Last Updated: December 11, 2024

‍1. Introduction

‍Welcome to Checkmate Live (“we”, “us”, “our”). Checkmate Live is a free-to-play platform where you can play chess online for free and join online chess tournaments. Optional in-app purchases are available. The platform is rated M (Mature), and users must be 18+ to access all features. To participate in certain activities and features, KYC (Know Your Customer) verification, linked to a Web3 wallet, is required.We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy and Compliance Policy outlines how we collect, use, store, and protect your data across all our services, including competitive play, in-game trading, VOIP services, payment processing, and general website usage.

By accessing or using our Website (www.checkmate.live) and services, you agree to the collection and use of information in accordance with this policy. If you disagree with any part of this policy, please do not use our Website or services.

‍2. Definitions

Personal Information (PI): Any information that can identify an individual, directly or indirectly, including but not limited to name, email address, contact details, and identification documents.
‍KYC (Know Your Customer): Procedures used to verify the identity of our users to prevent fraud, money laundering, and other illicit activities.
‍Bitometric Data: Biometric data is information collected during the KYC process to verify your identity securely. It also includes audio and video landmarks for delivering Avatars in-video and for fair play.
‍GDPR: General Data Protection Regulation, applicable in the European Union.
‍AUSTRAC: Australian Transaction Reports and Analysis Centre, responsible for AML/CTF compliance in Australia.
‍Wallet Address (Non-Custodial): A unique identifier associated with your Web3 wallet, used for linking your account and ensuring compliance with regulatory requirements. The wallet is non-custodial, meaning we do not have access to manage your funds.

‍3. Information We Collect
‍We collect and store the following information about you:

‍A. Identifying Information
‍Name
Date of Birth
Country
FIDE ID Number
Federation ID Number
IP Address
Email Address
Device Identifier
Alias
Online Identifier
Account Name
Wallet Address (Non-Custodial)

‍B. Characteristics of Protected Classifications

‍Age
Sex

‍C. Internet or Other Electronic Activity

‍Information regarding your interaction with our Website or application

‍D. Audio and Video Information
‍Audio, electronic, thermal, olfactory, or other similar informationVoice Recordings

‍E. Sensitive Personal InformationGeolocation InformationNational OriginImagery of the Iris, Retina, Face, Landmarks Keystroke Patterns or RhythmsGait Patterns or Rhythms

‍F. Biometric DataInformation collected during the KYC process to verify your identity securely

‍4. How We Use Your Information
‍We will only use, disclose, or otherwise process your Personal Data when there is a genuine reason to do so for a permitted purpose. We may collect and use your Personal Data and information together with other information for the purposes of:

‍Processing Transactions: Including online payments.
‍Account Management: Setting up, operating, and managing your account.Fair Play Enforcement: Addressing and investigating violations.
‍Profiling: Building your Fair Play Score and analyzing performance metrics.
‍Legal Compliance: Complying with our legal and regulatory duties.
‍Customer Research: Carrying out customer research, surveys, and analyses.
‍Marketing and Promotion: Providing you with information about promotional offers and our products and services, where you have consented.
‍Fraud Prevention: Carrying out age and identification checks (which might include your personal information and/or data being sent to and verified by a third-party record holder). This process may involve the third-party record holder verifying the personal information you have provided us with against the information that this third party holds, and monitoring transactions to prevent fraud, irregular betting, money laundering, cheating, or detecting suspicious behavior.Tax Compliance: Determining your liability to taxes where applicable.
‍Customer Care: Dealing with and managing complaints and other customer care activities including Fairplay reports
‍Partner Activities: Your participation in activities conducted by our business or Federation partners, provided that you have consented to this participation.
‍Protection of Rights: Protecting and defending the rights or property of Checkmate Live, this Website, or partner websites.
‍Regulatory Obligations: Otherwise complying with our legal or regulatory obligations.

‍Important Notice: If you choose not to provide your Personal Data, it may prevent us from meeting legal obligations, fulfilling a contract, or performing services required to run your account. Not providing your Personal Data may mean we are unable to provide you with the products or services you request.

‍A. Integrity and Compliance
‍
Sharing with Integrity Bodies:
We may share your personal information with the Esports Integrity Commission, Federation partners, or legal authorities when required to ensure fair play, prevent fraud, or comply with local regulations and legal obligations.
‍Fair Play Enforcement: Sharing information with integrity bodies helps us maintain a fair and competitive environment by addressing violations such as cheating, collusion, or other unethical behaviors.
‍Fair Play Reporting: In the event of a Fair Play report, we retain and process the relevant user information to investigate and enforce fair play standards. A dedicated file is created and retained solely for integrity purposes, ensuring compliance with our legal obligations and maintaining the integrity of our platform.
‍
‍B. Profiling and Automated Decision-MakingProfiling:
We use the information that we collect about you for profiling purposes, including evaluating performance, behavior, and adherence to fair play standards.
‍Automated Decision-Making: Decisions related to fair play enforcement, bans, and integrity scores are made through automated processes without human intervention.

‍C. Marketing and Promotion
‍From time to time, we may provide you with promotional offers, newsletters, or other information about our products and services. However, if you wish not to receive communications about our latest offers, products, and services, please contact us. Our electronic communications also include an “unsubscribe” link which will enable you to opt out of receiving further marketing materials.

