Procomps Ltd (‘Procomps’/‘us’/‘our’/‘we’) is committed to protecting and respecting your privacy.
We created this Privacy Policy (‘Policy’) to provide you with information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website “https://procomps.gg/”(‘Website’) and ProComps’ desktop app (‘App’). The services we provide to you (including the Website, the App and the content) will be called the ‘Services’.
Please read this Policy carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our Website or creating a user account in our App you are accepting and consenting to the practices described in this Policy
IF YOU DO NOT AGREE WITH THIS POLICY, DO NOT ACCESS OR USE OUR SERVICES OR INTERACT WITH ANY OTHER ASPECT OF OUR BUSINESS.
This Policy is provided in a layered format so you can click through to the specific areas set out below.
This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Policy.
Data controller: Procomps Ltd, a limited company incorporated in England and Wales with registered number 14678346 and with our registered office at 71-75 Shelton Street, Covent Garden, London WC2H 9JQ is a data controller when you use our App, when you subscribe to our e-newsletter, or when we deal with a Website user’s data.
Our App is only available on the Overwolf platform, owned by Overwolf Ltd (‘Overwolf’). Overwolf may also gather information about you in accordance with their own separate privacy policy. For information on how your personal data is handled, please read Overwolf's privacy policy here.
UK Information Commissioner’s Office (ICO) Registration number: ZB675329
What types of information we collect: We may collect, use, store and transfer different kinds of personal data about you which we have grouped as Identity Data (e.g. name), Contact Data (e.g. e-mail address), Technical Data (e.g. your IP address, device or browser type), Usage Data (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address)), Marketing and Communications Data and Profile Data (e.g. your Discord ID, your feedback provided on our social media channels). Learn more about it here.
Do we collect any sensitive personal information? We do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us.
How we collect or obtain information about you: We collect personal data from you directly when you provide it to us (e.g. by contacting us; creating a user account on our App; signing up for our e-newsletter, sending us feedback); and automatically from your use of our Website or App, using cookies and similar technologies; and occasionally, from third parties. Learn more here.
How we use your information: We use your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention, advertise our goods and services, analyse your use of our Website, and comply with the law. We may also use your information for other purposes with your consent. We process information only when we have a valid legal reason to do so. Learn more more here.
How we share your information with third parties: Only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you, where required by law or to enforce our legal rights. Learn more here .
Transfers of your information outside the European Economic Area (EEA): We will only transfer your information outside the UK and European Economic Area if we are required to do so by law. Where we do so, we will ensure appropriate safeguards are in place together with enforceable rights and effective legal remedies for you. Learn more here .
How long we keep your information: For no longer than necessary, taking into account any legal obligations we have, any other legal basis we have for using your information (e.g.your consent, performance of a contract with you or our legitimate interests as a business). Learn more here .
How we secure your information: We have appropriate security measures to prevent personal data from being accidentally lost, used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it. Learn more here.
Use of cookies and other tracking technologies: We use cookies and similar information-gathering technologies such as web beacons on our Website including functional, analytical and targeting cookies. For more information, please visit our Cookie Policy here .
Your rights in relation to your information: To access your information and to receive information about its use; to have your information corrected and/or completed to have your information deleted; to restrict the use of your information to receive your information in a portable format; to object to the use of your information; to withdraw your consent to the use of your information not to have significant decisions made about you based solely on automated processing of your information including profiling to complain to a supervisory authority.
Additional Disclosure for California Residents: If you are a California resident, please see the “Additional Disclosure for California Residents” asset out in Section13.
“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
· Identity Data includes first name, maiden name and last name [if you choose to give this to us].
· Contact Data includes email address.
· Technical Data includes internet protocol (‘IP’) address, device ID, your login data, browser type and version, time zone setting and location (only country code of the user), browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website, App and Services.
· Usage Data includes information about how you use our Website, App and Services, including your device ID and the full Uniform Resource Locators (‘URL’) clickstream to, through and from our Website and App (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences [if you choose to give this to us].
