1. Data controller
- Legal name
- Virtual Sports Industry, FZCO
- License No.
- DMCC-982829
- Registered address
- DMCC Business Centre, Uptown Tower, Dubai, United Arab Emirates
Virtual Sports Industry, FZCO (hereinafter, the “Controller”, “Virtual Sports” or “BeFootball”) is a company validly incorporated under the laws of the United Arab Emirates.
2. Scope
This Privacy Policy governs the processing of personal data associated with the virtual reality video game VSSoccer – Virtual Sports Soccer (the “Video Game” or “VSS”), its linked application VSS: Virtual Sports Soccer App (the “App”) and the SideQuest Series tournament (the “Tournament”). In particular, it applies to:
- Registration and maintenance of the account in the application linked to VSSoccer – Virtual Sports Soccer.
- Access to rankings, matchmaking and competitive features.
- Registration and participation in the 1vAI qualifying phase.
- The compilation of the ranking, the tie-breaking criteria, the selection of the Top 8 and the management of the final 1v1 bracket.
- Operational coordination, check-in and communications through the official Discord server.
- The validation of results, incident management, fraud prevention, application of sanctions and resolution of claims.
- The identification of potential winners, the verification of their eligibility and the processing of the prize pool.
- The publication and communication of rankings, qualifiers, results and winners in accordance with the Official Rules.
This Policy does not replace the privacy policies applicable to third-party services, such as Meta, Discord, SideQuest VR, payment providers or other services used by the user, which may process data independently in accordance with their own terms and policies.
3. Minimum age and participation of minors
VSS and the Tournament are not directed at children under thirteen (13) years of age. In addition, each user must meet any higher minimum age required by their country of residence, by Meta, Discord, the App, the device or the platform used.
Users who have not reached the applicable age of majority may only register, use the application, participate in the Tournament and be eligible for prizes if they have the prior, valid and verifiable consent of their parent or legal guardian.
The Controller may request reasonable proof of age and, where applicable, of consent and legal representation. If the requested proof is not provided, or it is detected that the user does not meet the applicable requirements, the registration may be cancelled, access may be limited, the user may be excluded from the ranking or the Tournament, their results may be deleted or delivery of the prize may be denied.
The Controller does not intend to deliberately collect personal data from children under thirteen (13) years of age. If such a registration is detected, reasonable measures will be taken to delete the data and cancel the participation, without prejudice to any applicable legal retention obligations.
4. Personal data collected
Depending on the user's relationship with VSS, the App and SideQuest, the following categories of data may be processed.
4.1 Registration data
We may process the data provided by the user when completing the registration form, including:
- Full name
- Email address
- Nickname, alias or Meta user identifier (Meta Quest username)
- Date of birth or age confirmation
- Country of residence
- Discord username and data necessary to link it with the participant account.
- Record of acceptance of the Official Rules, T&C, Privacy Policy and other applicable documents.
- Confirmation or proof of parental consent, where applicable.
- Any additional information reasonably requested to manage the registration
4.2 Technical, usage and competitive participation data
During use of the video game, the linked application and participation in the Tournament, we may process technical, usage and competitive activity data, including:
- Device ID, device model, operating system version and application version
- Session duration, game statistics, in-match actions and use of features
- Data relating to the matches played during the qualifying phase in 1vAI format.
- Number of wins obtained.
- Number of goals scored and other data necessary to apply the ranking and tie-breaking criteria.
- Number of matches played and, where applicable, matches deemed valid.
- Position obtained in the qualifying ranking.
- Ranking among the top eight participants and the position or seed assigned for the final phase.
- Data relating to participation in the final phase in 1v1 format, including pairings, results, wins, losses, tie-breaker matches and final position.
- Data relating to check-in, availability and actual participation in the final phase, where necessary for the organization of the Tournament.
- Technical records, logs, telemetry, match identifiers, incidents, disconnections and other information reasonably necessary to verify results, resolve claims or investigate possible irregularities.
- Reasonable technical evidence intended to detect or investigate cheating, exploits, result manipulation, use of bots, automation, multiple accounts, impersonation or any conduct contrary to the Tournament rules.
4.3 Data derived from VR use
Use of the Meta Quest device may generate body-movement data, hand tracking and, on compatible models, eye tracking.