‍5. Legal Basis for Processing
‍Our processing of your personal information is based on the following legal grounds:

‍Consent: Obtained when you provide personal information voluntarily and register on Checkmate Live
‍Legal Obligation: Processing necessary to comply with laws and regulations, including AML/CTF Fairplay and gambling laws.
‍Contractual Necessity: Processing required to fulfill our contractual obligations to you.
‍Legitimate Interests: Processing necessary for our legitimate business interests, such as improving services and ensuring security, provided it does not override your privacy rights.

‍6. Data RetentionWe retain your personal information for the following periods:
‍Personal Information: Retained for as long as necessary to fulfill the purposes outlined in this policy, comply with legal obligations, resolve disputes, and enforce our agreements.
‍KYC Data: Retained for a minimum of seven years to comply with AML/CTF regulations and other applicable laws.
‍FIDE ID or Federation ID: Retained indefinitely to prevent multiple accounts and circumventing Fairplay rulings 
‍Anonymized Data: Retained indefinitely for analytical and research purposes, ensuring no personal identification is possible.
‍Game  Data: Retained indefinitely integrity purposes 
‍Fair Play Reports: Information related to Fair Play reports is retained as long as necessary to investigate and enforce fair play standards, complying with legal requirements.
‍Information Storage:Whenever your data is kept by

‍Checkmate Live, we will ensure that it is appropriately protected and only used for acceptable purposes. We take all reasonable steps to ensure that your Personal Data is kept secure and protected.We will keep your data for the period that you are a customer of Checkmate Live. To comply with Checkmate Live's legal and regulatory requirements and internal risk management procedures, we will also retain information for a period of time (generally not more than seven years) after the closure of your account, including (but not limited to) for reasons relating to anti-money laundering, fraud prevention, Fairplay or our responsible gambling obligations.Once your information is no longer required for these purposes, we will take all reasonable steps to destroy the information or ensure that it is de-identified. All such information will be held in accordance with this Privacy Policy.Your Personal Data may be kept longer if we cannot delete it for technical reasons.

‍7. Data Deletion

A. User Requests
‍You may request the deletion of your personal data at any time. While we strive to honor such requests, certain information may be retained to comply with legal obligations (e.g., AML/CTF laws) or for legitimate business purposes.

‍B. Automated Deletion
‍Once verification is complete, unnecessary KYC data is automatically deleted unless required by law, while essential information (e.g., FIDE ID, Wallet Address) is retained for compliance and fair play records.

‍C. Data Minimization
‍Where feasible, we anonymize or pseudonymize retained data to protect your privacy while maintaining necessary records.
‍
‍D. Specific Deletion Scenarios
‍
‍Upon a valid account deletion request:
‍
‍Deleted Data: Personal identifiers (e.g., name, email address), transaction history, communication records.
‍Retained Data: Due to obligations under the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act 2006 and regulatory requirements, certain information is retained for seven years, including transaction records and compliance-related identifiers (e.g., FIDE ID, Wallet Address).
‍Fair Play Reports: Information related to Fair Play reports is retained as outlined above.

‍8. User Rights

‍Under the Privacy Act 1988 (Cth), General Data Protection Regulation (GDPR), and other applicable laws, you have the following rights:

‍Access: Request access to your personal information.
‍Correction: Request correction of inaccurate or incomplete data.Deletion: Request deletion of your personal data, subject to legal exceptions.
‍Restriction: Request restriction of processing under certain conditions.
‍Portability: Request transfer of your non-game personal data to another service.
‍Objection: Object to processing based on legitimate interests.
‍Opt-Outs: Opt out of tracking your location, profiling, and automated decision-making.
‍Limitation on Portability: Please note that the
‍Portability right is limited to non-game personal data.

‍Gameplay data, which includes your interactions, game history, and performance metrics, is not eligible for data portability as it is considered intrinsic to the functioning and integrity of the Checkmate Live platform.

‍Exercising Your Rights: To exercise these rights, please contact our Data Protection Officer (DPO) as outlined below. We may require verification of your identity before processing your request.

‍9. KYC Procedures

A. Identity Verification and Compliance

Light KYC (Basic Platform Use):

Information Collected: Email address, country of residence, date of birth, sex, FIDE ID (optional for casual play, required for FIDE-rated games), and Wallet Address (Non-Custodial).

‍Full KYC (Advanced Features & High-Stakes Activities):Information Collected: Government-issued ID (for identity verification), proof of age, Anti-Money Laundering (AML) compliance data, verification for FIDE ID synchronization, and Wallet Address (Non-Custodial).

‍B. Third-Party KYC Provider (Sumsub)
‍All sensitive verification documents are processed securely by Sumsub, a trusted third-party KYC provider. We do not store these documents on our servers.

‍C. Sumsub Security Overview

Sumsub employs robust security measures to protect your sensitive information, including
‍Encryption: All data transmitted to and from Sumsub is encrypted using industry-standard protocols.Access Controls: Strict access controls ensure that only authorized personnel can access your verification data.Data Processing: Sumsub processes your data in compliance with GDPR and other relevant data protection regulations.Regular Audits: Sumsub undergoes regular security audits and assessments to maintain high security standards.Data Minimization: Only necessary data is collected and processed to fulfill KYC requirements, ensuring your privacy is maintained.

