Privacy Policy

1. General Information 


1.1. Service description and provider
Bayes Esports Solutions GmbH, domiciled in Axel-Springer-Str. 54b, 10117 Berlin (“Bayes”, “we” or “our”), takes the protection of your personal data very seriously and therefor makes available to you the following information (the “Privacy Policy”).
Bayes is a company focusing on analysis, distribution and delivering customized solutions in esports data. We combine technical expertise and an extensive distribution network; we are a one of a kind one-stop-shop for rights holders and data consumers alike.
Whenever you use our website (the “Service”), we will be processing personal data, as described in the Processing Procedure section of this Privacy Policy. By processing the General Data Protection Regulation (“GDPR”) references a very broad spectrum of operations executed on personal data - basically, whenever we or others get in contact with your personal data, we process it, according to the GDPR definition. Personal data is information that we or others can use to identify a person, i.e. information that can be linked to a particular individual.
As a company based in the European Union, we treat all personal data in compliance with GDPR, no matter where you are from or where you are currently located.

1.2. Scope of the privacy policy
The following Privacy Policy will provide you with information about the type of personal data that is collected and how it is processed and used during your use of the Service. Unless otherwise provided in this Privacy Policy, this Privacy Policy exclusively regulates how Bayes, including the companies that help us provide the Service (the “Vendors”), processes your personal data. In case you make use of services provided by third parties other than the Vendors, the privacy policies of these third parties apply exclusively.

1.3. Contact details of the provider
Contact Detail of the controller according to Art. 4 GDPR:
    Bayes GmbH, Axel-Springer-Str. 54b, 10117 Berlin, 
    Managing Director: Martin Dachselt 
    Email: contact@bayes.gg, telephone: 49 30 120 848 98;
    District Court Berlin Charlottenburg: HRB  201860 B.
Unless otherwise provided in this Privacy Policy and in case you want to exercise any right pursuant to this privacy policy or applicable data protection laws and regulations or if you have any questions concerning privacy policy issues, please contact contact@bayes.gg. At this address, you can inquire about privacy issues and issue a request to review, change or delete your personal data stored by Bayes, as described below. Alternatively, you can also contact Bayes using the above postal address or by phone. This will cause you no other costs than the transmission costs stated in the base rates (i.e. the costs of your Internet, e-mail, mobile phone or telephone connection).
You can reach our data protection officer at the following contact details:
ClixOn GmbH, Oranienburger Straße 70, 10117 Berlin
Email contact@bayes.gg

1.4. Rights
In accordance with the requirements pursuant to the GDPR, you may exercise the following rights:
1.4.1. Right to be informed (Art. 12 GDPR) - You have the right to be informed about how Bayes processes personal data. To this end this privacy policy will provide you with descriptions of the purpose (why we use your data), the retention policy (how long we process data) and who we share personal data with (our processors/Vendors).
1.4.2. Right of access (Art. 15 GDPR) - You have the right to know what personal data about you we use and process. Please have a look at the Processing Procedure sections below for a comprehensive overview. If you want to know more, get in contact with us using the contact details provided above.
1.4.3. Right to rectification (Art. 16 GDPR) - You have the right to request, that we correct inaccurate data we process about you or that we add data, where it is incomplete. Some of the information we process is being provided by you during the account creation or during the use of the App and may be modified through the App itself. If you feel that other personal data may be incorrect, simply get in touch with us, as described above.
1.4.4. Right to erasure (Art. 17 GDPR) - In some instances, we may ask for your consent before processing your data. If you change your mind later, you can simply change the respective setting in the Service and we will no longer process any consent based data. Please note that we automatically erase your data, if it no longer necessary for the purpose we collected or processed it for. We will also ensure that data is erased from Vendor systems. If, for example, you have contacted our customer support and requested help, we will erase all personal data once your request has been solved, since your personal data is no longer needed for the purpose of providing you with customer support. If beyond that you believe that you have a right to have your personal data deleted, please contact us as described above.
1.4.5. Right to restrict processing (Art. 18 GDPR) - When you exercise your right to rectification, to object or to erasure you may ask Bayes to restrict the processing of personal information to the extent necessary to review your request. If you continue using our Service(s) during such a request, we will also process your personal data to provide you with the Service. If beyond that you believe that you have the right to have your personal data use restricted, please contact us as described above.
1.4.6. Right to data portability (Art 20 GDPR) - You may ask us to export for you the personal data that you provided us with during the Service. This does however not include any data we have created based on the personal data you provided us with. You may also ask us to have your personal data transmitted from us to another controller. Please note that we will consider the technical feasibility on a request by request basis. If you choose to exercise this right, simply get in contact with us using the contact information provided above.
1.4.7. Right to object (Art. 21 GDPR) - To the extent that Bayes’ data processing is based on legitimate interest, you can object the processing of data we engage into at any point. Please check the Processing Procedures below to see if the processing you are objecting to is based on legitimate interest. You can find this information under the Legal Basis subsections. If you choose to exercise this right, simply get in contact with us using the contact information provided above.
1.4.8. Rights in relation to automated decision making and profiling (Art. 22 GDPR) - We do not engage in automated decision making or profiling according to the definitions provided under GDPR.
1.4.9. The right to lodge a complaint (Art. 77 GDPR) - You may get in contact with the supervisory authority if you believe that the data concerning you is being processed by Bayes in breach of data protection provisions. The Berlin Commissioner for Data Protection and Freedom of Information is responsible for Bayes and may be contacted as provided here.
In each case mentioned in this Rights section please always ensure to provide us with all the all necessary information to process your request. Once we receive all necessary information, we will usually get back to you no later than a month after you completed your request.Please note, that we may require that you provide means of authentication, if we are not sure about your identity.