BeFootball does not access such biometric data directly; it is managed directly by Meta Platforms, Inc. under its own privacy policy. However, the gameplay data collected by the Video Game may incorporate performance metrics derived from such movements, such as in-game movements, actions performed, scores, times, accuracy, results or in-match performance, always for the purpose of providing the service, managing the Tournament, compiling the rankings, validating results, resolving incidents, preventing fraudulent conduct and improving the operation and user experience of the video game.
4.4 Parent or legal guardian data
When the participant is under 18 years of age or has not reached the applicable age of majority, we may process data of their parent or legal guardian to verify consent and, where applicable, manage participation in the Tournament or the delivery and payment of prizes.
This data may include:
a. Full name of the parent or legal guardian. b. Email address. c. Contact phone number, if necessary. d. Identity document or equivalent information, where necessary to verify the authorization. e. Relationship to the minor participant. f. Statement of parental or guardian consent or authorization.
4.5 Payment data (prize pool winners only)
- Full name
- Official identity document, passport or equivalent document
- Proof of tax residency
- Bank details or payment platform information (PayPal or equivalent) necessary to transfer the prize
- Identification details and authorization of the parent or legal guardian when the winner is under 18 years of age
- Information necessary to verify compliance with the participation and eligibility requirements.
- Any additional information required by legal, tax, accounting, anti-fraud, anti-money laundering or compliance obligations
This data is collected exclusively from the Tournament prize pool winners and is processed solely to verify identity and eligibility, confirm compliance with the Official Rules, manage the delivery and payment of the prize and meet any applicable legal obligations.
Mandatory data and consequences of not providing it: The data marked as mandatory during registration or requested as necessary to use the application, access the competitive features, participate in the Tournament, verify age, prove parental consent, validate results or receive a prize will be necessary for those purposes.
Refusal to provide it, insufficient proof, or the communication of incomplete, inaccurate, false, outdated or unverifiable information may prevent registration, access to certain features, participation in the Tournament, inclusion or continuation in the ranking, qualification for the final phase, the validation of results or the delivery and payment of prizes.
5. Purposes of processing and legal basis for processing
Provision of the Service
We will process the registration, technical and usage data necessary to enable access to the Video Game and the App, enable account, ranking, matchmaking and competitive participation features, maintain the stability and security of the service, resolve incidents and ensure its correct operation.
Tournament management and ranking
We will process the registration, gameplay, match, win, goals-scored, score, performance, ranking and other competitive information necessary to organize and administer SideQuest Series, apply the Official Rules, compile the ranking for the 1vAI phase, apply the tie-breaking criteria, determine the eight (8) qualified participants, assign the positions or seeds for the final phase and record the results of the 1v1 bracket.
Likewise, we may process the information necessary to manage check-in, verify the availability of participants, coordinate pairings, create matches from the backend, resolve incidents and determine the final ranking and the winners.
Age verification and parental consent
We will process the data necessary to verify that the user meets the applicable age requirements and, when they are a minor or have not reached the corresponding age of majority, verify that they have the prior, valid and verifiable consent of their parent or legal guardian.
Identity verification (winners and prize payment)
When the user is a winner or potential winner, we will process the data necessary to verify their identity, residency and eligibility, confirm compliance with the participation requirements, manage the corresponding communications, process the prize payment and comply with the applicable legal, tax, accounting, fraud-prevention, anti-money-laundering or compliance obligations.
When the winner is a minor or has not reached the applicable age of majority, we may require the intervention, express authorization and identification details of their parent or legal guardian to verify eligibility and process the prize payment.
Operational communications related to the video game and the Tournament
We may contact Participants and, where applicable, their parents or legal guardians, by email, Discord or other means provided, to send communications necessary for or reasonably related to the operation of the Video Game, the App or the Tournament.
These communications may include registration confirmations, instructions for access to or linking with the application, information about rankings and standings, announcement of the Top 8 participants, check-in instructions, match coordination and creation, schedule or calendar changes, incidents, result validation, claims, communication of winners or information relating to the verification and payment of prizes.
Service improvement and analytics
We may analyze technical data, errors, usage metrics, game statistics, performance data, aggregated information and general usage patterns for the purpose of improving the design, operation, playability, stability, performance, security and user experience of the Video Game and the App.
Protection of the tournament and fraud prevention
We may process data to detect, prevent or investigate cheating, exploits, bots, result manipulation, unauthorized use, rule violations, system abuse or any conduct that may affect the integrity of the Tournament.
