Game Academy Limited (we in this document) is committed to protecting your personal data and respecting your privacy. When taking advantage of any service we provide you are strongly advised to take particular note of the way in which your personal data and other data provided by you may become accessible by others as part of the service we provide. This privacy notice has been developed to provide in the clearest possible terms (whilst complying with data protection laws and requirements for notices of this kind) details about how your personal data is used within the service and options available to you to manage the access others have to your personal information.
- INTRODUCTION TO GAME ACADEMY
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- Contacting the Information Commissioners Office
INTRODUCTION TO GAME ACADEMY
Game Academy Limited is the controller and is responsible for your personal data (collectively referred to as "we", "us" or "our" in this policy).
Contacting Game Academy
Our full details are:
- Full name of legal entity: Game Academy Limited (we are a company registered in England and Wales under company number 12070401).
- Postal address: 19 Palace Mansions, Earsby Street, London, United Kingdom, W14 8QW
- Contact details for enquiries: firstname.lastname@example.org; email@example.com;
Third party links
Our Sites may contain links associated with other websites. The links may take you to one of our partner organisations and other parties whose services or products may be of interest to you. The websites and any services that may be accessible through links provided will operate their own privacy policies. Please accordingly take care when visiting any sites of this kind. Note also that Game Academy does not accept liability for these policies or for any personal data that may be collected through these websites or services.
The data we collect about you
At Game Academy we look to engage with Users at all times in a way that is relevant to the User. Please remember that you have the responsibility to update us as when any data that we have collected and hold about you requires updating. This could be your change of mobile telephone number or email address for example. We provide means to update your information at any time. Please let us know if any of your personal details change whilst you are a User of Game Academy.
We may collect, use, store and transfer different kinds of personal data about you. The data we may collect through your use of the Service falls into categories described in the first column of the table below. The second column provides more information about the individual elements of data that may be collected and which comprise the data set for the particular category:-
|Identity Data||Full name as you provide this, date of birth, email address, and gender.|
|Special Category Data||This includes data associated with your race or ethnicity. In order to benefit from the Services we provide you will be required to indicate your race or ethnicity. This is a requirement of a funding agreement that Game Academy is a beneficiary of. Information will only be provided to a third party on an aggregated basis.|
|Profile Data you upload||This is made accessible by you at your discretion but in order to enjoy the benefits of the Service you must allow us to access information associated with the games you play, your skills, qualification and work experience in order to complete a profile of yourself. To assist with this, the Service will invite you to connect your gaming profiles (for example Steam, Playstation and X-box).|
|Profile Data created under a Service we provide to you||Within the Service we provide data will be created from other information you provide or authorise that we collect in order that we may make suggestions concerning courses of study, careers opportunities and other activities that may prove to be of interest to you.|
|Device(s) operated by you||This information is collected automatically.|
|Usage||We may use information in the form of statistics regarding Service usage, but always in the form of anonymised data|
|Marketing and Communications||If you contact Game Academy by email or text, you are indicating that you wish us to communicate with you and we will keep a record of these communications. You may be invited to receive newsletters and other communications and with your consent we will keep a record of your contact information in those circumstances|
|Location||Your location details may be accessible subject to location settings being on. The data will only be accessible when location settings permit.|
|Transactions you enter into with us||We receive data associated with your purchases via our payment providers who are likely to be Stripe and or Paypal.|
We leave it to Stripe or Paypal to manage payments that you make and we do not have access to bank account, credit card or other means of payment information.
We do collect Special Category Personal Data about you but this is currently limited to information about your race or ethnicity. We do not collect any information that would be treated as special category data such as religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We also do not collect information regarding criminal convictions and offences.
How is your personal data collected?
We will collect the following data about you:
- Information you give us. This is information (including Identity, Contact, Decisions to enter into transactions with us and Marketing and Communications Data) you consent to giving us information about you by the way you respond to any requests to provide information within the Service, or by corresponding with us (for example, by email or chat). It includes information you provide should you enter a competition, promotion or survey and when you report a problem with any Service. If you contact us, we will keep a record of that correspondence.
- Your Profile. This, includes information directly provided by you including through your authority to allow us to import the required information from your gaming profiles.
- Information we access from gaming profiles. You are also asked to allow us access to and to collect information from your gaming profiles. The data we take is about the games you play including; the genres, number of games played, tags, time played, achievements and other information that is available to third parties from these profiles.
- Information we extrapolate from other profile information. In addition we process data of this kind to further develop your profile as part of the Service – this creates new personal data that support the provision of our Service to you.
- Location Data. We may in the future use GPS functions within any mobile device that you use to access the service when you have location services on. This will allow us to access the detail of your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to allow us to take advantage of this particular feature, you will be asked to consent to your data being used for this purpose. You can later withdraw your consent at any time by disabling Location Data in your settings.
- Information we receive from other sources including third parties and publicly available sources. We don’t collect information from third parties other than as identified above. Specifically we do not buy third party mailing lists.
