Effective Date: January 29, 2021
1. How We Collect And Use Your Personal Data
1.1. The information below explains what data we may collect, how we use it, and which recipients it might be shared with. Your account information Account information (information provided by you when creating an account on the Platform):
- Username and password
- Email address
- Username alias and Profile picture
How we use your account information
Recipients of your account information
Additionally, we rely upon our legitimate interests for this processing activity, being our interests in promoting the success of our business by providing you with a quality service with additional functionalities relating to your account with us. We use the services of vendor SendGrid (Twilio Inc.), so that we can help users automatically recover their accounts if a password is lost. SendGrid receives your email address from us. You can find out more about their privacy practices here: https://www.twilio.com/legal/privacy
Your Support / enquiry information
Support / enquiry information (information we receive when you get in touch with us for support)
- Account/name alias
- Email address and other personal data you may choose to send to us
How we use your Support / enquiry information
Recipients of your Support / enquiry information
We may share this information with vendors who assist us with managing customer services enquiries.
Your User-generated content and feedback
Your User-generated content and feedback (information that you provide to us by way of feedback, or submit into the Platform such as comments or messages, or your virtual experiences or assets submitted to the Platform):
- Virtual experiences you submit into the Platform for access by others
- Virtual assets and items you submit into the Platform for access by others
- Direct messages and group messages
- Likes and shares
- Referrals and
- Other user-generated content or feedback you submit into the Platform
How we use your User-generated content and feedback
Recipients of your User-generated content and feedback
Please be aware that your submitted content, such as reviews and comments and your virtual experiences or store-submitted assets, will be viewable by third parties including other Platform users.
Your order and purchase-related information
Order and purchase-related information (processed when you make an order or purchase via the Platform):
- Your order details
- Your Platform account details (as set out in the first row above)
How we use your order and purchase-related information
Recipients of our order and purchase-related information
We utilize third party payment vendors to process payments and we do not directly take receipt of your card or bank details.
Analytics (collected from your device and interaction with the Platform):
- How often you use the Platform, and timestamps of usage (such as for particular features)
- Which content, pages and areas you go to and which features you use/interact with, view or purchase and other similar information relating to your usage and engagement with the Platform
- Your IP address, and device identifiers communicated by your device
- Your Platform Unique User Identifier
- Device and browser operating system, version, make and model
How we use your analytics
We may process this information (on its own or together with your Platform account information) so that we can: (i) understand usage of our services and improve our services, such as by prioritising serving content in our services to you which we think is more interesting for you; (ii) identify and solve problems or bugs; and (iii) develop new services or content we think will be of greatest interest to our users.
Recipients of your analytics
We do this in pursuit of our legitimate interests, being our commercial interests in ensuring that our service functions well so that you and other users have the best experiences (promoting the success of our business). We use vendor Sentry (Functional Software, Inc.) to assist us with collecting and understanding analytics information, so that we can more quickly identify and solve problems, for example. You can find out more about Sentry’s privacy practices here: https://sentry.io/privacy/.
Your Competition and promotion related entry data
Your competition and promotion related entry data (where you may enter a competition / prize promotion with us (such as over email or over social media)):
- your entry contact information (e.g. social media username or email)
- information submitted as part of your entry
- information submitted so we can process your entry (such as your address, if we need to send you a prize)
How we use your Competition and promotion related entry data
We may from time to time operate prize promotions and competitions (without any obligation to do so). If we do, your personal data processed in connection with that activity would be processed on the basis of performance of a contract (being the competition/prize promotion terms of entry).
Recipients of your competition and promotion related entry data
Your newsletters, updates and marketing messages
Newsletters, updates and marketing messages (information provided by you when signing up to our newsletter or marketing emails, if you choose to sign-up):
- Email address
How we use your newsletters, updates and marketing messages
Consent-based mailing lists – We may process your data to make suggestions and recommendations to you and other users of the Platform about: (i) news and updates relating to us, our partners, products, services and content; (ii) content, goods and services that may interest you; and (iii) other promotional activity and events we think may be of interest. ‘Soft opt-in’ mailing lists- In some instances (such as with some of our existing customers) the law may permit us to process your personal information in order to send information to you by marketing messages that we think is of interest for you on the basis of our legitimate interests, being our legitimate business interests in marketing our activities and promoting the success of our business and the Platform, content, products and services. We may process your information for this purpose.
