Our legal status is that of a “data controller” and in this capacity we will securely store and process your/your children’s personal information which you/your children have provided to us or which we otherwise collect. Data controller is a legal term used in EU legislation to signify the person who controls what to do with any given personal information.
The Services are designed partly for children. Therefore we are aware that we must be extra cautious when processing personal information. Most of our Services contain a children’s section (the “Children’s Area”) and a separate parents’ (or guardians’) section (the “Grown-Up Area”). In the Children’s Area, children mainly participate only by playing games, reading e-books and/or watching videos. We generally do not offer any place in the Children’s Area where a child can sign up or enter personal information themselves. Typically, the only part of the Services where anyone can enter personal information directly is the Grown-Up Area. Accordingly, in most cases, we do not anticipate that we will be collecting personal information directly from any children. We anticipate and assume that we will be collecting personal information only from parents or guardians.
If you are under the age of 13, you may only use the Services and provide personal information if you have the consent of, and are supervised by, a parent or guardian.
If we believe a child using the Services is under 13 we will not process any personal information of that child without the consent of the parent or guardian. If the user is 13 or over we will only collect and process personal information as the long as we believe the user understands what is involved.
What personal information do we collect?
We may collect the following personal information:
If you contact us with a complaint or query, we may keep a record of any phone number used to call our customer service team as well as the correspondence.
How and when we collect your/your children’s personal information
We may collect personal information from you when you/your children:
When you browse or otherwise use the Services, we will also collect certain information about your device and your use of the Services using cookies and similar technologies as further described below.
We will indicate where any personal information we have requested is mandatory or optional. Please note that if you decide not to provide certain information which we have indicated is mandatory, in some circumstances this may mean we are unable to provide you with a certain service or product.
We may also collect personal information about you from third party sources, such as from our sub-contractors.
How we may use your/your children’s personal information
We (or third party data processors acting on our behalf) may collect, store and use your/your children’s personal information for the following purposes:
We may also collect information about visitors to and users of the Services for the purposes of aggregate statistics or reporting purposes.
Legal basis for processing your personal information
We will only process your/your child’s personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use the personal information. In almost every case the legal basis will be one of the following:
Where we store your personal information
The personal information that we collect may be transferred to, and stored at, a destination outside the European Economic Area (the “EEA”), including countries, which have less strict, or no data protection laws, when compared to those in Europe.
How we keep your personal information
We take steps to ensure that the personal information we collect is retained for only as long as it is necessary for the purpose for which it was collected. After this period it will be deleted or in some cases anonymised.
Where we have collected personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will delete your personal information. However, please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.
Do we share personal information with any third parties?
We may share your personal information within our group of companies (i.e. our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).
We may share your (or your child’s) personal information with our marketing vendor/data processor, who hosts the Services and stores all associated data on our behalf, and sends out certain e-mails on our behalf.
If a third party acquires all (or substantially all) of our business and/or assets, we may disclose your/your children’s personal information to that third party in connection with the acquisition. We may also disclose your/your children’s personal information where we are required to do so by applicable law, by a governmental body or by a law enforcement agency.
We may also disclose personal information to protect the rights, property or safety of us or our users, or others, and in order to enforce or apply our terms and conditions (this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction) or where we are required to do so by applicable law, by a governmental body or by a law enforcement agency.
Cookies and similar technologies
We may also use technologies such as tag, pixels or web beacons. These are objects embedded in a web page or email and are usually invisible to the user but allows checking that a user has viewed the page or email. The site may also use “local shared objects”, also known as “flash cookies”. These are pieces of data that websites which use certain video players may store on your computer, such as game preferences or game progress.
Third party sites
We take appropriate technical and organisational measures to safeguard the personal information that we hold about you and regularly review our security measures to consider new technologies and methods, to safeguard your data. Please note that no transmission over the Internet can ever be guaranteed secure and we consequently cannot guarantee the security of any personal information that we receive over the Internet.
You must keep your password and any other authentication information for the Services confidential. If you know or suspect that anyone other than you knows your password or any other authentication information, you must promptly notify us using the contact details below.
You have certain rights in relation to your personal information. These include: the right to object to the processing of your information for certain purposes, the right to access your personal information, and the ability to erase, restrict or receive a machine-readable copy of your personal information.
We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of these rights please conduct us using the contact details below.
You may also have the right to complain to a data protection authority (such as the UK Information Commissioner’s Office) if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have such concerns we request that you initially contact us (using the contact details below) so that we can investigate, and hopefully resolve, your concerns.