· Profile Data includes information on your Discord ID, your feedback provided on our social media channels (e.g. Discord, Instagram), tickets created on Discord, and survey responses [if you choose to give this information to us].
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data because this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
We do not collect, store and/or use ‘special category data’ about you. This means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.
If you fail to provide necessary personal data to us (we will let you know when this is the case, for example, by making this information clear in our registration forms), we may not be able to provide you with our goods and/or services.
When you use our Services or interact with us through some other means we collect personal data either directly from you or through you. This information is divided into three main categories: (1) information you provide to us directly, (2) information we automatically collect from you, and (3) information we collect from third parties.
We may collect personal data from you when you enter or send us information such as when you:
a) Create a user account on our App: Signing up is not mandatory, and you can use ProComps without creating a user account on our App. Creating a ProComps user account is needed when you want to access certain features like making custom tier lists, champion pools, and saving comps. We collect the following information: e-mail address and any other information you provide to us when you complete the registration form, including any optional information, such as name, Discord ID, and your server.
b) Request Marketing Communications: During the registration process for creating an account on our App when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us via e-mail.
c) Subscribe to our e-newsletter: We collect your e-mail address when you subscribe to our e-newsletter.
d) Enter a competition, promotion, or survey: We collect the information you provide if you choose to participate in a competition, promotion, survey, marketing campaign, or event conducted and sponsored by us.
e) Give us reviews, feedback, or other user-provided content: We collect and use your information when you provide reviews on our social media pages, reach out to us through our customer support channels or through surveys we send out. This may include your e-mail address and any other information you provide in that e-mail (such as your name, Discord ID, telephone, the information contained in any signature block) when you send us an e-mail or post; any pictures or video content that you provide us with; and your public social media information if you choose to reach out to us through our social media sites or channels (e.g., X/Twitter, LinkedIn, YouTube, Instagram, and Discord etc.).
We collect information automatically using cookies, web beacons, and other automated technologies when you visit our Website or use our App or Services. The type of information that we collect includes Technical and Usage Data. For additional information, please see our Cookies and other tracking technologies section below.
We receive information about you from information made public by third parties via a website and/or API. For example, our App is only available on the Overwolf platform and Overwolf will share users’ data including but not limited to game data, device information, connected hardware, played games, captured media, etc.
The information we receive depends on the settings, permissions and privacy policy controlled by that third-party service. You should always check the privacy settings and notices in these third-party services to understand what data may be disclosed to us or shared.
We're required by GDPR and UK GDPR to tell you the legal reasons we have for processing your personal data. Here's why we might use your information:
· Consent: We may use your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose.
· Performance of a Contract: We may use your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request before entering into a contract with you.
· Legal Obligations: We may use your information to follow the law, work with legal bodies, defend our rights, or show evidence in court.
· Legitimate Interests: We may use your information where it is necessary to conduct our business and pursue our legitimate interests, for example, to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
| Why we collect | What we collect | Legal Basis if residing in the UK/EEA |
|---|---|---|
| To create and manage your account with us | (a) Identity (b) Contact |
Performance of a contract with you |
| To provide our App and Services | (a) Identity (b) Contact |
Performance of a contract with you |
| To manage our relationship with you which will include: (a) notifying you about changes to our terms or Policy (b) dealing with your requests, complaints and queries |
(a) Identity
(b) Contact (c) Marketing and Communications (d) Profile (e) Other personal information you provide us with |
Depending on the circumstances: (a) Performance of a contract with you; (b) Necessary to comply with legal obligation; or (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To administer and protect our business and our Website and App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical |
Depending on the circumstances: (a) Necessary to comply with our legal obligation (b) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) |
| To use data analytics to improve our Website, App, Services, marketing, customer relationships and experiences | (a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To enable you to partake in a prize draw, or competition or complete a survey (such as confirming your eligibility or sending you a prize if you win) | (a) Identity (b) Contact (c) Usage (d) Marketing and Communications (e) Profile (f) Aggregated Data |
Depending on the circumstances: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business by generating statistics and insights based on Aggregated Data and in connection with contacting you if you win a prize) |
| To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your interests | (a) Identity (b) Contact (c) Usage (d) Marketing and Communications (e) Profile (f) Aggregated Data |
Consent, having obtained your prior consent to receiving direct marketing communications |
| Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g., to record and demonstrate evidence of your consent where relevant | (a) Identity (b) Contact (c) Marketing and Communications (d) Profile (e) Technical Usage |
Necessary to comply with our legal obligation |
During the creating a user account process on our App or subscribing to our e-newsletter, when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from ProComps via e-mail.