Such information may be used to validate or void results, resolve claims, apply the measures set out in the Official Rules and, where applicable, disqualify participants.
AML compliance (international payments)
Compliance with a legal obligation
VR biometric data (if applicable)
This will always require the explicit consent of users
The processing of personal data is based, as applicable, on the following legal bases:
a. Performance of the contractual or pre-contractual relationship, to manage registration, allow access to and use of the Video Game and the App, apply the Terms and Conditions, administer the tournament and manage the delivery of prizes.
b. User consent, when the user voluntarily accepts to participate, receive certain non-essential communications or grant specific authorizations where necessary.
c. Consent of the parent or legal guardian, when the user is a minor or has not reached the age required by applicable regulations and it is necessary to allow their registration, participation, acceptance of applicable documents or, where applicable, prize management.
d. Legitimate interest, to improve the service, maintain security, prevent fraud, protect the integrity of the Tournament, analyze technical metrics and defend our rights.
e. Compliance with legal obligations, when necessary to meet tax, accounting, regulatory, fraud-prevention, anti-money-laundering, compliance obligations or requests from authorities.
When processing is based on consent, it may be withdrawn at any time, without affecting the lawfulness of processing carried out previously.
The withdrawal of consent or the lack of proof of parental consent may prevent participation in the Tournament, access to certain features or the delivery of prizes where such consent is necessary.
6. Retention periods
- Tournament registration and participation data: up to six (6) months after the end of the Tournament, unless such data forms part of an active account in the App or is necessary for the continued provision of the service, in which case it will be retained for the duration of the contractual relationship or while the account remains active.
- Ranking and results data: up to twelve (12) months after the end of the Tournament for statistical, analytical and results-verification purposes, in anonymized form.
- Identity, verification, parental consent and winner payment data: retained for as long as necessary to prove the validity of the minor's participation and, where applicable, for the periods necessary to address liabilities, claims, and to comply with legal, tax, accounting and AML compliance obligations.
- Technical device data: maximum twelve (12) months, after which it is anonymized or deleted, unless it is necessary to retain it for a longer period to investigate incidents, prevent fraud, resolve claims or comply with legal obligations.
- Data processed on the basis of consent: retained until the user, or their parent or legal guardian where applicable, withdraws such consent or requests its deletion, provided there is no other legal basis to retain it.
7. Recipients of the data and international transfers
The Controller does not sell or transfer users' personal data to third parties for their own commercial purposes.
We may disclose or allow access to personal data to the following categories of recipients, provided it is necessary for the purposes described:
- Technology, hosting, infrastructure, forms, analytics, security, support, maintenance, backend, rankings, matchmaking or App-operation providers.
- Distribution or access platforms for the Video Game, such as Meta Quest, SideQuest VR or other equivalent platforms, when necessary to provide the service or manage participation in the Tournament.
- Email providers and communication tools, including Discord, when used to manage operational communications, announce qualifiers, carry out check-in, coordinate matches, resolve incidents or communicate information related to the Tournament.
- Payment providers, banking entities, PayPal, Wise or other equivalent systems, solely when necessary to manage the delivery and payment of prizes.
- Legal, tax, accounting advisors, auditors, consultants or compliance service providers, when necessary to provide their services or comply with applicable obligations.
- Administrative, tax, regulatory, judicial or law-enforcement authorities where there is a legal obligation, a valid request or it is necessary for the formulation, exercise or defense of claims.
- Group entities, technical collaborators, development studios, providers or operational partners involved in the provision of the Service, operation of the video game or the application, management of the Tournament, technical support, result validation, fraud prevention or prize payment.
When SideQuest VR processes data obtained directly through its own websites, platforms, services or tools, such processing will be governed by its own terms and privacy policies.
Given that the Video Game, the App and the Tournament may be available to users located in different countries, and that the Controller is located in the United Arab Emirates, personal data may be processed or accessible from jurisdictions other than the user's country of residence.
When it is necessary to carry out international data transfers and a third party processes personal data on behalf of the Controller, adequate safeguards will be applied in accordance with applicable regulations, including contractual agreements, technical and organizational security measures, access limitation and the selection of providers that offer reasonable safeguards.