Recipients of your newsletters, updates and marketing messages
If the information is not of interest for you, you can opt-out at any time by emailing us. We may share your data with email and marketing message vendors to assist us. Newsletters, updates and marketing messages (information provided by you when signing up to our newsletter or marketing emails, if you choose to sign-up):
- Email address
Consent-based mailing lists
We may process your data to make suggestions and recommendations to you and other users of the Platform about: (i) news and updates relating to us, our partners, products, services and content; (ii) content, goods and services that may interest you; and (iii) other promotional activity and events we think may be of interest.
‘Soft opt-in’ mailing lists
In some instances (such as with some of our existing customers) the law may permit us to process your personal information in order to send information to you by marketing messages that we think is of interest for you on the basis of our legitimate interests, being our legitimate business interests in marketing our activities and promoting the success of our business and the Platform, content, products and services. We may process your information for this purpose. If the information is not of interest for you, you can opt-out at any time by emailing us. We may share your data with email and marketing message vendors to assist us.
2. Your Rights In Relation To Your Personal Data
2.1. You have certain rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest, in response to any requests submitted by you to us:
- for a copy of personal data we are processing about you and/or to have inaccuracies corrected; to restrict, stop processing, or to delete your personal data
- for a machine-readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer
- to make a complaint to a data protection regulator. You may contact them at: https://ico.org.uk/concerns/
2.2. To make a request in relation to any of the aforementioned rights, please send your request to firstname.lastname@example.org.
2.3. There may be circumstances where we will ask you for your prior consent in respect of our use of your personal data for direct marketing. Where we rely upon your consent to do this activity, you can withdraw your consent at any time by messaging us at email@example.com. We hope that you would like to receive our updates, but we do not want to send you emails that are not of interest for you. If you would like to be removed from our mailing list please let us know by clicking unsubscribe at the bottom of any marketing email that you receive from us.
3. Disclosure Of Your Personal Data
3.1. We will share your personal data with third parties only in the ways that are described in this policy.
3.2.Group, suppliers, subcontractors, service providers, application stores.
We keep your personal data confidential, but may disclose it to any member of our corporate group, to application store providers, our personnel, suppliers (such as our customer services, hosting and payment processing suppliers) or subcontractors insofar as it is reasonably necessary for the purposes set out in this Policy. Additionally, we may need to disclose information to application store providers in order to either: (i) ensure fulfilment of an order you have made or to process a cancellation or refund; or (ii) detect and prevent fraud.
In addition, we may disclose your personal data to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
3.4.Potential acquirers or investors.
If we are involved in a merger, acquisition, or sale of all or a portion of our business or assets, the personal data we hold may be included as part of that sale, in which case you will be notified via email, your account and/or a prominent notice in Platform of any changes in ownership or use of your personal data, as well as any choices you may have.
We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of us, our personnel or customers, or others.
3.6. We only permit our suppliers and subcontractors to process your personal data for specified purposes and in accordance with our instructions. All our third-party service providers are required to take appropriate security measures to protect your personal data.
4. Data Retention
4.1. We will only hold data about you for as long as necessary, bearing in mind the purpose for which that data was collected, or as otherwise described in this Policy.
4.2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
5.1. We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of the Platform taking into account the likelihood and severity those risks might pose to the rights and freedoms of Platform customers and our website visitors.
5.2. In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal data transmitted, stored or otherwise processed by us.
6. International Data Transfers
6.1. We use a hosting services provider who are based in the Republic of Ireland. We may also utilise hosting services in the USA (such as for our USA-based users). Where we use data processors which are outside the UK or EEA, where necessary there are agreements in place to ensure that personal data is processed using appropriate safeguards that meet the requirements of data protection laws. Such appropriate safeguards may include standard data protection clauses adopted by a data protection regulator and/or those approved by the European Commission, such as the European Commission’s standard contractual clauses.
6.2. If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this Policy, please let us know by contacting us at firstname.lastname@example.org.
7.1. If you follow a link from the Platform to any third party websites, please be aware that those websites may have their own privacy policies. We do not accept any responsibility or liability for those websites. Please check the policies of any third party websites before submitting any personal data to those websites.
7.2. We may make changes to this Policy in the future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes by email.
All questions, comments or enquiries should be directed to us through our customer services options available within our services or by email to email@example.com.