We appreciate your interest in our Privacy Policy. At Galium, we take the protection of your data very seriously, and in the below we explain what data we collect when you use our website www.galium.gg and how it is used.

General Information

What law applies?

Our use of your Personal Data is subject to both Canada's Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the EU's General Data Protection Regulation (“GDPR”), and of course we process your Personal Data accordingly.

What is Personal Data?

Personal Data is any information relating to personal or material circumstances that relates to an individual. This may include a name, date of birth, e-mail address, postal address, or telephone number but also online identifiers such as IP addresses or device ID`s.

What is processing?

"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

Who is responsible for data processing?

The responsible party within the meaning of the PIPEDA and the GDPR is Galium AntiCheat LLC (“Galium”, “we”, “us”, or “our”).

If you have any questions about this policy or our data protection practices, please contact us using [email protected].

What are the legal bases of processing?

In accordance with the PIPEDA and the GDPR, we have to have at least one of the following legal bases to process your Personal Data:

For the fulfilment of contractual obligations
- The purposes of the data processing are primarily based on the service we provide.
Within the framework of our legitimate interests

Where necessary, we process your data beyond the actual performance of the contract in order to safeguard legitimate interests of us or third parties. Examples are:

Ensuring IT security and IT operations,
Measures for business management and further development of our services,
Defence against third-party claims and enforcement of own claims.

Based on your consent
- Insofar as you have given us your consent to process personal data for certain purposes.

Is there an obligation for me to provide data?

Within the scope of our business relationship, you are only required to provide personal data that is necessary for the establishment, implementation, and termination of a business relationship or that we are legally obliged to collect. Without this data, we will usually have to refuse to conclude the contract or will no longer be able to perform an existing contract and may have to terminate it.

Data we collect automatically

Log data

Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii)

amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user's device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.

Use of cookies

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies:

Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and
Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).

As set out in Canada`s PIPEDA and Anti-spam legislation (“CASL”), and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies and do so when you visit our website for the first time through our Cookie Consent Management Tool. For further information on the Cookies we use, please refer to our Cookie Policy.

Cookie consent

Our website uses a cookie consent management tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The basis for processing is our legitimate interest.

Economic analyses and market research

For business reasons, we analyse the data we have on web and server traffic patterns, website interactions, browsing behaviour etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarised and or anonymized values. For this purpose we use Google Analytics. The legal basis is our legitimate interest and your consent. For further information on our use of Google Analytics, please refer to our Cookie Policy.

Links to other providers

Our website also contains - clearly recognisable - links to the websites of other companies. When you use a link from our website to a third-party website, such third-party websites may also set cookies or become aware of your IP address. This processing is not subject to this policy. The respective provider or operator of the pages is always responsible for the content of these pages. We recommend that you refer to the privacy policy on the relevant third-party website itself.

Data we collect directly

Contacting us

In addition to your name, company name, and e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and contract.

Contractual services

We process the Personal Data involved in your use of our services in order to be able to provide our contractual services. This includes in particular our support, correspondence with you, invoicing, fulfilment of our contractual, accounting and tax obligations. The data processed includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g., e-mail addresses and telephone numbers) as well as contractual data (e.g., services used, contents of the contract, contractual

communication, names of contact persons) and payment confirmations (Payment data will solely be processed through our payment service provider and we have no access to any Payment Data you may submit). Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations.

Dashboard access

A user profile and access to our dashboard will be created for you based on the information you provide during the sign up. You are able to sign up using the convenience log in and sign up from Steam (Valve Corporation) (this may require prior registration with Steam and/or installation of Steam software). For convenience log in and sign up, you will be asked to provide your basic information (i.e., name, email address, and display picture if any) linked to your account. When registering via convenience functions, you agree to the relevant terms and conditions and consent to certain data from your respective profile of being transferred to us. You have the option of adjusting, changing, or deleting the information in your account and profile or by contacting us. The data processing carried out in this context is necessary to provide our service on the basis of the requests made by you.

When using our Services

We may also and depending on how you use our services process personal data (including your users steam ID, steam name, IPs (if tracking the IP is enabled) from your customers. Including name, address, address history, invoice details, ect.

As such and when using our services, you become the data controller and we become the data processor in accordance with Chapter 4 of the GDPR. Where we process Personal Data as data processor or in other words on behalf of you, we will process the Personal Data involved in your use of our services in accordance with your instructions and shall use it only for the purposes agreed between you and us.

We ensure that access by our employees to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our employees and enforce privacy and protection safeguards strictly.

Further, please be advised that:

some jurisdictions may require you to disclose your use of our services as your processor in your privacy policy and/or data processing agreement as applicable.
if you are providing us with Personal Data relating to a third party, you agree a) that you have in place all necessary appropriate consents and b) that such third party has read this Privacy Policy. You agree to indemnify us in relation to all and any liabilities, penalties, fines, awards, or costs arising from your non-compliance with these requirements.

Administration, financial accounting, office organisation, contact management

We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

We have a presence on social media based on our legitimate interest (currently, TikTokand Discord). If you contact or interact with us via social media platforms, we and the respective social media platform are jointly responsible for the processing of your data and enter into a so-called joint-controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual performance, if any.

We refer to our offered social media presences with links. Unlike social media plugins, links do not cause the social media platform to learn of your visit when you access our site. However, like any link, they do lead to your data being processed by the social media platform at the latest when you click on the link. As a rule, the social media platform stores cookies on your device or even your usage behaviour in your account, especially if you are logged in yourself. The social media platform may use your data to analyse your usage behaviour and use it for (interest-based) advertising. This may result in advertising being displayed to you inside and outside the social media platform.

General Principles

Who receives my data?

Within Galium, those that need your data to fulfil our contractual and legal obligations will receive access to it. Processors used by us may also receive data for these purposes. These are companies in the categories of IT services, telecommunications, and sales and marketing. Where we use processors to provide our services, we take appropriate legal precautions and corresponding technical and organisational measures to ensure the protection of personal data in accordance with the relevant legal provisions.

Data is only passed on to third parties within the framework of legal requirements. We only pass on users' data to third parties if this is necessary, for example, for contractual purposes or on the basis of legitimate interests in the economic and effective operation of our business, when we are lawfully obligated to do so, or you have consented to the transfer of data.

How long will my data be stored?

As far as necessary, we process and store your personal data for the duration of our business relationship, which also includes, for example, the initiation and execution of a contract.

In addition, we are subject to various storage and documentation obligations, which result from the minimum statutory retention periods. The retention and documentation periods specified there are two to 8 years.

How do we secure your data?

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of content or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

Is data transferred to a third country or to an international organisation?

We may transfer your Personal Data to other companies and/or staff members as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.

Special Category Data

Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.

Minors

We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

Automated decision-making

Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.

Do Not Sell

We do not sell your Personal Data.

Your Rights and Privileges

Privacy rights

Under the PIPA, you have the following rights:

Right to be informed
Right to access
Right to rectification
Right to erasure
Right to object/opt-out
Right to Consent
Right to Redressal

Under the GDPR, you can exercise the following rights:

Right to information
Right to rectification
Right to object to processing
Right to deletion
Right to data portability
Right to withdraw consent
Right to complain to a supervisory authority
Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

Updating your information

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.

Withdrawing your consent

You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Access Request

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The Office of the Privacy Commissioner, 30 Victoria Street, Gatineau,

Quebec, J8X 0A8, www.priv.gc.ca.However, we would appreciate the opportunity to address your concerns before you contact the Privacy Commissioner.

Validity and questions