Rolex Shanghai Masters: ATP Masters 1000 Tournament, referred below as "RSM", respects the privacy of its online visitors of its services and complies with applicable laws for the protection of your privacy, including, without limitation, the European Union General Data Protection Regulation ("GDPR") and the Swiss and EU Privacy Shield Frameworks.
Wherever we talk about Personal Data below, we mean any information that can either itself identify you as an individual ("Personally Identifying Information") or that can be connected to you indirectly by linking it to Personally Identifying Information. RSM also processes anonymous data, aggregated or not, to analyze and produce statistics related to the habits, usage patterns, and demographics of customers as a group or as individuals. Such anonymous data does not allow the identification of the customers to which it relates. RSM may share anonymous data, aggregated or not, with third parties.
2. Why RSM Collects and Processes Data
RSM collects and processes Personal Data for the following reasons:
a) where it is necessary for the performance of our agreement with you to provide a full-featured website data service and deliver associated Content and Services;
b) where it is necessary for compliance with legal obligations that we are subject to (e.g. our obligations to keep certain information under tax laws);
c) where it is necessary for the purposes of the legitimate and legal interests of RSM or a third party (e.g. the interests of our other customers), except where such interests are overridden by your prevailing legitimate interests and rights; or
d) where you have given consent to it.
These reasons for collecting and processing Personal Data determine and limit what Personal Data we collect and how we use it (section 3. below), how long we store it (section 4. below), who has access to it (section 5. below) and what rights and other control mechanisms are available to you as a user (section 6. below).
3. What Data We Collect and Process
3.1 Basic Account Data
When setting up an Account, RSM will collect your email address and name. You are also required to choose a user name and a password. The provision of this information is necessary to register a RSM User Account. During setup of your account, the account is automatically assigned a number that is later used to reference your user account without directly exposing Personally Identifying Information about you.
3.2 Other Data You Explicitly Submit
We will collect and process Personal Data whenever you explicitly provide it to us or send it as part of communication with others on RSM e.g. in RSM Community Discussions or when you provide feedback or other user generated content. This data includes:
Information that you post, comment or follow in any of our Content and Services;
Information sent through discussion / chat;
Information you provide when you request information or support from us;
Information you provide to us when participating in competitions, contests and community events or responding to surveys, e.g. your contact details.
3.3 Your Use of the RSM Websites and Apps
We collect a variety of information through your general interaction with the websites, apps, Content and Services offered by RSM.
Personal Data we collect may include, but is not limited to, browser and device information, data collected through automated electronic interactions and application usage data.
Likewise, we will track your process across our websites and applications to verify that you are not a bot and to optimize our services.
3.4 Your Use of Website, Apps and other Services
In order to provide you with services, we need to collect, store and use various information about your activity in our Content and Services. "Content-Related Information" includes your username, as well as what is usually referred to as "user statistics". By user statistics we mean information about your preferences, community activity, session time, as well as information about the device you are using, including what operating system you are using, device settings, unique device identifiers, and data regarding errors.
3.5 Tracking Data and Cookies
3.6 Google Analytics
This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on visitors' computers, to help the website operators analyze how visitors use the site. The information generated by the cookie about the visitors' use of the website will generally be transmitted to and stored by Google on servers in the United States.
3.8 Content Recommendations
We may process information collected under this section 3 so that content, products and services shown on the pages of RSM can be tailored to meet your needs and populated with relevant recommendations and offers. This is done to improve your customer experience. Subject to your separate consent or where explicitly permitted under applicable laws on email marketing, RSM may send you marketing messages about products and services offered by RSM to your email address. In such a case we may also use your collected information to customise such marketing messages as well as collect information on whether you opened such messages and which links in their text you followed. You can opt-out or withdraw your consent to receive marketing emails at any time by either withdrawing the consent on the same page where you previously provided it or clicking the "unsubscribe" link provided in every marketing email.
3.9 Information Required to Detect Violations
We collect certain data that is required for our detection, investigation and prevention of fraud, cheating and other violations of the SSA and applicable laws ("Violations"). This data is used only for the purposes of detection, investigation, prevention and, where applicable, acting on of such Violations and stored only for the minimum amount of time needed for this purpose. If the data indicates that a Violation has occurred, we will further store the data for the establishment, exercise or defense of legal claims during the applicable statute of limitations or until a legal case related to it has been resolved. Please note that the specific data stored for this purpose may not be disclosed to you if the disclosure will compromise the mechanism through which we detect, investigate and prevent such Violations.
4. How Long We Store Data
We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or - where the applicable law provides for longer storage and retention period - for the storage and retention period required by law. After that your Personal Data will be deleted, blocked or anonymized, as provided by applicable law.
If you terminate your RSM User Account, your Personal Data will be marked for deletion except to the degree legal requirements or other prevailing legitimate purposes dictate a longer storage.
In certain cases Personal Data cannot be completely deleted in order to ensure the consistency of the website experience or the RSM Community. For instance, discussion you participated in that affect other user' data will not be deleted.
