and to participate in tournaments;

        • Your old and new password; and

        • Your communication preferences.

      8. Tournaments;

        • Your PUBG ID, PlayStation Network ID, XBOX Live Gamertag, and any other of your platform names for platforms supported on the Site, in order to participate in tournaments, and for us to track your game results.

      The Site will also provide you with certain ways to voluntarily give us your Personal Information. We may collect Personal Information about you if you choose to send us an email message, which contains such information through using links contained on the Site. You may also disclose Personal Information when you post content with such Personal Information on the Site or when you contact our Customer Support representatives via live chat or email. Certain information about your activity on the Site is not itself Personal Information (for example, information about your game play preferences) but may be linked to your account information. For example, the following information (“Gaming Information”) is publicly displayed on the Site and, provided it doesn’t identify you personally, shall not be considered Personal Information:

      • your Username or Alias;

      • your Skill Ratings

      • your friends on Bountie;

      • your ranking (if any);

      • your scores in games and tournaments;

      • your User Profile and statistics;

      • your gaming preferences or your personal motto;

      • summary of your gaming activity on the Site;

      • summary of your gaming activity outside the Site;

      • winnings from games and tournaments; and

      • any personal information you chose to disclose in a chat window.

      You can register to join Bountie via the Site or by logging into your account with certain third-party social networking sites (“SNS”) (e.g., Facebook) via our Site. If you decide to create your Account by logging into a SNS via the Site, we will extract the Personal Information you have provided to the SNS (such as your “real” name, email address and other information you make publicly available via the SNS) from the account you have with such SNS and use that information to create your Account; the information we extract may depend on the privacy settings you have with the SNS.

      If you are not currently registered as a Member and you click on “Register with Facebook”, you will first be asked to enter your Facebook credentials and then be given the option to register with Bountie. By using Facebook Connect, you are allowing Bountie to access your Facebook account information for the purpose of completing your registration, and you are agreeing to the Facebook Terms of Use regarding your use of the Service via Facebook.

      Similarly, if you are not currently registered as a Member and you click on “Register with Google”, you will first be asked to enter your Google credentials and then be given the option to register with Bountie. By signing in with Google, you are allowing Bountie to access your Google account information for the purpose of completing your registration, and you are agreeing to the Google Terms of Use regarding your use of the Service via Google.

      In order to provide a fair playing environment for all users and to protect the integrity of the Site, we also collect Personal Information which we can use to investigate complaints of cheating or behavior that we believe may be contrary to the Terms of Service, including the Rules of Conduct. This may include screenshots of players' computer desktops or footage of in-game play.

      In addition to the collection of Personal Information directly from visitors to the Site, we may also collect Personal Information from third parties such as marketing partners to which permission has been granted to share that information with us.

      When you download any Bountie widget or a Bountie application, you may also be provided with the opportunity to download software provided by parties other than Bountie. Please note that when you install and use software provided by third parties, any information that you provide through such use (including Personal Information) will be subject to the privacy policy of that software provider, and not this Privacy Policy.

    2. What Are “Cookies” and how does the Site use them?

      A cookie is a small text file containing a unique identification number that is transferred (through your browser) from a website to the hard drive of your computer. The cookie identifies your browser but will not let a website know any Personal Information about you, such as your name or address. These files are then used by such websites as a kind of electronic identification tag when users revisit that site. Since cookies are only text files, they cannot run on your computer, search your computer for other information, or transmit any information to anyone.

      As with many major websites, the Site uses cookies. Cookies are used by the Site so that we can recognize you when you return to the Site and personalize your settings and preferences. Most browsers are initially set up to accept cookies. If you wish, you can change your browser settings either to notify you when you have received a cookie, or to refuse to accept cookies. This Privacy Policy only covers the use of Cookies by Bountie. It does not cover the use of Cookies by any other 3rd-party or advertisers.