‍10. Security MeasuresWe have implemented the following measures to protect and safeguard your personal information:

‍Secure Data Vault System: Sensitive user data is stored in a robust data vault, providing an extra layer of protection against unauthorized access.
‍Data Hashing and Pseudonymization: Sensitive data, including biometric and identity information, is hashed (e.g., using SHA-256 with salting). This process complies with GDPR’s pseudonymization principles and enhances security by ensuring the original data cannot be reconstructed.
‍Encrypted Storage and Transmission: Data is encrypted at rest and in transit, ensuring end-to-end security.
‍Usercentrics Privacy Management: Usercentrics enables you to manage your privacy preferences, offering full control over data permissions and meeting GDPR’s transparency and consent requirements.
‍Restricted Access and User Permissions: Only authorized personnel can access user data, and solely for legitimate purposes such as compliance, fair play enforcement, or operational support.
‍Data Redundancy and Backup: To ensure data integrity and availability, we maintain redundant systems and regular backups across our server locations.
‍Regular Audits: We conduct regular security audits and assessments to identify and mitigate potential vulnerabilities.
‍Incident Response: We have established protocols to respond promptly to data breaches or security incidents, including notifying affected users and relevant authorities as required by law.
‍
‍11. Compliance with Gambling Laws
‍
Jurisdictional Compliance: Checkmate Live operates in compliance with the gambling laws of the jurisdictions in which it is available. This may include obtaining necessary licenses and adhering to specific regulatory requirements.

‍Nature of the Game: Chess is fundamentally a pure game of skill, relying on strategic thinking, planning, and expertise. However, we acknowledge that in some jurisdictions, certain skill-based gaming activities may be mistakenly classified as gambling. In such cases, we ensure that our operations comply with the local regulations and legal definitions of gaming and gambling. We continuously monitor and adapt to regulatory changes to maintain our compliance and uphold the integrity of our platform.
‍
‍Age Verification: We implement age verification processes to prevent underage participation, as mandated by gambling regulations.
‍
‍Fair Play: We maintain fair play standards and conduct regular audits to ensure the integrity of our platform.

‍12. Third-Party Services

Sumsub: Our KYC data is handled by Sumsub, a trusted third-party service provider specializing in data verification and management. Sumsub complies with relevant data protection laws and employs robust security measures.
‍
‍Payment Processing: Checkmate Live does not hold credit card information. Our payment processor is Wert.io. Wert is a licensed virtual currency provider and is regulated by relevant authorities in the USA and Estonia. Wert.io's website is operated by SHA2 Solutions Inc. and SHA2 Solutions OU (Reg. code 14952299).
‍Other Partners: We may engage other third-party service providers for various functions (e.g., customer support). These partners are required to adhere to our privacy and security standards.

‍13. International Data Transfers

‍Your data may be stored and processed in multiple locations to ensure optimal service performance and compliance with local regulations. Specifically, our servers are located in :
‍
Australia
Mumbai, India
Frankfurt, Germany
Singapore
UAE
United States

‍
Data Localization and Compliance:

Data Storage Locations: By operating servers in Mumbai, Frankfurt, Australia, and other parts of India, we ensure that your data is stored in regions that comply with international data protection standards. As our player base grows, we may implement additional Points of Presence (POPs) in other regions to enhance service performance and comply with evolving local data protection requirements.
‍Cross-Border Data Transfers: When your data is transferred across borders, we implement appropriate safeguards to ensure compliance with applicable data protection laws. These safeguards include Standard Contractual Clauses (SCCs), ensuring that your data remains protected regardless of where it is processed.
‍Jurisdictional Adherence: We adhere to the data protection requirements of each jurisdiction where our servers are located. This includes compliance with the General Data Protection Regulation (GDPR) in the EU, the Privacy Act 1988 (Cth) in Australia, and the Information Technology Act 2000 in India.

‍Security Measures Across All Locations:

Consistent Security Standards: All our server locations adhere to the highest security standards, including encryption, secure access controls, and regular security assessments.
‍
‍Data Redundancy and Backup: To ensure data integrity and availability, we maintain redundant systems and regular backups across our server locations.
‍Local Data Protection Laws: We respect and comply with the data protection laws specific to each server location, ensuring that your personal information is handled lawfully and securely.
‍
‍14. Privacy Guardrails
‍Explore Checkmate Live's privacy protection measures for online chess. Learn how we safeguard player data while ensuring fair play in tournaments.

‍High Standards of Integrity and Privacy:
At Checkmate Live, we prioritize protecting sensitive information while maintaining a secure, fair, and enjoyable gaming environment. Our approach to handling biometric data from the KYC process and managing integrity scores reflects our unwavering commitment to upholding the highest standards of integrity and privacy.Integrity Score Management:
User integrity scores are managed securely and updated in real-time. This ensures that scores are always current, accurately reflecting each player’s conduct and adherence to fair play standards. We use robust security measures to protect these scores, preserving the fairness and credibility of our gaming environment.

‍AI Anti-Cheat System:
Our AI system detects and prevents unfair practices, ensuring a level playing field.