Please note that RSM is required to retain certain transactional data under statutory commercial and tax law for a period of up to ten (10) years.
If you withdraw your consent on which a processing of your Personal Data or of the Personal Data of your child is based, we will delete your Personal Data respectively the Personal Data of your child without undue delay to the extent that the collection and processing of the Personal Data was based on the withdrawn consent.
If you exercise a right to object to the processing of your Personal Data, we will review your objection and delete your Personal Data that we processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or unless applicable law requires us to retain the data.
5. Who Has Access to Data
5.1 RSM and its subsidiaries may share your Personal Data with each other and use it to the degree necessary to achieve the purposes listed in section 2. above. In the event of a reorganization, sale or merger we may transfer Personal Data to the relevant third party subject to applicable laws.
5.3 In accordance with internet standards, we may also share certain information (including your IP address and the identification of RSM content you wish to access) with our third party network providers that provide content delivery network services in connection with RSM. Our content delivery network providers enable the delivery of digital content you have requested, e.g. when using RSM, by using a system of distributed servers that deliver the content to you, based on your geographic location.
5.4 We make certain data related to your RSM User Account available to other users and our partners through the website. This information can be accessed by anyone by querying your username. At a minimum, the public persona name you have chosen to represent you on RSM and your Avatar picture are accessible this way, as well as whether you have received a ban for violating the rules. The accessibility of any additional info about you can be controlled through your RSM Community user profile page; data publicly available on your profile page can be accessed automatically through the website and apps.
While we do not knowingly share Personally Identifying Information about you through RSM such as your real name or your email address, any information you share about yourself on your public RSM Profile can be accessed through the website and apps, including information that may make you identifiable.
5.5 The RSM community includes discussions, message boards, forums and/or chat areas, where users can exchange ideas and communicate with each other. When posting a message to a board, forum or chat area, please be aware that the information is being made publicly available online; therefore, you are doing so at your own risk. If your Personal Data is posted on one of our community forums against your will, please use the reporting function and the RSM contact section to request its removal.
5.7 RSM may release Personal Data to comply with court orders or laws and regulations that require us to disclose such information.
6. Your Rights and Control Mechanisms
The data protection laws of the European Economic Area and other territories grant their citizens certain rights in relation to their Personal Data. While other jurisdictions may provide fewer statutory rights to their citizens, we make the tools designed to exercise such rights available to our customers worldwide.
As a resident of the European Economic Area you have the following rights in relation to your Personal Data:
6.1 Right of Access.
You have the right to access your Personal Data that we hold about you, i.e. the right to require free of charge (i) information whether your Personal Data is retained, (ii) access to and/or (iii) duplicates of the Personal Data retained. You can use the right to access to your Personal Data through the Privacy Dashboard. If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request.
6.2 Right to Rectification.
If we process your Personal Data, we shall endeavor to ensure by implementing suitable measures that your Personal Data is accurate and up-to-date for the purposes for which it was collected.
6.3. Right to Erasure.
You have the right to obtain deletion of Personal Data concerning you if the reason why we could collect it (see section 2. above) does not exist anymore or if there is another legal ground for its deletion. You can request the deletion of your RSM user account via the RSM support section.
As a result of deleting your RSM User Account, you will lose access to RSM services, including the RSM User Account, Subscriptions and information linked to the RSM User Account and the possibility to access other services you are using the RSM User Account for.
We allow you to restore your RSM User Account during a grace period of 30 (thirty) days from the moment you request deletion of your RSM User Account. This functionality allows you not to lose your account by mistake, because of your loss of your account credentials or due to hacking. During the suspension period, we will be able to finalize activities that you may have initiated before sending the RSM User Account deletion request. After the grace period, Personal Data associated with your account will be deleted subject to section 4. above.
6.4 Right to Object.
You also have the right to lodge a complaint at a supervisory authority.
6.5 Right to restriction of processing of your Personal Data
You have the right to obtain restriction of processing of your Personal Data under the conditions set out in article 18 of the GDPR.
6.6 Right to Personal Data portability
You have the right to receive your Personal Data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller under the conditions set out in article 20 of the GDPR. RSM makes your Personal Data available in structured HTML format through the Privacy Dashboard as described above.
6.7 Right to Post-Mortem Control of Your Personal Data
If French data protection legislation is applicable to you, you have the right to establish guidelines for the preservation, the deletion and the transmission of Personal Data after your death in accordance with article 40-1 of the Act No 78-17 of 6 January 1978 on Information, Technology, Data Files and Civil Liberties.
The minimum age to create an RSM User Account is 13. RSM will not knowingly collect Personal Data from children under this age. Insofar as certain countries apply a higher age of consent for the collection of Personal Data, RSM requires parental consent before a RSM User Account can be created and Personal Data associated with it collected. RSM encourages parents to instruct their children to never give out personal information when online.
8. Contact Info
You can contact RSM by visiting our contact us section.
Revision Date: January 9, 2020