GameBake Privacy Notice
Last updated: 23 October 2020
OUR PRIVACY PROMISE
Your privacy is important to GameBake ("we", "us" and "our"). We are committed to protecting your personal
data and being transparent about the personal data we hold and use and, wherever possible, giving you
control over how we use your personal data.
This notice is intended to be communicated to you in a concise, transparent, intelligible, and easily accessible
manner, but we appreciate that you may have queries or want to seek clarification as to its terms. If so, please
contact us (using the details set out at paragraph 2 below) and we will endeavour to respond to you as soon as
possible.
We may make changes to this notice from time to time, including as may be necessary or prudent to reflect any
changes in the ways in which we process personal data or any changes in data protection laws. Any changes
and updates to this notice will be posted on the GameBake Website. Please check this notice regularly so that
you are aware of any changes.
1
INTRODUCTION
Please read this notice carefully. Among other things, it explains:
● What personal data we collect about you;
● Why we collect and use your personal data and the legal bases we rely on for processing;
● Who we disclose your personal data to;
● Where we store your personal data;
● How long we keep your personal data; and
● Your rights regarding the personal data you provide to us.
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WHO WE ARE AND OUR CONTACT DETAILS
For the purposes of data protection laws, the data controller is GameBake Limited, a company
registered in England and Wales (company no. 11974510) with its registered office at New Broad
Street House, 35 New Broad Street, London EC2M 1NH.
If you have any queries regarding this notice or the way in which we process your personal data,
please contact us at:
Email: terms@gamebake.io
Address: Data Protection, New Broad Street House, 35 New Broad Street, London EC2M 1NH
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CHANGES TO YOUR PERSONAL INFORMATION
It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes or if you become aware that any personal data that we hold
about you is not accurate.
4
WHEN DO WE COLLECT YOUR PERSONAL DATA
We may collect information direct from you and use, disclose and store it when you:
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(GameBake Website), our video game(s), platform and apps;
● correspond/interact with us via email, phone, social media or other channels;
● make any enquiry;
● purchase, request or subscribe for a product or service from us;
● request technical support or other customer care support;
● participate in competitions, surveys and questionnaires or provide us with a review or
feedback;
● post content on our social media pages or any of our other channels.
Where lawful, we may also obtain personal data from third parties (including third party platforms)
and we may process that information where it is needed in order to provide our products and
services to you, including access to our games or where it is needed for our internal administrative
purposes or for marketing and business development purposes.
We may also automatically collected certain Technical Data (as defined below) relating to your
device and your activities on the Gamebake Website and/or within our video games or apps. We
may also collect such data from third parties such as analytics providers (including Google) and third
party platforms and organisations within advertising networks (including Facebook).
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WHAT PERSONAL DATA WE COLLECT
The type of personal data we process may include (as applicable) the following:
Categories of Data
Description of Data
Identity Data
Name, address, date of birth, age, marital status,
title, gender, nationality, country of residence,
job title, role, employer, company/organisation
details in an email signature, user name, bio and
any profile data that is publicly available eg. in
your Facebook profile.
Contact Data
Email address, address, telephone number,
mobile number, social media handles, other
information in an email signature.
Employment Data
CV,
résumé,
educational
background,
employment history and any other information
you provide in connection with the same.
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Correspondence Data
Information which you provide in, or we learn
about you from, any correspondence or
communications with us, including details of any
enquiries or requests for technical support or
customer care support and any other information
you provide to us.
Usage Data
Device IP address, the pages of the GameBake
Website that you visit, usage information for the
GameBake Website and details of your activities
in any of our video games and apps, your use of
social sharing features such as Likes, comments
and links that you share
(eg. via Facebook
Comment or Share).
Technical Data
Type of device, unique device identifier (e.g. an
IMEI number, IDFA, IP, or Mac address), network
information, the type of operating system,
platform and browser you use, location, time
zone settings and other device related
information and online identifiers.
Marketing and Communications Data
Your marketing preferences and communication
preferences and any information that you may
provide to us in any reviews or feedback.
Financial and transaction data - If you make any payments in respect of one of our video games,
your payment details (such as bank account and payment card details) will be collected by the
platform provider or an external payment service provider. We will not collect or access any such
details and you should contact the relevant third party for information relating to use of your
financial and transaction data.
Children - you must be 13 years old or over in order to play any of our video games. We do not
knowingly collect any personal data relating to anyone under this age.
Analytics Data - we may receive aggregated statistics and insights from advertising, analytics and
attribution providers and third party platforms on which our video games and apps are available. We
use this information to help us to understand how people are using our products and services and
how our ads are performing. This information does not contain any personally identifiable
information.