‍In-Game Video Monitoring:
‍
Tournament footage is retained for:
‍
Fair Play Reviews
Dispute Resolution
Inclusion in Checkmate Live’s Video Library
Broadcast
Promotional Purposes

Peer to Peer personal video is not retained.

By using Checkmate Live, players consent to the recording and retention of tournament footage as stated in our Terms of Service and Privacy Policy. This practice aligns with industry norms, enhancing community engagement and platform integrity.
‍
‍Hashing Biometric Data:
Biometric data collected during KYC is hashed, ensuring that the original biometric information cannot be reconstructed. This method protects against privacy breaches, even in the unlikely event of a data compromise.
‍Handling Proof of Identity Data:
We do not store proof of identity documents from the KYC provider. Once verification is complete, sensitive documents and detailed personal data are not retained on our servers.
‍Web3 Wallet Integration:
Your Web3 wallet may serve as a unique ID after KYC verification, aligning with Web3’s ethos of user privacy and control while ensuring regulatory compliance.
‍Quantum Avatars:
Play anonymously with Quantum Avatars that safeguard your identity. If you join tournaments requiring transparency, you will follow fair play identification rules.
‍Benefits of Our Approach:
This method strikes the right balance between user privacy and the need for platform security. By protecting sensitive information and managing integrity scores carefully, we maintain a trustworthy, transparent, and fair competitive landscape while ensuring that our users’ personal data is treated with the utmost care.

‍15. Compliance with Gambling and Online SafetyA. Gambling ComplianceLicensing and Regulation:

Checkmate Live operates under the necessary licenses and adheres to the regulations set forth by the gaming authorities in each jurisdiction where it is available. We ensure that all gambling-related activities, including tournaments with prizes, comply with local laws to maintain legal operation and user trust.
‍Responsible Gaming:We promote responsible gaming practices by providing resources and tools to help users manage their gaming activities. Features include setting deposit limits, self-exclusion options, and access to support organizations for individuals experiencing gaming-related issues.
‍Anti-Fraud Measures:Robust anti-fraud systems are in place to detect and prevent fraudulent activities. This includes monitoring for suspicious transactions, implementing secure payment gateways, and conducting regular audits to ensure the integrity of financial operations.
‍Age Verification:Strict age verification processes are enforced to prevent underage users from participating in gambling-related activities. This includes mandatory KYC procedures for users engaging in high-stakes or prize-based tournaments.

‍B. Online Safety MeasuresUser Conduct Policies:Checkmate Live has established clear user conduct policies to maintain a respectful and safe gaming environment. Prohibited behaviors include harassment, hate speech, cheating, and any form of discrimination. Violations of these policies may result in account suspension or termination.
‍Content Moderation:Our platform employs both automated and human moderators to oversee user interactions and content. This ensures that inappropriate content is swiftly identified and addressed, maintaining a positive community atmosphere.
‍Data Security and Privacy:We implement advanced security protocols to protect user data from unauthorized access, breaches, and other cyber threats. This includes end-to-end encryption, regular security assessments, and adherence to international data protection standards such as GDPR.
‍Secure Communication Channels:All communication between users and the platform is secured using encrypted channels. This prevents eavesdropping and ensures that sensitive information remains confidential.
‍Incident Response and Reporting:We have established comprehensive incident response procedures to handle security breaches or violations of our policies. Users are encouraged to report any suspicious activities or inappropriate behavior, and we act promptly to investigate and resolve such incidents.
‍Cybersecurity Training:Our team undergoes regular cybersecurity training to stay informed about the latest threats and best practices. This ensures that we are well-equipped to protect both our platform and our users from evolving cyber risks.
‍User Education: We provide educational resources to inform users about online safety best practices. This includes guidance on creating strong passwords and safeguarding personal information.

‍16. Account Deletion Policy

A. Introduction
‍Checkmate Live respects user privacy and complies with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and related global standards. This Account Deletion Policy explains how personal information (PI) is managed when users request account deletion, as well as when certain data may be retained.
‍B. Requesting Account Deletion
‍Users can request account deletion at any time by following in-platform instructions or contacting our Support team at privacy@checkmate.live.
‍C. Scope of Deletion
‍Upon a valid deletion request, we remove all Personally Identifiable Information (PII) that directly identifies the user (e.g., name, email, payment info, profile images, non-required communication logs). However, if a player has registered a FIDE ID or a similar federation identifier, that identifier (not PII) will be retained and linked to a username to maintain competition integrity and historical accuracy.
‍D. Participation in Prize Tournaments and Regulatory Requirements
‍If a user participated in prize tournaments, certain records may be kept to comply with:Australian state/territory gaming and wagering laws,The Competition and Consumer Act 2010 (Cth) and the Australian Consumer Law,Taxation and financial record-keeping requirements,International regulations where events are hosted.Only the data necessary for these obligations is retained, and it is securely disposed of or de-identified after the legally mandated period.
‍E. Justification for Retention
‍Retaining federation identifiers and event results is standard in sporting and competitive contexts to preserve historical records and uphold fairness. No additional PII is retained beyond legal or operational necessity.
‍F. Enforcement of Bans and Platform Integrity
‍Minimal non-PII data (e.g., hashed identifiers) may be retained to enforce bans and prevent previously banned users from rejoining, consistent with industry standards.
‍G. Legal and Regulatory Compliance
‍Data may be retained to fulfill legal requirements (taxation, anti-fraud, gaming regulations). Retention periods meet Australian and relevant international standards.
‍H. Data Security and Protection
‍All retained data is secured with industry-standard measures, encryption, and access controls, complying with APP 11 and other applicable regulations.I. Transparency and UpdatesThis policy is part of our broader Privacy Policy. We will notify users of any material changes and provide further details on retention periods upon request.
‍J. Contact and DisputesFor questions or concerns, contact our Support team or DPO at privacy@checkmate.live. If issues remain unresolved, users may contact the OAIC, relevant Australian authorities, or the appropriate authority where events are hosted.
‍K. Periodic Review
‍We review and update this policy periodically to ensure continued compliance with legal requirements and industry standards.
‍
‍17. Benefits of Our Approach
‍This method strikes the right balance between user privacy and the need for platform security. By protecting sensitive information and managing integrity scores carefully, we maintain a trustworthy, transparent, and fair competitive landscape while ensuring that our users’ personal data is treated with the utmost care.

