Other Covered Entities



  • Media and Entertainment
  • Video Games
  • Online Games


Swiss-U.S. Privacy Shield Framework: Active

Original Certification Date: 5/24/2019
Next Certification Due Date: 9/9/2022
Data Collected: NON-HR

EU-U.S. Privacy Shield Framework: Active

Original Certification Date: 5/24/2019
Next Certification Due Date: 9/9/2022
Data Collected: NON-HR

Purpose of Data Collection

Our organization collects user data internally and through third-party mechanisms (Google Analytics and Hotjar) to improve the user experience of our users. This behavioral data, such as click and viewing behavior, is either owned by our organization or anonymized before being sent to the third party. We also collect data to enable user features: such as user preferences and connected third party accounts.

Privacy Policy

Non-HR Data


Outplayed Inc. Privacy Policy Last Updated on July 15th, 2020 Introduction This privacy policy will help you understand what information Outplayed Inc. and its various platforms (such as U.GG) collects and uses, and the choices you have associated with that information. When we refer to “Outplayed,” “we,” “our,” “us” or “U.GG” in this policy, we are referring to Outplayed Inc., which provides the Services to you. The “Services” refers to the applications, services, and websites (marketing and product) provided by Outplayed Inc. Outplayed may, from time to time, introduce new products and services. To the extent that these new products and services affect this policy, we will notify you as described in Section 8 below. This privacy policy covers all of the digital properties associated with Outplayed Inc., specifically U.GG and all of its subdomains. The use of information collected through our service shall be limited to the purpose of providing the services for our customers and as specified herein. If you have any questions, inquiries, or complaints about this privacy policy or our practices, please contact us via email at privacy@u.gg. Contents Information We Collect and Receive How We Use the Information We Collect and Receive Analytics, Cookies and Other Web Site Technologies Information Sharing and Accountability for Onward Transfers Communicating Accessing Your Data Security Internal Policies and Procedures Recourse, Enforcement, and Dispute Resolution Changes to this Statement/Contact Us 1. Information We Collect and Receive We collect several different types of information to provide Services to you, including: User Account and Registration Data This includes information you provide to create your account with us, and may include, first and last name, billing information, a password and a valid email address. Service Data (including Session and Usage data) When you use our Services, we receive information generated through the use of the Service, either entered by you or others who use the Services with you (for example, League of Legends summoner name, favorite champions, etc.), or from the Service infrastructure itself, (for example, duration of session, connection information, etc.). We may also collect usage and log data about how the services are accessed and used, including information about the device you are using the Services on, IP addresses, location information, language settings, what operating system you are using, unique device identifiers and other diagnostic data to help us support the Services. Device Information: When you use our Services, we automatically collect information on the type of device you use, operating system version, and the device identifier (or "UDID"). 2. How We Use the Information We Collect and Receive U.GG may access and use the data we collect as necessary (a) to provide and maintain the Services; (b) to address and respond to service, security, and customer support issues; (c) to detect, prevent, or otherwise address fraud, security, unlawful, or technical issues; (d) as required by law; (e) to fulfill our contracts; (f) to improve and enhance the Services; (g) to provide analysis or valuable information back to our Customers and users. Some specific examples of how we use the information: Create and administer your account Send you reminder and update emails Send you product updates, marketing communication, and service information Respond to customer inquiries and support requests Conduct research and analysis Display content based upon your interests Analyze data, including through automated systems and machine learning to improve our services and/or your experience Provide you information about your use of the services and benchmarks, insights and suggestions for improvements 3. Analytics, Cookies and Other Web Site Technologies U.GG is continuously improving our websites and products through the use of various third party web analytics tools, which helps us understand how visitors use our websites, what they like and dislike, and where they may have problems. While we maintain ownership of this data, we do not share this type of data about individual users with third parties. Geolocation and Other Data: We may utilize precise Geolocation data but only if you specifically opt-in to collection of that data in connection with a particular service. We also use information such as IP addresses to determine the general geographic locations areas of our visitors. The web beacons used in conjunction with these web analytics tools may gather data such as what browser or operating system a person uses, as well as, domain names, MIME types, and what content, products and services are reviewed or downloaded when visiting or registering for services at one of our websites or using one of our mobile applications. Google Analytics: We use Google Analytics as described in “How Google uses data when you use our partners' sites or apps.” You can prevent your data from being used by Google Analytics on websites by installing the Google Analytics opt-out browser add-on here. We also employ IP address masking, a technique used to truncate IP addresses collected by Google Analytics and store them in an abbreviated form to prevent them from being traced back to individual users. Portions of our website may also use Google Analytics for Display Advertisers including DoubleClick or Dynamic Remarketing which provide interest-based ads based on your visit to this or other websites. You can use Ads Settings to manage the Google ads you see and opt-out of interest-based ads. Tracking Technologies: U.GG uses cookies and similar tracking technologies to track user traffic patterns and hold certain registration information. Tracking technologies also used are beacons, tags and scripts to collect and track information and to improve and analyze our service. If you wish to not have the information these technologies collect used for the purpose of serving you targeted ads, and are located in the European Union, click the Privacy button in the bottom right corner of your screen. The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can still review the website if you choose to set your browser to refuse all cookies; however, you must enable cookies to establish an account and to install the Services. Social Media: Our sites may include social media features, such as Facebook, Google, and Twitter “share” buttons. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These services can also authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to expedite the login and signup process respectively. Your interactions with these features are governed by the privacy policy of the company providing them. Hotjar: We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link. 4. Information Sharing and Accountability for Onward Transfers Ensuring your privacy is important to us. We do not share your personal information with third parties except as described in this privacy policy. We may share your personal information with (a) third party service providers; (b) business partners; (c) affiliated companies within our corporate structure and (d) as needed to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence. Third party service providers have access to personal information only as needed to perform their functions and they must process the personal information in accordance with this Privacy Policy. Examples of how we may share information with service providers include: Payment processing and fraud prevention Providing customer support Sending marketing communications Conducting research and analysis Providing cloud computing infrastructure Examples of how we may disclose data for legal reasons include: As part of a merger, sale of company assets, financing or acquisition of all or a portion of our business by another company where customer information will be one of the transferred assets. As required by law, for example, to comply with a valid subpoena or other legal process; when we believe in good faith that disclosure is necessary to protect our rights, or to protect your safety (or the safety of others); to investigate fraud; or to respond to a government request. We may also disclose your personal information to any third party with your prior consent. We maintain written contracts with these third parties and require that these third parties provide at least the same level of privacy protection and security as required by the Privacy Shield Principles. To the extent provided by the Principles, Outplayed Inc. remains responsible and liable under the Privacy Shield Principles if a third-party that it engages to process personal information on its behalf does so in a manner inconsistent with the Privacy Shield Principles, unless Outplayed Inc. proves that it is not responsible for the matter giving rise to the damage. 5. Communications U.GG may need to communicate with you for a variety of different reasons, including: Responding to your questions and requests. If you contact us with a problem or question, we will use your information to respond. Sending you Service and administrative emails and messages. We may contact you to inform you about changes in our Services, our Service offerings, and important Service related notices, such as billing, security and fraud notices. These emails and messages are considered a necessary part of the Services and you may not opt-out of them. Sending emails about new products or other news about U.GG that we think you’d like to hear about either from us or from our business partners. You can always opt out of these types of messages at any time by clicking the unsubscribe link at the bottom of each communication. Conducting surveys. We may use the information gathered in the surveys to enhance and personalize our products, services, and websites. Offering referral programs and incentives, which allow you to utilize email, text, or URL links that you can share with friends or colleagues. 6. Accessing Your Data U.GG will, when you request, provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. Please contact us at privacy@u.gg if you need assistance in reviewing your information. U.GG will respond to your access request to review the information we have on file for you within a reasonable time. Pursuant to the Privacy Shield Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@u.gg. If requested to remove data, we will respond within a reasonable timeframe. We may transfer personal information to companies that help us provide our service, and when we do, these transfers to subsequent third parties are covered by appropriate transfer agreements. We will retain personal data we process on behalf of our customer as needed to provide services to our customers. Also, we will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. U.GG is headquartered in the United States of America and maintains a global infrastructure. Information that we collect and maintain may be transferred to, or controlled and processed in, the United States and/or other countries around the world. When you provide us with information, or use our website(s) and services, you consent to this transfer. We will protect the privacy and security of personal information we collect in accordance with this privacy policy, regardless of where it is processed or stored. 7. Security U.GG follows generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received, however, no security measure is perfect. We recommend safeguarding your password, as it is one of the easiest ways you can manage the security of your own account – remember that if you lose control over your password, you may lose control over your personal information. 8. Internal Policies and Procedures We train and educate every employee about the above Privacy Policy and any changes that may occur. Employees that are found to violate the Privacy Policy face severe disciplinary actions - which can include termination and a referral to law enforcement agencies in the most extreme cases. Employees are trained upon employment and at least once every calendar year, and the privacy policies are reviewed at least once every calendar year. A statement verifying the above is signed at least once per year and available upon request. 9. Recourse, Enforcement, and Dispute Resolution Outplayed Inc. complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United States in reliance on Privacy Shield.  Outplayed Inc. has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/     Outplayed Inc. is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”). We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@u.gg.   In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.    In compliance with the Privacy Shield Principles, Outplayed Inc. commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact Outplayed Inc. by email at privacy@u.gg Outplayed Inc. has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you. If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction 10. Changes to this Statement/Contact Us We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will provide notice on this website, and we may notify you by email (sent to the e-mail address specified in your account), prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. If you continue to use the Services after those changes are in effect, you agree to the revised policy. If you have any other questions about this policy please contact the U.GG Privacy Team via email at privacy@u.gg, or write to us via postal mail at: U.GG, 200 E. 6th St Suite 202, Austin, TX, 78701, USA. To reach our Global Customer Support department, you may contact us via email at info@u.gg.

Effective Date: 7/17/2020

Verification Method


Dispute Resolution

Questions or Complaints?

If you have a question or complaint regarding the covered data, please contact Outplayed, Inc. at:

Shinggo Lu
Outplayed, Inc.
200 E 6th St Suite 202
Austin, Texas 78701

Privacy Shield organizations must respond within 45 days of receiving a complaint.

If you have not received a timely or satisfactory response from Outplayed, Inc. to your question or complaint, please contact the independent recourse mechanism listed below


Appropriate statutory body with jurisdiction to investigate any claims against Outplayed, Inc. regarding possible unfair or deceptive practices and violations of laws or regulations covering privacy Federal Trade Commission