We may also analyze your Identity, Contact, Technical, Usage and Profile Data to form a view of which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
You have the right to opt out of receiving marketing communications at any time by:
- contacting us at privacy@procomps.gg
- using the ‘unsubscribe’ link in emails
In delivering our Services to you, we may share your personal data with:
• Third parties in order to undertake various activities or services on our behalf in supporting our Services. This includes:
o website and application support (e.g. Google Analytics, Sentry), and
o hosting and backend infrastructure (e.g. Firebase & Google Cloud);
o Platform provider for our App (e.g. Overwolf);
o analytics and search engine providers (e.g. Google Analytics); and
o providers for the delivery of promotional, digital advertising, co-marketing, or other communications.
• If our business enters into a joint venture, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, or new business partners or owners or their advisors.
• We may use the information that you provide if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation; or to enforce the relevant terms of service and any other agreement; or to protect our rights or the rights of third parties. This includes exchanging information with other companies and organisations such as credit agencies, law enforcement or government bodies or the courts in connection with a criminal investigation, suspected illegal activity, fraud prevention and detection or in legal proceedings.
Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject.
We work with certain other parties (including analytics companies) to provide us with information regarding traffic on and use of the Services. Some of these parties collect information when you visit the Services or other online websites and services. These other parties set and access their own tracking technologies (including cookies, embedded scripts, and web beacons) and may otherwise collect or have access to your IP address or other unique identifiers, log information, and related information about you. These tracking technologies, including the Google Analytics User ID feature, may be used to assist in providing analytics, marketing, and for other purposes. We also use Google services to provide you with in-site search functionality. Both we and Google may collect, receive, and use your information as a consequence of your use of the Google services. Google’s data practices are set out in its privacy policy available at https://policies.google.com/privacy.
We do not control the information collection, use, or sharing practices of such parties, and we encourage you to consult their online policies. Some other parties may collect information about your online activities over time and across different websites when you use the Services.
The EEA, the UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy
.It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases, we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data. As we are based in the UK, we will also transfer your personal data from the EEA to the UK.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
• in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here. We rely on adequacy regulations for transfers to the following countries: e.g. Israel and the USA (under the EU-US data privacy framework).
• We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers; or
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
• a specific exception applies under relevant data protection law.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 6 (six) further months, after which point we will delete your information.
E-Newsletter or e-mail marketing: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not “unsubscribe”) or if we decide to cancel our e-newsletter service, whichever comes earlier.
Creating an account on our App: we will keep your personal data for as long as we have a contract with you. If you delete your user account, we will retain your data for a further 90 days and then securely delete it.
We take appropriate technical and organizational measures to secure your information and to protect it against unauthorized or unlawful use and accidental loss or destruction, including:
· only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on ananonymised basis wherever possible;
· using secure servers to store your information; verifying the identity of any individual who requests access to information before granting them access to information;
· using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our Website; and
· pseudonymisation of passwords.
However, despite our efforts to secure your information, no electronic transmission over the Internet or information storage technology can guarantee 100% security. Therefore, we cannot promise or guarantee that hackers, cyber criminals, or unauthorized third parties will not be able to bypass our security measures and access, steal, modify, or collect your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. It is essential that you only access our Services within a secure environment.
Where you have chosen a password which allows you to access our App for using specific features (e.g. making custom tier lists, champion pools, and saving comps), you are responsible for keeping this password confidential. We advise you not to share your password with anyone. We will not be liable for any unauthorized transactions entered into using your personal data, including but not limited to your username, and/or password. If you suspect unauthorized access, you should change your password, using a strong password immediately.