‍18. Anonymous Play for Enhanced Privacy

Anonymous Usernames:

Checkmate Live Players: No real names are required for general gameplay, casual tournaments, or most platform activities.
‍FIDE Players: Real names and identity verification are required only for FIDE-affiliated events, in accordance with FIDE regulations. Identity checks are conducted via our secure Know-Your-Customer (KYC) provider, Sumsub.

This balanced approach allows players to enjoy a secure and anonymous experience while adhering to necessary regulatory standards where applicable.

‍19. Video Privacy and Retention Policy1-to-1 Private Matches:
No video is recorded for private matches, ensuring that your personal gaming sessions remain confidential.

‍Tournament Footage:
Tournament footage may be recorded and retained for:
Fair Play Reviews
Dispute Resolution
Inclusion in Checkmate Live’s Video Library
Broadcast
Promotional Purposes

‍By using Checkmate Live, players consent to the recording and retention of tournament footage as stated in our Terms of Service and Privacy Policy. This practice aligns with industry norms, enhancing community engagement and platform integrity.

‍20. Web3 Wallet Integration
‍Your Web3 wallet may serve as a unique ID after KYC verification, aligning with Web3’s ethos of user privacy and control while ensuring regulatory compliance.
‍Wallet Address (Non-Custodial): Your Web3 wallet address is used solely for linking your account and facilitating participation in activities that require enhanced verification. We do not have custody of your wallet or access to manage your funds.
‍
‍21. Quantum AvatarsPlay anonymously with Quantum Avatars that safeguard your identity. If you join tournaments requiring transparency, you will follow fair play identification rules.
‍
‍22. Commitment to GDPR Compliance
‍Checkmate Live combines advanced technologies, robust security measures, and strict adherence to regulatory standards. We adapt to market-specific requirements and incorporate state-of-the-art privacy solutions to ensure a user-centric, legally compliant platform.

‍23. Handling Biometric Data and Integrity ScoresHashing Biometric Data:
Biometric data collected during KYC is hashed, ensuring that the original biometric information cannot be reconstructed. This method protects against privacy breaches, even in the unlikely event of a data compromise.

‍Proof of Identity Data:
We do not store proof of identity documents from the KYC provider. Once verification is complete, sensitive documents and detailed personal data are not retained on our servers.

‍Integrity Score Management:
Integrity scores are securely updated and stored, ensuring that fairness and credibility remain central to the gaming experience.

‍24. Compliance with Gambling and Online Safety(This section is duplicated and already covered as Section 15. To avoid redundancy, ensure there is only one comprehensive section covering compliance with gambling and online safety.)

‍25. Data Transfers
‍We maintain servers around the world, and your information may be processed on servers located outside the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy. We also comply with certain legal frameworks relating to the transfer of data.

‍A. Cross Border Data Transfer
‍Given that the Internet is a global environment, using the Internet to collect and process Personal Data necessarily involves the transmission of data on an international basis. Some of the data processors engaged to process Personal Data may be based outside of Australia.A cross-border transfer of your Personal Data will not take place unless:

‍Necessity for Verification or Contract: The transfer is necessary for the verification of your identity or suitability to become a client of Checkmate Live, the performance of a contract between you and Checkmate Live, or for the implementation of pre-contractual measures taken in response to a request by you; or Necessary for Third-Party Contract: The transfer is necessary for the conclusion or performance of a contract concluded in your interest between Checkmate Live and a third party; or All of the Following Apply:The transfer is for your benefit;It is impracticable to obtain your consent to the transfer; andIf it were practicable to obtain such consent, you would be likely to give it; or Reasonable Steps for Protection: Checkmate Live has taken reasonable steps to ensure that the information which it has transferred will not be held, used, or disclosed by the recipient of the information inconsistently with the Australian Privacy Principles. We may also disclose personal information to other companies within associated or subsidiary companies and to business partners, or successors in title to our business, which may be based outside of Australia.