2. Processing Procedures


2.1. Access of the website
Whenever you access our website (the “Website”), without using any additional features or services as described below, we process data that your browser and the servers on which the website is hosted, automatically exchange.
2.1.1. Your Data 
In order for the content of the Website being displayed on your device, we process the following data, including as applicable personal data:
- Date and time of access;
- Amount of data sent;
- Browser used;
- Operating system used;
- IP address used (if applicable: in anonymous form).
2.1.2. Data transfer
2.1.2.1. Vendors - Vendors provide applications and services, in this case host services and content delivery service for the Website
Our Vendor for the hosting and delivery of the website is Webflow, Inc.
We have contractually agreed with this Vendor that it may only use your data as instructed by Bayes and for our services. Any other use - including contact by the this Vendor - is only permitted with your prior consent.
2.1.2.2. Authorised public authorities - Law enforcement authorities or public authorities (e.g. tax authorities, social insurance), supervisory authorities in the event of requests for or obligations to provide information in the event of legal action, preliminary proceedings and to our own tax advisors, auditors and lawyers in order to exercise our rights and our legal obligations.
2.1.2.3. Change in ownership - In the event of a takeover or merger with another company, we will pass on your data to that company. In such a case, we will ensure that the applicable data protection regulations are complied with and that the data will only be processed to the same extent as described in this policy.
2.1.3. Legal basis
Your data related to displaying the Website will be processed pursuant to Art. 6 para. 1 lit. b GDPR, which allows for the processing of personal data for the purpose of fulfilling a contract.
2.1.4. Data retention
Any processing of this data will cease as soon as you stop interacting with the website. Data is automatically deleted no later than 24 hours after your visit.

2.2. Server Log Files
Each time you access the Website, we automatically collect a series of technical data and store them in our systems (the “Server Log Files”), some of which is considered personal data. We use Server Log Files to monitor and secure the services we offer to you and in order to improve and better our services, including error tracking, usage evaluation, anti intrusion and fraud protection.
2.2.1. Your Data
The data processed in Server Log Files includes:
- IP Address,
- operating system version,
- the configuration of your device and browser when accessing the Website,
- the time and date of your use of the Website.
This data is not combined with other personal data that you provide Bayes during the use of the Website. We collect Server Log files for the purpose of administering the Website and being able to recognize and prevent unauthorized access.
2.2.2. Data transfer
2.2.2.1. Vendors - Vendors provide applications and services, e.g. host computers, backup services, database services, error tracking, and technical analysis, anti intrusion and fraud protection.
This Vendor is the Webflow, Inc.
We have contractually agreed with these Vendors that they may only use your data as instructed by Bayes and for our services. Any other use - including contact by one of these Vendors - is only permitted with your prior consent.
2.2.2.2. Authorised public authorities - Law enforcement authorities or public authorities (e.g. tax authorities, social insurance), supervisory authorities in the event of requests for or obligations to provide information in the event of legal action preliminary proceedings and to our own tax advisors, auditors and lawyers in order to exercise our rights and our legal obligations.
2.2.2.3. Change in ownership - In the event of a takeover or merger with another company, we will pass on your data to that company. In such a case, we will ensure that the applicable data protection regulations are complied with and that the data will only be processed to the same extent as described in this policy.
2.2.3. Legal basis
Server Log Files are processed pursuant to Art. 6 para. 1 lit. f GDPR, which allows the processing of personal data based on a "legitimate interest" of the controller, provided that your fundamental rights, freedoms or interests do not prevail. Bayes’ legitimate interest in this instance is to make administration easier and to detect and to track unauthorised access attempts, errors and attacks on the services. You may object to this data processing at any time if you think there may be particular reasons regarding your particular situation which result in your interest prevailing against this data processing.
2.2.4. Data retention
Unless otherwise provided herein, personal data contained in Server Log Files is automatically deleted and generally not processed longer than 90 days. We reserve the right to store the server log files for longer if there is evidence suggesting that an incident (such as an attempt at hacking, a database error or a so-called DDOS attack) has taken place. In this case the Server Log Files in question will be deleted, once the investigation regarding the incident has been closed.

