> For the complete documentation index, see [llms.txt](https://asterix-division.gitbook.io/home/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://asterix-division.gitbook.io/home/documentation/privacy-policy.md).

# Privacy Policy

> Last updated: **2025, October 7th**

## 1. Introduction

This Privacy Policy outlines how ASTERIX\* DIVISION (Further: "we", "us", "our") collects, processes, stores, and protects personal data in compliance with the EU General Data Protection Regulation (Further: "GDPR"). The data controller is ASTERIX\* DIVISION.

This document is governed by Lithuanian law.

## 2. How this policy applies 

This policy covers all of the data we collect as an organization. Key sources include of data include:

* Electronic communication platforms (such as email, social media, surveys);
* Competitions & events we host and attend;
* Operation of our staff and members;
* Other generic business activities.

## 3. Collecting your information

As you interact with us, we may collect and process a wide range of personal information about you. This might include:

* Personal contact details such as full name, email address, telephone number(s), gamer tag and social media handles;
* Information about your date of birth, age and gender;
* Any terms and conditions relating to your relationship with us;
* Any communications between ourselves and you;
* Publicly available personal information, including any which you have shared via a public platform, online or on social media;
* Responses and results of surveys;
* Details of any queries, complaints, claims and cases involving both us and yourself including any related communications;
* Photographs, video footage, audio recordings and other content, posts made on social media or which you provide to us;
* Any other personal information you provide to us.

## 4. Data Usage

We have set out the main uses below and indicated the main applicable legal bases of processing:

* Monitor and manage our relationship with you, which may involve communications with you, decisions regarding your relationship with us and in some cases meeting with you. As well as relating to the entry into or performance of a contract with you either directly or indirectly, this will also be in our legitimate interests;
* Hold or conduct promotions or campaigns, create social media posts. In most cases, we may rely on your consent to do this, for example if you provide us with a photograph to use. You also agree that your data may be sent to a third party, which we work with (e.g. sponsors, subcontractors).

## 5. Data Protection Principles

We are committed to protecting personal data in accordance with GDPR principles: 

* Transparency and lawfulness in all processing activities;
* Clear purpose — media captured is only used for agreed purposes;
* Making sure all data captured is correct;
* Making sure data captured is kept for as long as it is needed;
* Making sure all data captured is secure and confidential.

We rely on one or more of the following lawful bases: 

* **Consent:** Explicit consent is obtained for personal data processing;
* **Legitimate interests**: For where our interest in promoting the team does not override individual rights;
* **Contract**: Use of person likeness is covered under contractual obligations;
* **Legal obligations**: For health & safety documentation or incident reports.

## 6. Consent Management 

We will request written or verbal consent before using personal data for the use case of social media posts or mentioned above.

* Consent can be withdrawn at any time by contacting us at <comms@asterixdivision.eu>;
* Personal data of minors: In accordance with the provisions of Article 8 of the European Regulation 2016/679 and the Data Protection Act, only minors aged 15 or over may consent alone to the processing of their Personal Data. If the user is a minor under 15 years of age, the consent of a legal representative will be required so that his/her Personal Data can be collected and processed.

## 7. Data Subject Rights

We respect all rights under the GDPR. Individuals may:

* Request access to their personal data;
* Request removal of their image from our and third-party, if that data has been sent by us, social media & blog posts (where feasible);
* Object to specific processing;
* Withdraw consent at any time;
* Request rectification or restriction.

Requests will be acknowledged within **one month**.

## 8. Data Security

We maintain strong security controls, including

* Secure cloud storage for media and documents;
* Access controls for sensitive files;
* Regular reviews of retention policies and deletion schedules.

## 9. Third Parties and Data Sharing

* Media may be shared with sponsors, event organizers, or media outlets under agreed usage terms;
* We ensure third parties comply with GDPR through Data Processing Agreements (verbal or written);
* We do not sell personal data.

## 10. Policy Review

This policy is reviewed annually or when legal or operational changes require it.

## 11. Contacts

Email: <data@asterixdivision.eu>