‍B. Important Notice: Cross-Border Disclosures
‍By providing your personal information to Checkmate Live, you consent to such disclosures to overseas recipients.Where we do provide your personal information to overseas recipients, we will take reasonable steps to ensure that the overseas recipients undertake to protect your privacy. However, by consenting to such disclosure, you acknowledge that Checkmate Live will not be accountable under the Privacy Act for any breach of your privacy by the overseas recipient nor will you be able to seek redress under the Privacy Act for any use or breach by an overseas recipient. You also acknowledge that the overseas recipient may not be subject to similar laws or principles as under Australian privacy law. Where we disclose personal information or transfer data to overseas recipients, the recipients are most likely to be located in the countries specified in Appendix 1 of this Privacy Policy. This list of countries is not exhaustive.

‍26. Cookies
‍A cookie is a small piece of data sent from a website and stored on your device by your browser. This Website collects cookies. Please visit our Cookie Policy to learn more about what cookies we collect, why we collect them, and how to change your cookie settings.

‍27. Children's PrivacyThis Website is intended for use by a general audience and does not offer services to children. Should a child whom we know to be under 15 send personal information to us, we will use that information only to respond to that child to inform him or her that they cannot use this Website.

‍28. Analytics Programs
‍This Website uses Google Analytics to collect information about you and your behaviors. If you would like to opt out of Google Analytics, please visit Google Analytics Opt-Out.

‍29. Sale of Your Information
‍We do not sell your personal information

‍30. Third-Party Websites
‍This Website may contain hyperlinks to websites operated by parties other than us. We provide such hyperlinks for your reference only. We do not control such websites and are not responsible for their contents or the privacy or other practices of such websites. It is up to you to read and fully understand their Privacy Policies. Our inclusion of hyperlinks to such websites does not imply any endorsement of the material on such websites or any association with their operators.

‍31. Do Not Track
‍Do Not Track is a preference you can set on your browser to inform websites that you do not want to be tracked. We do not support Do Not Track ("DNT"). You can either enable or disable Do Not Track by visiting the Preferences or Settings page of your browser.

‍32. Transferring DataWe plan to transfer data to Poland, Singapore, and the United Arab Emirates. This means that your information may be processed in a country outside of Australia and it may be accessible to law enforcement authorities and national security authorities of that country and jurisdiction.As our player base grows, we may implement additional Points of Presence (POPs) in other regions to enhance service performance and comply with evolving local data protection requirements. This ensures that your data remains protected and complies with international data protection standards.

‍33. Changes to Privacy Policy
‍We reserve the right to amend this Privacy Policy at any time. We will notify you of any changes to this Privacy Policy by posting the updated Privacy Policy to this website or application.We may update this policy from time to time, so please review it frequently.Any changes we may make to our Privacy Policy in the future will be posted on this page and any such changes will become effective upon posting of the revised Privacy Policy.If any material changes are made to this Privacy Policy, we will use reasonable endeavours to inform you in advance by email, notice on the Website, or other agreed communication channels. We will communicate the material changes to you in advance, giving an appropriate amount of time for you to consider and understand the changes before they become effective.Your continued use of the Website and the Checkmate Live products or services after you have been notified of the changes constitutes your understanding and acceptance of those changes.If you decline to accept the changes to the Privacy Policy, or otherwise disagree with the changes, please do not use the Website or otherwise provide us with your personal information. However, please note that if you do not provide us with certain personal information, we may not be able to continue to provide some or all products and services.

‍34. Contact Us
‍If you have any questions, concerns, or requests regarding this policy or our data practices, please contact our Data Protection Officer (DPO):
‍Email: privacy@checkmate.live
Phone: +61421001766
Mailing Address:
Checkmate Live
143A King St, Mascot, Sydney, NSW 2020
Australia

Website: www.checkmate.live

‍35. Example Communication for Data Deletion Requests
‍
Subject: Your Account Deletion Request

‍Hi [User’s Name],We have received your request to delete your Checkmate Live account and the associated personal data. We take your privacy seriously and have processed your request accordingly.
‍Data Deleted:
‍Personal identifiers (e.g., name, email address)
Transaction history
Communication records
‍Data Retained:
Due to our obligations under the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act 2006 and requirements from regulatory bodies, we are required to retain certain information for a period of seven years.

This includes:Transaction records
Compliance-related identifiers (e.g., FIDE ID, Wallet Address)

Additionally, in the event of a Fair Play report, relevant user information is retained and processed to investigate and enforce fair play standards. A dedicated file is created and retained solely for integrity purposes, ensuring compliance with our legal obligations and maintaining the integrity of our platform. Please be assured that the retained data is securely stored and used solely for compliance and integrity purposes. It is not accessible for other uses and is protected under our stringent data security policies.

If you have any further questions or require additional assistance, please feel free to contact our Data Protection Officer at privacy@checkmate.live.Thank you for your understanding.Best regards,
Checkmate Live Team
[Contact Information]

‍36. Complaints
‍Should you have any privacy-related concerns or complaints, please contact us via our designated privacy email address privacy@checkmate.live. We will confirm receipt of your complaint within two business days. We will investigate your complaint and reply within seven business days of receiving your complaint. If you are dissatisfied with our response, you can refer your complaint to the Australian Information Commission via enquiries@oaic.gov.au.