How we use your personal data
We will only use your personal data when the law allows us to do so. Typically your personal data is processed by or on behalf of Game Academy in the following circumstances:
- Where we have asked you for consent and you have provided that consent;
- As we are entitled to do because we have a contract with you and need to undertake a processing task in preparation for or in order to perform our contractual obligations owed to you.
- When the processing is considered by us to be permitted in order that we can satisfy our legitimate interests provided that we are also able to demonstrate that we have taken into account as a balancing factor your interests as a data subject and it is still reasonable to proceed;
- When processing the data is expected of us because of a legal or judicial requirement that we should be compliant with.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us or by opting out as detailed in our newsletters and other communications.
Purposes for which we will use your personal data
We summarise below the key activities that are undertaken involving your personal data. As mentioned above by law we must be able to demonstrate that under data protection laws we have a lawful basis for the activity concerned. The final column in the table below provides you with that information.
|Purpose/activity||Type of data||Lawful basis for processing|
|To register you as a Service user||
|Your consent including for the purpose of providing access to certain gaming profiles.|
|To recommend course of study and employment opportunities||
|To provide feedback including recommendations and other guidance within the Services you subscribe to||
Any preferences you express to us
Where enabled in the future geographically relevant information
In order to prepare for and perform a contract with you.
|To process purchases through Stripe or Paypal and deliver Services that we may in future provide||
Marketing and Communications
Performance of a contract with you.
Necessary for our legitimate interests (marketing activities that you have not opted out of as an example).
|To manage our relationship with you including notifying you of changes to the Service or any Services||
Marketing and Communications
Preparation to perform and performance of a contract with you.
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services).
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions).
|If we do this at any time to enable you to participate in a prize draw, competition or complete a survey||
Marketing and Communications
Performance of a contract with you.
Necessary for our legitimate interests (to allow us to review how Users take advantage of our Service and any paid for Services that we offer and to consider further Services that we may implement in the future).
|To administer and protect our business and this Service including troubleshooting, data analysis and system testing||
Technical issues you or other Users who are interacting with you may raise and which require investigation and possibly remediation
Performance of a contract with you.
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and working with partner organisations committed to supporting improvements in communication quality).
AGGREGATION OF PERSONAL DATA THAT WE HAVE COLLECTED
Disclosures of your personal data
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes described below. Please note that we do not sell User lists to third parties or make them available on any basis. The third parties that we do need to disclose your personal data to are as follows:
Your personal data will be subject to international transfer but on a basis that is compliant with the data protection laws that we as data controller are subject to. The data processors we identify in this notice may receive and further process your personal data outside of the United Kingdom. Where processing occurs in the Republic of Ireland the data processing is conducted within the European Economic Area (“EEA”) and therefore directly subject to GDPR. Where processing is undertaken by companies outside of the EEA these companies must none the less accept the jurisdiction of the European Union in respect of their processing of the data of EU data subjects and have, accordingly, made formal commitments to Game Academy to comply with the requirements expected of a data processor under EU (and also UK data protection laws) – for more information follow the links to their privacy policies above.
Our commitment to protection of your personal data extends to the operational policies and procedures that we apply within Game Academy – and expect others who work with us to also comply with. We take all appropriate and reasonable steps within our organisation and in the manner we interact with Users through the internet to protect your personal data from unlawful access, misuse, alteration, loss or inappropriate access. We employ external parties to support us in meeting our data security obligations such as for the conducting of cyber security monitoring and test penetrations of our internal network, communications and data storage systems.Your data is stored securely – this supported by our data back-up policy.
It is also our policy to ensure that Game Academy personnel will receive induction and ongoing training and that they are subject to and fully understand confidentiality obligations in connection with personal data any member of staff is entitled to access for the purpose of that person’s employment duties.
All information you provide to us is stored securely. Any payment transactions carried out by our chosen third-party provider of payment processing services will be encrypted using appropriate technological solutions. Stripe and Paypal are recognised as organisations that applies highly secure payment methodologies.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We operate procedures that help us to respond to suspected personal data breaches and will notify you and any applicable regulator when we are legally required to do so.
Details of retention periods for different aspects of your personal data are available in our retention policy, which you can request by contacting us.
By law we have to keep basic information about our customers (including Contact, Identity, and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data. See “Your legal rights” immediately below this section for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event that you do not use the Service for a period of 12 months then we will treat the account as expired and your personal data (excluding data within chat logs) will be deleted in accordance with our data retention policy.
Your legal rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
You can exercise any of these rights at any time by contacting us at 19 Palace Mansions, Earsby Street, London, United Kingdom, W14 8QW or firstname.lastname@example.org.
- You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data's accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- You also have the right to ask us not to continue to process your personal data for marketing purposes. We provide an opt-out facility associated with emails issued and you may also contact us at email@example.com to opt out.
CONTACTING THE INFORMATION COMMISSIONERS OFFICE
Should you have any concerns regarding the way we treat your personal data or the way we undertake control of the data do, please, get in touch. Please contact us at at firstname.lastname@example.org. We will respond to you quickly and will want to help you.
In the event that you are not happy with our response or prefer in any event for your concern to take an alternative route you are entitled to make contact with the Information Commissioner’s Office. Contact details are as follows:-