MARMALADE GAME STUDIO
Last Updated: 22 May 2020
This Policy sets out the basis on which personal data will be processed by us. This Policy applies to personal data we may collect from you, or that you provide to us, through or in connection with the websites where we make this Policy available (the “Website“). Please read the Policy carefully to understand our views and practices regarding your personal data.
We will only collect and process information about you in accordance with this Policy and we will only use information collected about you in accordance with applicable data protection laws including the EU General Data Protection Regulation 2016 (“GDPR”) and the UK Data Protection Act 2018. Where we decide the purpose or means for the processing of the personal data that you provide when using our Website, we are the “data controller” for the purposes of the GDPR.
You have the right to object to the processing of your personal data, including where your personal data is being processed for direct marketing purposes. Further information on this right, and your other rights, is set out below.
If you have any concerns over privacy, or this Policy contact us at firstname.lastname@example.org.
1. HOW WE COLLECT AND USE YOUR PERSONAL DATA
1.1. The table below explains what data we collect, how we use it, and which recipients it might be shared with.
|Your data||How we use it||Third Party Recipients|
|Support / enquiry information (information we receive when you get in touch with us for support): Name;Contact details (address, phone number, email); andOther personal data you send to us.||We process this information in accordance with the terms of our contract with you (where we need this information to provide our services to you) and also in pursuit of our legitimate interests, being our business interests in responding to your enquiry, maintaining good customer service and improving our services.||We use vendors: (i) Freshworks Inc. for customer support software; and (ii) PartnerHero, Inc. for managing our customer support.|
|Recruitment-related enquiries that you may send to us (such as when you get in touch speculatively, or about a vacancy): Name;Contact details (address, phone number, email);CV and the information you provide within the CV; andOther personal data you send to us.||We process this information in anticipation of the potential for an employment relationship with you (in the event your enquiry is actioned further) and for our evaluation of your appropriateness for certain roles from time to time. For this processing we rely upon the legal bases of both: (i) performance of a contract (being the anticipation of that performance); and (ii) legitimate interests, being our legitimate commercial interests in taking receipt of speculative job enquiries and responses to vacancy posts, to pursue our interests in recruitment and staffing.||None.|
|Website analytics (collected from your device and interaction with our Website): how often you use our Website;which pages and websites you go to / arrived from;your IP address;your geolocation (at a country and/or town/city level only);Technical information about your device (e.g. device type, browser, system, model, memory, wifi status, timestamp and zone, language, mobile carrier);Technical identifiers (e.g. advertiser identifier numbers (IDFA), Google Advertiser ID, Android ID); andEngagement and usage information (e.g. viewing information, information about interactions and usage events, engagement time).||This processing is necessary for us to pursue our legitimate interests, being our business interests in understanding how you use the Website, and to collect statistics, so we might identify problems and also continually improve the Website. We also process this information in order to provide localisation of aspects of our services. For example, your geolocation (at a country level), may be processed so that we can direct you to the appropriate first party platform or store for the country relevant to you. This processing is necessary for us to pursue our legitimate interests of providing a higher-quality, more tailored service and promoting the success of our games.||We use (1) Google Analytics (Google LLC); and (2) IPStack (apilayer GmbH) to help us understand how our Website is used.|
|Email newsletters (the sign-ups where you can best keep up-to-date with the latest Marmalade news and offers): your email address; andother information collected and clearly identifiable to you at the point of your signing up to our email newsletter.||Consent-based mailing lists We may process your data to make suggestions and recommendations to you 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. To the extent required by law, we rely upon your consent in order for us to undertake this data processing activity. You can revoke your consent at any time by letting us know, including by emailing us. ‘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 data in order to send information to you by email 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 our websites, 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 letting us know, including by emailing us.||We use vendor MailChimp (The Rocket Science Group LLC) to help us to administer our email newsletter databases and to send out our newsletters.|
|Competition and promotion related entry data (where you may have entered 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 address);information submitted as part of your entry (e.g. user-generated information); andinformation submitted so we can process your entry (such as your address, if we need to send you a prize).||We may from time to time operate prize promotions and competitions (without any obligation to do so). If we do, your personal data may be processed in connection with that activity, if you choose to enter it. Your personal data would be processed on the basis of performance of a contract (being the competition / prize promotion terms of entry).||We work with vendor Gleam (Crowd9 PTY LTD) to help us to administer our competitions and prize promotions.|
|Attribution – we may direct you (such as via a link on our Website) to the service of an external website. When this happens (such as when you click the relevant link and are redirected), a limited amount of information is processed. This may include: Technical information about your device (e.g. device type, browser, system, model, memory, wifi status, timestamp and zone, language, mobile carrier);Technical identifiers (e.g. advertiser identifier numbers (IDFA), Google Advertiser ID, Android ID);IP address;Engagement and usage information (e.g. clicks on adverts, viewing information, information about interactions and usage events, engagement time);Link source or link destination (e.g. where you arrived at our Website from, or where you clicked from our Website to go to).||We process this information in order to understand to which partners we directed you to from our Website. We process this information on the legal basis of our legitimate interests, being our commercial interests in undertaking efficient marketing activities and being able to identify attribution, promoting the success of our business.||We use vendors such as (1) AppsFlyer (AppsFlyer UK LTD and AppsFlyer Inc.); and (2) Google Tags (Google, LLC) to help us to administer attribution / affiliate link tracking.|
|The following information may be collected via the Facebook Pixel on our Website: IP address; Engagement and usage information (e.g. clicks on adverts, viewing information, information about interactions and usage events, engagement time);Technical information about your device (e.g. device type, browser, system, model, memory, wifi status, timestamp and zone, language, mobile carrier); andTechnical identifiers (e.g. advertiser identifier numbers (IDFA), Facebook ID).||We process your information in this way for the purposes of our targeted and re-targeted marketing activities. In other words, so that we are able to provide you with marketing and advertising that we think may be of more interest for you, through Facebook’s services and sites. We conduct this processing on the basis of our legitimate interests, being our business interests in conducting more efficient marketing which reaches the customers it is potentially more interesting for and in order to therefore promote the commercial success of our games and services.||We use the services of Facebook (Facebook Ireland Ltd.) for this purpose.|
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; and
- 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 email@example.com
2.3 You may request deletion of your personal data by sending an e-mail to firstname.lastname@example.org. Please note that some information may remain in our private records after deletion. We may use any aggregated data derived from or incorporating your personal data but not in any manner that would identify you personally.