‍37. VOIP Privacy and Retention Policy

A. IntroductionCheckmate Live may offer Voice Over Internet Protocol (VOIP) services in the future to facilitate real-time audio communication between users. This VOIP Privacy and Retention Policy outlines how we collect, use, store, and protect VOIP-related data to ensure your privacy and comply with applicable laws.

‍B. VOIP Data Collection
‍
Voice Communications: We may record VOIP conversations for purposes such as service quality improvement, security monitoring, and compliance with legal obligations.
‍Consent: By using our VOIP services, you consent to the recording and processing of your voice communications as described in this policy.
Metadata:We collect metadata related to VOIP calls, including call duration, timestamps, and participant information.

‍C. How We Use VOIP DataService Facilitation:
To enable and improve VOIP communication features on our platform.
‍Quality Assurance: To monitor and enhance the quality of VOIP services.
‍Security and Compliance: To detect and prevent fraudulent activities, ensure compliance with legal obligations, and protect the rights and property of Checkmate Live and its users.
‍Research and Development: To analyze usage patterns and develop new features.
‍
‍D. VOIP Data Sharing and Disclosure
Internal Sharing: VOIP data may be accessed by authorized personnel within Checkmate Live for the purposes outlined above.
‍Third-Party Service Providers: We may share VOIP data with third-party service providers who assist in delivering VOIP services, provided they adhere to strict confidentiality and security standards.Legal Obligations: We may disclose VOIP data to law enforcement agencies, regulatory bodies, or other authorities as required by law.
Business Transfers: In the event of a merger, acquisition, or sale of assets, VOIP data may be transferred to the acquiring entity.

‍E. Data Storage and Security Encryption:
All VOIP communications are encrypted both in transit and at rest using industry-standard encryption protocols.
‍
‍Secure Storage: VOIP recordings and metadata are stored in secure servers with access controls to prevent unauthorized access
‍Data Retention:VOIP recordings are retained for a period of 30 days unless a longer retention period is required for legal or security purposes.Metadata is retained for 90 days to support operational and security needs.

‍Data Deletion: After the retention period, VOIP data is securely deleted or anonymized to prevent identification of individuals.

‍F. User Rights and Control Access: Users can request access to their VOIP recordings and metadata by contacting our Data Protection Officer (DPO).

‍Deletion: Users may request the deletion of their VOIP recordings, subject to legal and operational constraints.
‍Opt-Out: Users can choose to disable VOIP recordings by adjusting their account settings, though this may limit certain service functionalities.
‍G. Cross-Border Data Transfers International Processing: VOIP data may be processed and stored in countries outside of your residence. We ensure that such transfers comply with international data protection laws and that appropriate safeguards, such as Standard Contractual Clauses (SCCs), are in place.User Consent: By using our VOIP services, you consent to the transfer of your VOIP data to countries with different data protection laws.

H. Compliance and Best Practices

Regulatory Compliance:
‍
‍Checkmate Live adheres to all applicable VOIP-related data protection regulations, including GDPR, CCPA, and others as relevant.Regular Audits: We conduct regular audits of our VOIP data processing practices to ensure compliance and identify areas for improvement.Employee Training: Our staff undergo training on VOIP privacy and security best practices to ensure the protection of your data.
‍I. Transparency and UpdatesPolicy Updates: Any changes to our VOIP Privacy and Retention Policy will be updated in this section and notified to users through our website or other com
munication channels.
‍User Notifications: Users will be informed of significant changes to how VOIP data is handled, and necessary consents will be obtained where required.J. Contact InformationFor any questions, concerns, or requests related to our VOIP Privacy and Retention Policy, please contact our Data Protection Officer (DPO):Email: privacy@checkmate.live
Phone: +61421001766
Mailing Address:
Checkmate Live
143A King St, Mascot, Sydney, NSW 2020
Australia
Website: www.checkmate.live

‍38. Payment Processing

A. Introduction
‍At Checkmate Live, we prioritize the security and privacy of your financial information. We do not hold or store your credit card information. Instead, all payment processing is handled by our trusted third-party provider.
‍B. Payment Processor Details
Payment Processor: Wert.ioLicense and Regulation: Wert is a licensed virtual currency provider regulated by relevant authorities in the USA and Estonia.Operating Entities:SHA2 Solutions Inc.SHA2 Solutions OU (Reg. code 14952299)

‍C. How We Use Payment Information
Transaction Facilitation: Wert.io processes all transactions on our behalf, ensuring secure and efficient payment handling.
‍No Data Retention: We do not retain any credit card information or payment details. All sensitive financial data is exclusively managed by Wert.io.
‍Compliance: Wert.io adheres to all relevant financial regulations and standards to protect your payment information.
‍D. Data Sharing and Disclosure
Internal Sharing: Checkmate Live does not have access to your credit card information or detailed payment data.
‍Third-Party Service Providers: Only Wert.io has access to your payment information, and they are required to adhere to strict confidentiality and security standards.

‍E. User Rights and Control

Access and Correction: Any issues related to your payment information should be directed to Wert.io. Please contact their support for assistance.
‍Opt-Out: You can choose to discontinue using our services by cancelling any active transactions or subscriptions through your Wert.io account.