    3. Personal Information about Children

      Our Site is intended for a general audience and we do not knowingly (a) allow people under 14 years of age to create accounts on the Site and (b) collect Personal Information from people under 14 years of age through our Site. In addition, in the event that a visitor to our Site identifies himself or herself as a person under the age of 14, we will not collect, store or use any Personal Information of such individual. In the event that we receive Personal Information that we discover was provided by a person under the age of 14, we will promptly delete such Personal Information not required for the purpose of continuing to block such person's use of the Site, and will comply with applicable laws, including, as applicable, the Children's Online Privacy Protection Act ("COPPA") in Singapore.

    4. We Collect Device Information Using the Following Technologies:

      1. "Cookies" are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit

      2. "Log files" track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

      3. "Web beacons", "tags," and "pixels" are electronic files used to record information about how you browse the Site.

      4. When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as "Device Information."

      5. Additionally, when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. We refer to this information as "Order Information".

      6. When we refer to "Personal Information" in this Privacy Policy, we are referring to both Device Information and Order Information.

  3. Use and Disclosure of Personal Information

    We use and disclose your information for the following purposes:

    1. Internal Uses

      We collect, use and disclose your Personal Information for such purposes to which you consent at the time of collection or in any case prior to such use, and as otherwise permitted or required by applicable law, including:

      • To operate our Site; to open and maintain your customer account with us, to edit your profile; and for the purpose of tournaments, in each case as more particularly described above;

      • To provide a product or service requested by you;

      • To contact you regarding updates to the Site, your account status, our new products and services and upcoming events, changes to our products and services;

      • To collect entry fees from you and to process payments and refunds;

      • For promotional or related purposes without additional compensation, including with respect to tournaments and the awarding of prizes;

      • To prevent fraud and protect the integrity of the Site;

      • To deliver prizes to you; and

      • To ensure that you comply with the Terms of Service (including in order to facilitate a fair gameplay environment) and are permitted to create an account based upon your age and where you reside.

      • To, in our discretion, use Personal Information to contact you regarding changes to the Terms of Service and any other policies or agreements relevant to the Site, including this Privacy Policy.

      When you create your account and when we collect your Personal Information, you can customize these preferences. If you wish to change your account preferences to modify the ways that we contact you, please contact [email protected] or, in the case where we use your Personal Information to communicate with you via email, use the "unsubscribe" link included in all email messages sent on our behalf.

    2. Related Entities and Authorized Third-Party Service Providers

      In addition to sharing information between affiliated, subsidiary, and/or related entities of Bountie for the Purposes, and in order to better serve our customers, we may transfer Personal Information to third-party service providers who are legally or contractually obligated to only use the information to help us provide our Services and not for any other purpose. For example, Bountie uses outside contractors for the purposes of (i) performing support functions, such as payment processing, business analytics, customer support, printing and mailing, data storage and destruction, and (ii) marketing any of Bountie's products and services.

      From time to time such entities and third parties may hold, use or disclose your Personal Information outside of Singapore, and while outside of Singapore such Personal Information may be accessed by regulatory authorities pursuant to the laws of such other jurisdictions.

    3. Co-Branded Partners

      Co-Branded Partners are third parties with whom Bountie may jointly offer a Service or feature, such as a tournament. You can tell when you are accessing a Service offered by a Co-Branded Partner because the Co-Branded Partner's name will be featured prominently. You may be asked to provide information about yourself to register for a Service offered by a Co-Branded Partner. In doing so, you may be providing your Personal Information to both us and the Co-Branded Partner, or, with your consent, we may share your Personal Information with the Co-Branded Partner. Please note that the Co-Branded Partner's privacy policy may apply to its use of your Personal Information.

    4. Marketing Partners

      To the extent that you consent, we may also disclose Personal Information you provide us to third party marketing partners who provide products, information or services you have expressly requested or which we believe you may be interested in purchasing or obtaining, in order that they may provide you with information regarding such products, information or services. In doing so, we will make reasonable efforts to ensure that these third parties only use the Personal Information for our stated Purposes and that they provide a method of opting out from receiving future communications from such parties, but we shall not otherwise be responsible for their handling or dissemination practices with respect to Personal Information. If you subsequently wish to change your account preferences to not receive information from such third party marketing partners, please contact [email protected] or use the "unsubscribe" link included in email messages sent by such parties.