A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our Website. We use cookies and web beacons, action tag and single-pixel gifs on our Website. These help us recognise you and your device and store some information about your preferences or past actions.
For further information on cookies and any similar technologies (e.g. web beacons, action tag and single-pixel gifs), our use of ‘cookies’ and/or to relevant similar technologies, when we will request your consent before placing them and how to disable them, please see our Cookie Policy.
We may contact you through email or Discord if you opt to connect with us on that platform. It's important to note that if you choose to engage with us via our Discord channel, you will be subject to Discord’s privacy policy.
You have several rights which you can access free of charge. In certain circumstances we reserve the right to charge a reasonable fee if your requests are unfounded or excessive.
You have the right:
· Right to access: You have the right to request a copy of your personal data which you can obtain by sending a message to privacy@procomps.gg. When doing so we will provide you with a copy in a machine-readable format that you can easily transmit to another controller (Right to data portability).
· Right to rectification: You can ask us to change or complete any personal data we hold about you which is inaccurate or incomplete by sending a message to privacy@procomps.gg.
· Right to be forgotten/erasure: You have a right, under certain circumstances to ask us to delete any personal data we hold out you. Please note that there may be situations where we must retain your personal data after a request for erasure where we have a lawful basis fordoing so.
· Right to restrict the processing of your personal data: You can request us to restrict our use of your personal data if you do not believe your data is accurate, you believe the data processing is unlawful but you do not want us to delete the data, we no longer need the data for its intended purpose but your require it for the establishment, exercise or defense of a legal claim, or you have objected to our use of your personal data and want us to restrict its use until we have decided your objection.
· Right to object to processing of your personal data: If we process your personal data based on our, or someone else’s, legitimate interest you can object to us using your personal data for that purpose. Please provide us with any information that you can based on which you believe your interest overrides ours. If you do, we shall reassess our legitimate interest based on the new facts that you have provided and if granted will stop using your personal data for this purpose. When objecting to our use of your personal data for direct marketing purposes we shall stop using your data for such purposes.
· Right to object to automated decision-making and profiling: You have the right to be informed about the existence of any automated decision-making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
· Withdrawal of Consent: Whenever you have given your consent to the processing of your personal data, you can withdraw that consent at any time, doing so is free of charge. You can withdraw your consent directly in your account settings or otherwise at the bottom of any marketing communication that we send you. Please note that you can also withdraw consent for each communication channel separately, including email, text messages (SMS), and in-app notifications, allowing you to manage your preferences with precision.
This section provides information for California residents, as required under California privacy laws, including the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 effective January 1, 2023 (“CPRA”). California privacy laws require that we provide California residents with information about how we use their personal information, and this section is intended to satisfy that requirement.
We do not share your information for cross-context behavioral advertising, or sell it(as those terms are defined under the CCPA), and have not done so in the past 12 months. For purposes of this Policy, “sell” means the disclosure of personal information for monetary or other valuable consideration.
We do not collect sensitive personal information and has not been collected in the past 12 months.
The following table describes the categories of personal information as defined in the CCPA and CPRA that we collected from you through your use of our Services, whether we sold or shared your personal information for cross-context behavioral advertising; and disclosed for a business purpose within the past 12 months.
| Category | Collected Information | Sold or Shared in the Past 12 Months | Disclosed for a Business Purpose in Past 12 Months |
|---|---|---|---|
| A. Identifiers | Unique personal identifier, online identifier, Internet Protocol address, email address, real name | No | Yes |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | Unique personal identifier, online identifier, Internet Protocol address, email address, real name | No | Yes |
| A. Internet or other similar network activity | Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements | No | Yes |
| A. Geolocation data | We do not collect the exact or approximate physical location of our users; however, we may collect the ‘country code’ derived from IP addresses. | No | Yes |
For more information on the information we collect, including the sources we receive information from, please see Section 2 "How do we collect your personal data?". We collect and use these categories of personal information for the business purposes described in Section 3 "How and why do we use your personal data?". For details about the categories of parties with whom your personal information may have been shared for a business purpose, please refer to Section 5 “How do we share your personal data?”.