8. Third-party platforms and services
The Video Game is distributed, run and accessed through third-party platforms, including Meta Quest, SideQuest VR, Discord or other equivalent platforms. Such platforms may process the user's personal data independently, in accordance with their own terms of use and privacy policies.
BeFootball does not control all processing carried out directly by such platforms, nor is it responsible for their own privacy practices.
In particular, access to the Video Game may take place through Meta Quest, while SideQuest VR may act as a platform for publication, promotion or access to the corresponding listing. Likewise, Discord may be used as a channel for communication and operational coordination of the Tournament.
The user and, in the case of minors, their parent or legal guardian, must review the terms and privacy policies of the relevant platform before accessing the game or using the device.
9. Users' rights
The user may exercise the following rights at any time by sending their request to contact@be.football:
- Right of access to their personal data
- Right to rectification of inaccurate data
- Right to erasure (“right to be forgotten”)
- Right to restriction of processing
- Right to data portability
- Right to object to processing
- Right to lodge a complaint with the competent data protection authority, where applicable.
- Right to withdraw consent at any time, without affecting the lawfulness of prior processing.
When the user is a minor, these rights may also be exercised by their parent or legal guardian, to the extent applicable under the relevant regulations.
The request must reasonably identify the user and specify the right they wish to exercise. We may request additional information to verify the identity of the applicant or their standing to act on behalf of the minor.
The Controller will respond to requests within the legally applicable period. Where the GDPR applies, that period will generally be one (1) month from receipt of the request, without prejudice to any legally provided extensions.
10. Data security
We apply reasonable technical and organizational measures to protect personal data against destruction, loss, alteration, unauthorized access, improper disclosure or unlawful processing.
These measures may include, as applicable:
- Access control.
- Limitation of internal permissions.
- Encryption or protection of communications.
- Logging and monitoring of incidents.
- Security measures at technology providers.
- Incident review and response procedures.
Although we adopt reasonable measures, no technological system can guarantee absolute security. The user must keep their credentials, devices and associated accounts protected.
In the case of minors, the parent or legal guardian must reasonably supervise the use of the device, the platform account and participation in the Tournament.
11. Data accuracy
The user warrants that the personal data provided is truthful, accurate, complete and up to date.
When the user is a minor, their parent or legal guardian will be responsible for reasonably verifying that the data provided is correct and that participation takes place with their knowledge and authorization.
The user, or their legal representative where applicable, must communicate any relevant change, especially if it is necessary to verify eligibility, contact the participant, validate results or process the payment of prizes.
The communication of false, incomplete or inaccurate data, or of third-party data without authorization, may result in exclusion from the Tournament, the deletion of results, exclusion from the ranking or the final phase and, where applicable, the loss of the right to receive prizes.
12. Commercial communications
Participation in the Tournament does not imply the receipt of commercial communications unrelated to the operation of the service, unless the user has given their consent or another valid legal basis exists.
Communications that are strictly operational or necessary for the operation of the Video Game, participation in the Tournament, ranking management, coordination via Discord, security, result validation, parental consent or prize management will not be commercial in nature.
The user may unsubscribe from promotional communications at any time by writing to contact@be.football
13. Cookies and tracking technologies
The associated website may use technical cookies necessary for its operation and Google Analytics analytical cookies for the statistical analysis of traffic.
The user may reject analytical cookies through their browser settings or through the consent banner present on the website. Disabling technical cookies may limit the functionality of the form.
Specific information about cookies is provided in a separate cookie policy or in the corresponding banner.
14. Data processing
Operations related to the prize pool will be managed from Dubai. In this context, the processing of the data of potential winners and winners will be carried out in accordance with the applicable data protection regulations, including, where applicable, Federal Decree-Law No. 45 of 2021 Concerning the Protection of Personal Data of the United Arab Emirates (PDPL).
The identification, residency, eligibility and payment data of potential winners and winners will be processed for the purpose of verifying compliance with the requirements set out in the Official Rules, managing the payment of the prize, preventing fraud and complying with the applicable legal, tax, accounting, anti-money-laundering or compliance obligations, and will be deleted, blocked or anonymized once the retention periods indicated in clause 6 have elapsed.
15. Modifications to this policy
The Controller reserves the right to modify this Privacy Policy to adapt it to regulatory, technological, operational or Video Game-, App- or Tournament-related changes. Modifications will be notified by publication on the website and, when substantial, by email to registered users. The date of last update appears in the header of the document.