2.3. Use of the Esports Directory API

Please note that we provide a directory of gamers and other esports figures, personalities and teams. This directory is compiled exclusively from data contained in publicly available sources such as the official stats and listings provided by games providers and made available to us through their own APIs in accordance with their own privacy guidelines and practices. Such data will comprise information like match history, past games details, static data, team data etc. All data will be made available only to the users of The Esports Directory and will not be shared with any third parties other than the service providers specified in this Privacy Policy who have contractually agreed that they may only use data for the sole purpose of providing the Service.


2.4. Contact
We offer you the possibility to get in contact via email or telephone. You may get in contact with us in order for us to fulfill applicable legal obligations such as assisting you with data protection related requests under GDPR or for other types of inquiries or requests.
2.4.1. Your Data

When you get in contact with us, certain personal data is processed. You are able to decide which personal data you provide us with during your request, but in general we need your contact information, to respond to your request. We therefore, process the following information:
- phone number; 
- email address;
- other contact information, as provided by you.
This data is stored and processed exclusively for the purpose of responding to your request, for establishing contact and the associated technical administration.
2.4.2 Data transfer
2.4.2.1. Vendors
 - Vendors provide applications and services, in this case host services and email provider services. Our Vendors for the hosting of the contact form and processing of all our emails are the Webflow Incand Google LLC through their Google Apps for Business’ service respectively.
We have contractually agreed with this Vendor that it may only use your data as instructed by Bayes and for our services. Any other use - including contact by this Vendor - is only permitted with your prior consent.
2.4.2.2. Authorised public authorities - Law enforcement authorities or public authorities (e.g. tax authorities, social insurance), supervisory authorities in the event of requests for or obligations to provide information in the event of legal action preliminary proceedings and to our own tax advisors, auditors and lawyers in order to exercise our rights and our legal obligations.
2.4.2.3. Change in ownership - In the event of a takeover or merger with another company, we will pass on your data to that company. In such a case, we will ensure that the applicable data protection regulations are complied with and that the data will only be processed to the same extent as described in this policy.
2.4.3 Legal basis 
Your contact data will be processed pursuant to Art. 6 para. 1 lit. b GDPR, which allows for the processing of personal data for the purpose of fulfilling a contract.

2.4.4. Data retention 
This data will be deleted after your request has been processed: This is the case if it is clear from the circumstances that the matter has been finally clarified and no legal storage obligations to the contrary exist.


2.5. Analytics
We use reports provided by analytics providers to help us understand Website traffic and Website usage.
2.5.1 Your Data 
When you access our Website, we will analyse how our Website is used. 
To this end 
- an analytics cookie 
is set on your device. This cookie enables us to track your use of the Website and your interaction with other websites. 
We have enabled the anonymisation feature in Google Analytics, which anonymizes the IP Address of the device accessing the Service.
2.5.2 Data transfer 
2.5.2.1 Vendors - Vendors provide applications and services, in this case host and analytics services. 
This Vendor is the Google, LLC through their Google Analytics service.
We have contractually agreed with this Vendor that it may only use your data as instructed by Bayes and for our services. Any other use - including contact by  this Vendor - is only permitted with your prior consent.
2.5.2.2. Authorised public authorities - Law enforcement authorities or public authorities (e.g. tax authorities, social insurance), supervisory authorities in the event of requests for or obligations to provide information in the event of legal action preliminary proceedings and to our own tax advisors, auditors and lawyers in order to exercise our rights and our legal obligations.
2.5.2.3. Change in ownership - In the event of a takeover or merger with another company, we will pass on your data to that company. In such a case, we will ensure that the applicable data protection regulations are complied with and that the data will only be processed to the same extent as described in this policy.
2.5.3. Legal basis 
Analytic data is processed pursuant to Art. 6 para. 1 lit. f GDPR, which allows the processing of personal data based on a "legitimate interest" of the controller, provided that your fundamental rights, freedoms or interests do not prevail. Bayes’ legitimate interest in this instance is to have an insight on how our website is used, where traffic is coming from and where it leaves the Service to. You may object to this data processing at any time if you think there may be particular reasons regarding your particular situation which result in your interest prevailing against this data processing.
2.5.4. Data retention
Notwithstanding anything to the contrary, you can opt out from analytic services at any point. To opt out of analytics services on the Website on your device, either change your setting for all websites by following this link.
The data retention for analytic services is 14 month.