1. Introduction
| 1.1 |
This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and forum users. In other words, it applies where we determine the purposes and means of the processing of that personal data. |
| 1.2 |
By using our website you agree to this policy and your consent to our use of data and cookies in accordance with the terms of this policy. |
| 1.3 |
In this policy, “we”, “us” and “our” refer to Pathfinder Games Limited. For more information about us, see Section 13. |
2. Credit
| 2.1 |
This document was created using a template from SEQ Legal (https://seqlegal.com). |
3. How we use your personal data
| 3.1 |
In this Section 3 we have set out: |
| a) the general categories of personal data that we may process; b) data obtained from third-parties such as Facebook, Twitter and Valve; c) the purposes for which we may process personal data; d) and the legal bases of the processing. |
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| 3.2 |
We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics & WordPress JetPack. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services. |
| 3.3 |
We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business. |
| 3.4 |
We may process your information included in your personal profile on our website (“profile data”). The source of the profile data is you. The profile data may include your name, email address, profile pictures, gender, date of birth, interests and hobbies. The profile data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is by our legitimate interests, namely the proper administration of our website and business. |
| 3.5 |
We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent and/or the proper administration of our website and business. |
| 3.6 |
We may process information contained in any enquiry you submit to us (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is by our legitimate interests, namely the proper administration of our website and business. |
| 3.7 |
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is by our legitimate interests, namely the proper administration of our website and business. |
| 3.8 |
We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users. |
| 3.9 |
In addition to the specific purposes for which we may process your personal data set out in Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person. |
| 3.10 |
You undertake not to supply any other person’s personal data to us, unless we prompt you to do so. |
4. Providing your personal data to others
| 4.1 |
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. |
| 4.2 |
We may disclose account data to Valve for the purpose of enabling them to contact you so that they can gift, market and sell you Pathfinder Game product(s). Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party is responsible for supplying to you a copy of its own privacy policy, which will govern that third party’s use of your personal data. |
| 4.3 |
In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. |
5. International transfers of your personal data
| 5.1 |
In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA). |
| 5.2 |
The hosting facilities for our website are situated in the United States of America. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to the United States of America will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en |
| 5.3 |
You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use or misuse of such personal data by others. |
6. Retaining and deleting personal data
| 6.1 |
This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. |
| 6.2 |
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. |
| 6.3 |
Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. |
7. Amendments
| 7.1 |
We may update this policy from time to time by publishing a new version on our website. |
| 7.2 |
You should check the website page occasionally to ensure you are happy with any changes to this policy. |
8. Your rights
| 8.1 |
You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to: |
| a) the payment of a fee; and b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address). |
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| 8.2 |
We may withhold personal information that you request to the extent permitted by law. |
| 8.3 |
You may instruct us at any time not to process your personal information for marketing purposes. |
| 8.4 |
In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes. |
9. About cookies
| 9.1 | A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. |
| 9.2 |
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. |
| 9.3 |
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. |
10. Cookies that we use
| 10.1 | We use cookies for the following purposes: |
| a) Authentication – we use cookies to identify you when you visit our website and as you navigate our website. b) Status – we use cookies to help us to determine if you are logged into our website. c) Personalisation – we use cookies to store information about your preferences and to personalise the website for you including your preferred viewing language. d) Security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally. e) Analysis – we use cookies to help us to analyze the use and performance of our website and services. f) Cookie consent – we use cookies not to display our cookie notice to returning visitors unless our cookies have changed. |
11. Cookies used by our service providers
| 11.1 | Our service providers use cookies and those cookies may be stored on your computer when you visit our website. |
| 11.2 | We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. |
| 11.3 | We use WordPress Jetpack to analyse the use our website. This service uses cookies to create reports about the use of our website . You can view Jetpack’s privacy policy at https://jetpack.com/support/privacy/ |
12. Managing Cookies
| 12.1 | Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links: |
| a) https://support.google.com/chrome/answer/95647?hl=en (Chrome); b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox); c) http://www.opera.com/help/tutorials/security/cookies/ (Opera); d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer); e) https://support.apple.com/kb/PH21411 (Safari); and f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge). |
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| 12.2 |
Blocking all cookies will have a negative impact upon the usability of many websites. |
| 12.3 |
If you block cookies, you will not be able to use all the features on our website. |
13. Our details
| 13.1 | This website is owned and operated by Pathfinder Games Limited. |
| 13.2 |
We are registered in England and Wales under registration number [number], and our registered office is at [address]. |
| 13.3 |
You can contact us: |
| a) using our website contact form; b) by email, using the email address on our website from time to time. We do not accept correspondance by post. |
14. Data protection officer
| 14.1 |
Our data protection officers can be contacted via e-mail using the methods outlined above in 13.3 |