    5. Legal Compliance

      There may be instances when Bountie may disclose Personal Information without providing notice or choice, as required or permitted by applicable laws, which may include (i) when required pursuant to a subpoena, other form of legal process or request on behalf of any local, provincial, state, or federal governmental department or agency; (ii) in an emergency, to protect the safety and physical security of users of the Services or members of the public; or (iii) to investigate breaches of agreements or Singapore law.

    6. Business Transfers

      If Bountie sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business, Bountie may transfer your Personal Information to the party or parties involved in the transaction as part of that transaction.

    7. Disclosure to Users

      You are entitled to see the Personal Information held about you and you may ask us to make any necessary changes to ensure that it is accurate and kept up to date. If you wish to do this, please contact us at [email protected].

  4. Obtaining Consent

    1. In most cases, when we do collect Personal Information directly from an individual, the Purposes for which the individual provides us with the information – for example, as required for us to effectively provide our Services – will be clear, and as such, consent to the collection and use of Personal Information for those Purposes will be implied by the use of the Services. If we choose to use Personal Information already in our possession for a purpose that was not identified at the time we initially collected the information, we will seek the consent of the affected individuals before using this information for the new purpose. Please note that if the new purpose is required or permitted by law, Bountie is not required to seek the consent of the affected individuals and may not do so. Individuals may withdraw consent to the collection, use and disclosure of their Personal Information at any time, subject to certain restrictions set out in applicable privacy legislation, but should recognize that by doing so they may be unable to utilize the Services and products offered on the Site.

  5. Management of Personal Information

    Bountie has policies and procedures as to how long it retains information that it collects. Personal Information that is no longer required to fulfil the Purposes is either destroyed, erased or rendered anonymous to prevent unauthorized parties from gaining access to the information.

    We retain Personal Information received from third parties in accordance with our legal and contractual obligations. The file containing your Personal Information will be made available to the authorized employees, contractors or agents of Bountie who need to access the information in connection with the Purposes, and will be held primarily in an electronic database.

    Bountie has implemented a variety of commercially reasonable security safeguards to protect Personal Information in our control against loss, theft, misuse and interception by third parties. These safeguards include organizational, technical and physical measures designed to protect information from unauthorized access, disclosure, copying, use or modification. Among the steps taken are:

    • Restricted file access to Personal Information;

    • Premises security;

    • Technology safeguards, including security software, firewalls to prevent hacking and other unauthorized computer access; and

    • Internal password and security policies

    However, please note that no data transmission or storage can be guaranteed to be 100% secure. We are committed to protecting your Personal Information, but we cannot ensure or warrant the security of any information you transmit to us. Please take reasonable steps to guard against identity theft, including 'phishing' attacks. You are responsible for maintaining the confidentiality of your password and account, and you are fully responsible for all activities that occur under your password or account. In the event of unauthorized use of your password or account or any other breach of security, you must notify Bountie immediately and promptly change your password.

  6. Accuracy and Collection of Personal Information

    1. Bountie is committed to open and fair privacy practices which comply with applicable privacy legislation.

      Any individual may request access to their Personal Information held by Bountie by contacting us at [email protected] After receiving such a request, our Privacy Officer shall inform the individual of the existence, use and disclosure of their Personal Information and shall allow the individual to access such information.

      In certain circumstances to the extent permitted or required by applicable law, access to Personal Information may be denied. If we deny an individual's request for access to their Personal Information, we will advise such individual in writing of the reason for the refusal and they may then challenge the decision.