As defined by the California Consumer Privacy Act, you have specific rights when it comes to the processing of your personal data: Notice at collection: Under the CCPA, California residents must be informed at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used. Right to Deletion: You can ask us to delete your personal information, except where the law allows us to keep it, like for free speech, legal obligations, or to prevent illegal activities.
Right to be Informed: You have the right to know if we collect, use, sell, or share your personal information; what categories of personal information we collect; the purposes for which we use it; and if we've shared it with third parties, among other details.
Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.
Right to Limit Use and Disclosure: We do not process sensitive personal information as defined by the CCPA.
Right to Opt-Out Of Sale or Sharing: We do not sell or share your information for cross-context behavioral advertising or any other reason.
Other Rights: You can object to our processing of your personal data, ask us to correct your data if it's incorrect or outdated, or to limit its processing, appoint an authorized agent to make CCPA requests on your behalf (but we will need proof of their authorization).
Verification Process: When you make a request, we will verify your identity using information you've previously provided. We might ask for additional information if necessary but will delete it once we've confirmed your identity.
California Civil Code Section 1798.83,also known as the 'Shine The Light' law gives you the right to request once a year (and for free) if we've shared any of your personal information with third parties for their direct marketing purposes. You can ask for the details of this sharing, including the third parties' names and addresses, for the previous calendar year. To request this information, please email us.
Minor’s Right to Remove Posted Content. If you're under 18, and if you live in California, and use our Services, you can ask us to remove any personal data you've posted publicly on our Services. Just contact us with your account's email address and mention that you're a California resident. We'll remove your data from public view on the Services, but it might not be fully deleted from all our systems, like backups.
To make any of these requests, please email to privacy@procomps.gg. If we deny your request and you disagree with our decision, you can appeal by email. We’ll review your appeal and respond within 45 days, explaining our final decision and the reasons behind it.
We are always happy to answer your queries regarding privacy. Please contact us by sending an e-mail to privacy@procomps.gg.
If you have a complaint, please get in touch with us so that we can resolve any concerns.
f you are located in the UK, you also have a right to lodge a complaint with the Information Commissioners Office if you believe your personal data has been processed in a way which does not comply with the applicable law. You may call the ICO helpline on 0303 123 1113 or visit their website here.
you are located in the EEA and you believe we are unlawfully processing your personal information, you may also complain to your Member State data protection authority.
If you have any general questions about the Website or the information we collect about you and how we use it, you can contact us directly via privacy@procomps.gg.
We respect the privacy of children and encourage parents and guardians to take an active role in managing their children's online activities. If you are under 18, please make sure you have consent from your parent and/or guardian before using the Services. We do not knowingly collect personal information from children in connection with those Services. This Policy is written for adults and assumes age-appropriate information will be made available for younger users.
We only collect the personal information necessary to provide and improve our Services. We do not use children's data in ways that could be detrimental to their well-being.
If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at privacy@procomps.gg.
Please note that children and their parents or guardians have rights regarding the personal information we hold, including the right to access, correct, and delete this information. We provide clear instructions on how you can exercise these rights.
Our Services may contain links to other external websites. We aren’t responsible for the practices, policies or content of such websites and suggest that you check their privacy policies to ensure that you are happy to continue browsing. We do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services or applications.
We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties including other websites, services, or applications that may be linked to or from Services. You should review the policies of such third parties and contact them directly to respond to your questions.
We update and amend our Policy from time to time.
Where we make minor changes to our Policy, we will update our Policy with a new effective date stated at the end of it. Our processing of your information will be governed by the practices set out in that new version of the Policy from its effective date onwards.
Where we make major changes to our Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible). We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose. Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
Welcome to ProComps Ltd.’s Privacy and Data Protection Policy (“Privacy Policy”).
At ProComps Ltd. (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.