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 We keep your personal data confidential, but may disclose it to any member of our corporate group, our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Policy.
3.3 Government authorities. 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 on the website of any changes in ownership or use of your personal data, as well as any choices you may have.
3.5 Enforcement. We may also disclose your personal data 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 our Website taking into account the likelihood and severity those risks might pose to the rights and freedoms of our Website visitors and customers.
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 are a UK company and our servers are located in the United Kingdom and your personal data will be stored in these servers.
6.2 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 approved by the European Commission, such as the European Commission’s standard contractual clauses.
6.3 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 emailing us at email@example.com
7.1 If you follow a link from the Website to any third party websites, you should 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.
7.3 All Website privacy questions, comments or enquiries should be directed to us. We will try to respond to you within 48 hours or otherwise within a reasonable time.
Cookies (and equivalent devices in the context of mobile devices) are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The table below explains the cookies we use and why.
|Cookie||Duration||Purpose/Third Party Access|
|Google Analytics (for our Website)||26 months||This Google LLC cookie is used to collect information about how visitors use our Website. We use the information to compile reports and to help us improve our Website. The cookies collect information in an anonymous form, including the number of visitors to the Website, where visitors have come to the Website from and the pages they visited. Google has access to this information, and uses it for reasons including to be able to provide us with the Google Analytics services and reports. You can find Google’s overview of privacy and safeguarding data here. To opt-out of being tracked by Google Analytics across all websites, visit the following URL: http://tools.google.com/dlpage/gaoptout.|
|Preferences||1 month||We may use this type of cookie to remember information about you such as your preferred language and configuration (where applicable).|
|Gleam||We process personal data collected via Gleam’s plug-in only so long as reasonably necessary for the administration of our record keeping. The data will be deleted by Marmalade thereafter. When you enter a giveaway or competition organised by us via Gleam’s plugin, you become a Gleam customer and you will have control of the duration for which your personal data may be kept. When your account is terminated or expired, all Personal Data collected through the platform will be deleted, as required by applicable law. For more information please refer to: https://gleam.io/privacy||This plugin is used to help us to administer competitions and prize promotions. The Gleam ((Crowd9 PTY LTD) plugin allows you to enter your details and enter those competitions and promotions which we may operate from time to time. Gleam has access to this information so that it is able to provide us with its competition / prize promotion management services. You can find more information about Gleam’s privacy practices here.|
|ipstack||1 month||We use the ipstack (apilayer GmbH) API on our websites. This helps us to understand general location analytics about our website visitors. Ipstack has access to this information so that it can provide us with its geolocation and related services. You can find more information about ipstack’s privacy practices here.|
|AppsFlyer||24 months||We use this cookie / equivalent technology so that we can measure and understand the effectiveness of our marketing, by understanding which of our partners lead you to us – and also to which of our partners we lead you to (by clicking links on our Website). AppsFlyer has access to this information. You can find more information about AppsFlyer’s (AppsFlyer UK LTD and AppsFlyer Inc.) privacy practices here.|
|Google Tags||26 months||We use this cookie / equivalent technology so that we can measure and understand the effectiveness of our marketing, by understanding which of our partners lead you to us – and also to which of our partners we lead you to (by clicking links on our Website). Google Tags (Google, LLC) has access to this information. You can find more information about Google’s privacy practices here.|
|Facebook Pixel||180 days||We use Facebook Pixel for the purposes of our targeted and re-targeted marketing activities. In other words, so that we are able to provide you with marketing and advertising that we think may be of more interest for you, through Facebook’s services and sites. Facebook has access to the information collected by the Facebook Pixel. You can find more information about Facebook’s (Facebook Ireland Ltd.) privacy practices here.|
HOW DO I CHANGE MY COOKIE SETTINGS
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org.
Find out how to manage cookies on popular browsers:
To find information relating to other browsers, visit the browser developer’s website.
Your mobile or tablet device provider may also provide you with additional cookie and browser control options, which may be available to you in your device settings – please consult your device settings for such device-specific controls (if applicable).