      Where Personal Information is used on an on-going basis, Bountie undertakes to correct any information that is shown to be inaccurate, incomplete or not up-to-date. Otherwise, Bountie does not routinely update Personal Information. It is the member's responsibility to provide us with current, complete, truthful and accurate information, including Personal Information, and to keep such information up to date. We cannot and will not be responsible for any problems or liability that may arise if a member does not provide us with accurate, truthful or complete information or Personal Information or the member fails to update such information or Personal Information.

      Upon notification from an individual of their desire to have any or all of their Personal Information in our records deleted or destroyed, Bountie may undertake to delete or destroy all such information to the extent that retention of such information is not required or permitted by applicable law, such as the investigation of claims or the defense of an action, and some Personal Information may remain in back-up storage for this purpose. In the event that an individual wishes to challenge Bountie's compliance with any of these principles, they can contact us at [email protected]. If Bountie finds a complaint to be justified, appropriate measures will be taken, including, if necessary, amending our policies and practices.

  7. Governing

    1. The Site is governed by and operated in accordance with the laws of the Republic of Singapore applicable therein, without regard to its conflict of law provisions, and you hereby consent to the exclusive jurisdiction and venue in the courts of the Republic of Singapore located in Singapore, in all disputes arising out of or relating to the Services. Notwithstanding any other provisions of this Policy or the Terms of Service, we may seek injunctive or other equitable relief from any court of competent jurisdiction. You agree that any dispute that cannot be resolved between the parties shall be resolved individually, without resort to any form of class action.

      We make no representation that this Site is operated in accordance with the laws or regulations of, or governed by, other nations. By utilizing the Services and participating in Site activities, you certify that you meet the age and other eligibility requirements of the Site and the Services set forth in the Terms of Service. If you do not meet the age and other eligibility requirements, please discontinue using the Site and the Services immediately as your continued use of the Site and the Services indicates that you are agreeing to the collection, use, disclosure, management and storage of your Personal Information as described in this Privacy Policy.

  8. Where is Your Personal Data Processed and Stored?

    1. Bountie always tries to process Your Personal Data within Singapore. However, in some situations Your Personal Data may be transferred to and processed in a country outside of Singapore. In those cases, Bountie ensures that appropriate measures are in place to protect Your Personal Data in accordance with applicable data protection law.

  9. Deselection of Personal Data

    1. Your Personal Data will be stored as long as You have an active User Account. Eleven months after Your last login will receive a reminder on Your inactivity. Upon further inactivity, Your User Account will be blocked. Two years after Your last login, Your User Account will be deleted due to inactivity unless the data is required for a specific reason or Bountie has agreed with You to store the Personal Data for a specified period. Bountie reserves the right to delete Personal Data earlier if Bountie deems it appropriate.

  10. Your rights

    Below are the rights that You have under applicable data protection law. If You wish to send a request regarding any of Your rights, please contact Us at [email protected].

    In order to meet Your request, the request needs to be as specific as possible. Please use indicators such as: the type of data, the type of document, the involved function/business department and/or the involved contact persons etc.. Your request cannot be processed if the request is not specific or clear.

    1. Right to Access - Once a year You have the right to request a withdrawal of a record of wish Your Personal Data We hold about you.

    2. Right to Rectification - If the Personal Data Bountie holds about You is inaccurate or not complete, You have the right to ask Us to rectify it. If that Personal Data has been passed to a third party with Your consent or for legal reasons, then We must also ask them to rectify Your Personal Data.

    3. Right to Erasure - You have the right to erase all Your Personal Data collected by Us if we do not have a legal reason to continue to process and hold it.

    4. Right to Object - You have the right to object to Bountie processing Your Personal Data even if it is based on Our legitimate interests, the exercise of official authority, direct marketing, or processing for the purpose of statistics.

    5. Right to withdraw consent - If You have given Us Your consent to process Your Personal Data but change Your mind, You have the right to withdraw Your consent at any time, and Bountie must discontinue processing Your Personal Data.

  11. Contact Us

    1. If you have any questions or complaints regarding this Privacy Policy or the practices of this Site, please contact us by sending an email to [email protected].

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