This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.
The individuals from whom we may gather and use data can include:
- Customers
and any other people that the organisation has a relationship with or may need to contact.
This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.
ProComps Ltd. is your Data Controller and is responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us by email to hello@procomps.gg or by post to 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). The responsibilities below may be assigned to an individual or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:
- Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information);
- Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
- Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
- Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
- Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
- Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
- Maintain a record of all categories of processing activities carried out on behalf of a Controller;
- Cooperate, on request, with the supervisory authority in the performance of its tasks;Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
- Notify the Controller without undue delay after becoming aware of a Personal Data Breach.
“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
- Profile/Identity Data: This is data relating to your first name, last name, gender, and date of birth.
- Contact Data: This is data relating to your phone number, addresses, email addresses, and phone numbers.
- Marketing and Communications Data: This is your preference in receiving marketing information and other information from us.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
There are a number of justifiable reasons under the GDPR that allow the collection and processing of Personal Data. The main avenues we rely on are:
- “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
- “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
- “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
- “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name so that we have a record of who to contact moving forwards.
We will only use your Personal Data when the law allows us to.
You will receive marketing and new content communications from us unless you specifically request that you would not like to receive these communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.
We will only use your Personal Data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
- Right to be informed. You have a right to be informed about our purposes for processing your personal data, how long we store it for, and whom it will be shared with. We have provided this information to you in this policy.
- Right of access. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (also known as a "data subject access request"). See section 4.5 below for more details on how you can make a data subject access request.
- Right to rectification. You have a right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Right to erasure. You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Right to object. You can object to the processing of personal data we hold about you. This effectively allows you to stop or prevent us from processing your personal data. Note that this is not an absolute right and it only applies in certain circumstances, for example:
i. Where we are processing your personal data for direct marketing purposes.
ii. Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
iii. In some cases, we may continue processing your data if we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
iv. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Right to data portability. You have the right to request the transfer of your personal data to you or to a third party. If you make such a request, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
If you wish to make a request under any of these rights, please contact us at hello@procomps.gg.
You may delete your account at any time – this will remove your account page from our systems and our related software.We guarantee this will delete all stored data.
You can access information associated with your account by logging into your account you created with us.
Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to
hello@procomps.gg.
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limited number of employees with special access rights to such systems and are bound by confidentiality obligations. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately, no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of ProComps Ltd. to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
You can ask us to stop sending you marketing messages at any time by clicking the "Unsubscribe" link at the bottom of the marketing e-mails.
Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We may also share Personal Data with interested parties in the event that ProComps Ltd. anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.
If ProComps Ltd. is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations, your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).
We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
You must not use ProComps Ltd. unless you are aged 16 or older. If you are under 16 and you access ProComps Ltd. by lying about your age, you must immediately stop using ProComps Ltd.
This website is not intended for children and we do not knowingly collect data relating to children.
Your information may be stored and processed in the US or other countries or jurisdictions outside the US where ProComps Ltd. has facilities. By using ProComps Ltd., you are permitting and consenting to the transfer of information, including Personal Data, outside of the US.
We keep our Privacy Policy under review and will place any updates here. This version is dated 4 August 2023.
By using ProComps Ltd., you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of ProComps Ltd. will constitute your express acceptance of any modifications to this Privacy Policy.
All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. You are more likely to get a reply if your request or question is polite, and reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website, etc.).
Our staff are not authorised to contract on behalf of ProComps Ltd., waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a ProComps Ltd. address contradicts anything in this policy, our terms or any official public announcement on our website or is inconsistent with or amounts to a waiver of any ProComps Ltd. rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the ProComps Ltd. legal department.
Please also see our Terms of Service which set out the terms, disclaimers, and limitations of liability governing your use of ProComps Ltd.
© All rights reserved by ProComps. ProComps isn’t endorsed by Riot Games and doesn’t reflect the views or opinions of Riot Games or anyone officially involved in producing or managing League of Legends. League of Legends™ and Riot Games are trademarks or registered trademarks of Riot Games, Inc.