‍39. Advertisers and Analytics ProvidersCheckmate Live may use third-party Web analytics services in connection with the Checkmate Live  Services. These service providers use a variety of tracking technologies such as cookies to analyze how users use the Checkmate Live  Services. The information collected (described above in “Automatically Collected Information”) may be shared with or collected directly by these services and processed to evaluate your use of the Checkmate Live  Services.Checkmate Live  may also work with third-party ad networks, advertisers, and advertising analytics providers to target (and measure the performance of) ads to you both on and off the Checkmate Live  Services. We may share with these third parties (or they may directly collect) data such as cookie and mobile ad identifiers in order to engage in advertising activity (including to understand how you respond to advertisements and to serve relevant ads). Checkmate Live  also works with third parties to serve ads to you off Checkmate Live ’s Services. When we do so, we may share information such as your email address or resettable device identifier for that advertising partner to “match” to other information that may have about you.Advertisers on Checkmate Live , or representatives or service providers working on their behalf (“Checkmate Live  Advertisers”), sometimes use technology to serve ads that appear on our services directly to your device. They automatically receive certain data, such as your IP address, when this happens. They may also use cookies (or similar technologies) to measure the effectiveness of their ads and to personalize ad content. This Privacy Notice does not apply to, and we cannot control the tracking technologies and activities of Checkmate Live  Advertisers and you should consult their respective privacy policies.

40. Merger or Sale
‍In the event that Checkmate Live , or some or all assets related to the Checkmate Live  Services are acquired by or merged with a third-party entity or in connection with a contemplated change-of-ownership transaction, we reserve the right, in any of these circumstances, to transfer or assign the information that we have collected from users as part of that merger, acquisition, sale, or other change-of-control event, including in the course of diligence

41. Checkmate Live  (in-person) Events:
Checkmate Live  holds live (in-person) events that may include creators, speakers, and exhibitors. These events will be photographed, recorded, and streamed, both by Checkmate Live  and by others, and these materials may be used for promotional purposes.

42. Third-Party Services and WebsitesThe Checkmate Live Services may link to third-party websites or services. The privacy practices of those third parties are not governed by this Privacy Notice. We encourage you to review the privacy policies of these third-party websites and services to understand their practices.If you connect to a third-party service (such as Discord, Telegram, or Whatsapp) through the Checkmate Live  Services or otherwise link your Checkmate Live  account with a third-party service, you are requesting and authorizing us to share or grant access to information on your behalf (such as your username, the fact that your connection originated from the Checkmate Live  Services, and other relevant usage and diagnostic information) with such third party. We may also send information about the content you watch or your activities on the Checkmate Live  Services to such third parties. For example, we may make information available to app developers, game developers, and game publishers and sponsors to facilitate purchases and awards of digital goods, such as games and in-game items.42. Checkmate Live  may disclose user information if we believe in good faith that such disclosure is necessary to comply with Australian. state and federal laws or other applicable laws around the world (for example, in the country of your residence), or respond to a court order, judicial or other government request, subpoena, or warrant in the manner legally required.

45. Retention of Your Information
‍Checkmate Live  maintains data related to your usage of Checkmate Live  for as long as it is required in order to fulfill the relevant purposes described in this Privacy Notice, as may be required (or permitted) by law such as for tax and accounting purposes, or as otherwise communicated to you. Once you have asked us to close your account and delete your profile information, we will delete all information that we are not required or permitted to retain by law. Checkmate Live  also reserves the right to disclose information that we believe, in good faith, is appropriate or necessary to protect Checkmate Live  from potential liability or from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third-party claims, or allegations; protect the security or integrity of the Checkmate Live  Services; or protect the rights, property, or safety of Checkmate Live , our users, or others.

‍46. Data Security
‍Checkmate Live  uses a variety of managerial, technical, and physical measures to protect the integrity and security of your information. These measures may vary based on the sensitivity of your information. However, no security precautions or systems can be completely secure. We cannot ensure or warrant the security of any information you transmit to Checkmate Live , and you do so at your own risk. We cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

47. Information from Other Sources: We may obtain additional information from third parties and sources other than the Checkmate Live  Services. For example, we may obtain additional information from advertisers, games or services you use, or social media networks (such as Discord, Steam, or YouTube) for which you have approved our access. When you access the Checkmate Live  Services through social media networks or when you connect the Checkmate Live  Services to social media networks, you are authorizing Checkmate Live  to collect, store, and use such additional information and content in accordance with this Privacy Notice. We may also obtain information from third-party services (such as Riot or Steam) regarding your use of such services, including about your use of the content you choose to broadcast through the Checkmate Live  Services. We use this information to supplement the information we collect about you in order to provide more relevant, safer experiences for you with the Checkmate Live  Services and improve the Checkmate Live  Services, analytics, and advertising. If we combine or associate information from other sources with information that we collect through the Checkmate Live  Services, we will treat the combined information in accordance with this Privacy Notie.

‍48. Conclusion
‍At Checkmate Live, we prioritize your privacy and are committed to maintaining the highest standards of data protection and regulatory compliance. By using our platform, you trust us with your personal information, and we strive to honor that trust through transparent practices and robust security measures.For any specific legal concerns or detailed guidance, please consult a qualified legal professional.