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Information about why we process the above personal data and the lawful basis we rely upon is set
out in the table at paragraph 6 below.
6
WHY WE COLLECT AND USE YOUR PERSONAL DATA
6.1
We use your personal data for a number of purposes but only where we are allowed to by the
law.
6.2
We may process your personal data in any circumstances where such processing is necessary:
6.2.1
in order to perform any agreement we have entered into with you or in anticipation
of any agreement we may enter into with you;
6.2.2
to comply with any applicable law or regulation; and/or
6.2.3
for the purposes of the legitimate interests pursued by us or a third party. These
legitimate interests include the purposes identified in the table below at paragraph
6.5 but also include other commercial interests and our internal administrative
purposes. Where we rely on legitimate interests as the lawful basis for processing
your personal data, we will put in place appropriate safeguards to protect your data
and to ensure that your interests or fundamental rights and freedoms are not
overridden by those legitimate interests.
6.3
We may also process your personal data where we have your consent. Where we rely on
consent as the lawful basis for processing your personal data, you have the right to withdraw
your consent at any time and if you wish to do so, you should contact us using the contact
details set out in paragraph 2 above. Where we obtain your consent to send you marketing
communications, you can unsubscribe by following the unsubscribe link within the
communication. The withdrawal of consent does not affect the lawfulness of processing based
on consent before withdrawal or the lawfulness of processing based on other lawful grounds.
6.4
We may process your personal data for more than one lawful ground depending on the
specific purpose for which we are using your data.
6.5
Information about the purposes for which we use your personal data, the types of personal
data we process to achieve these purposes, and the lawful basis by which we process it, is set
out in the table below:
Purpose/Activity
Type of Personal Data
Lawful Basis for Processing
Processed
Registration
● Identity Data
● Consent
● Contact Data
● Performance of a contract
● Correspondence Data
● Compliance with a legal
● To register you as a new
● Usage Data
obligation
customer or user
● Technical Data
● Our legitimate interests to
● Marketing and
operate our business and fulfil
Communications
our legal and contractual
Data
obligations
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Provision of our products, services
●
Identity Data
●
Performance of a contract
and games
●
Contact Data
●
Compliance with a legal
●
Correspondence Data
obligation
●
Usage Data
●
Our legitimate interests to
● To provide our products,
services and games.
●
Technical Data
operate our business and fulfil
our legal and contractual
obligations
Business Operation and
●
Identity Data
●
Performance of a contract
Maintenance
●
Contact Data
●
Compliance with a legal
●
Correspondence Data
obligation
● To operate and protect the
●
Usage Data
●
Our legitimate interests to
GameBake Website, apps,
●
Technical Data
operate and improve our
games and our social media
business, fulfil our legal and
contractual obligations and for
channels, (including
the purposes of IT security
troubleshooting, incident
management and data breach
management, data analysis,
product and system testing,
system maintenance, support,
reporting and hosting of data)
Customer Relationship
●
Identity Data
●
Consent
Management
●
Contact Data
●
Performance of a contract
●
Correspondence Data
●
Compliance with a legal
●
Usage Data
obligation
● To manage our relationship
with our customers which
●
Technical Data
●
Our legitimate interests to
●
Marketing and
respond to enquiries, messages
includes notifying you of any
changes to our terms or this
Communications
and requests, operate, develop
Data
and improve our business and
notice or to our
products/services/games,
to fulfil our legal and
contractual obligations
apps, to respond to enquiries,
messages, and requests for
technical support and
customer care support
Business Development
●
Identity Data
●
Our legitimate interests to
●
Contact Data
define types of customers for
● To improve the GameBake
●
Correspondence Data
our products and services,
Website, our apps and games,
●
Usage Data
develop and improve our
●
Technical Data
business and to inform our
customer relationships and
experiences
●
Marketing and
marketing strategy
Communications
Data
Business Management
●
Identity Data
●
Performance of a contract
●
Contact Data
●
Compliance with a legal
● To manage our business
●
Correspondence Data
obligation
including to keep financial and
●
Usage Data
●
Our legitimate interests to
accounting records, carry out
●
Technical Data
exercise our rights (including to
audits, testing, comply with
recover debts), to operate our
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our reporting requirements
business (including internal
and other corporate
administration and IT services,
governance requirements
network security, to prevent
● To exercise our rights set out in
fraud and in the context of a
agreements including
business reorganisation, sale or
recovering debts owed to us
group restructuring exercise)
and to fulfil our legal and
contractual obligations
Marketing and Advertising
●
Identity Data
●
Consent
●
Contact Data
●
Our legitimate interests to
●
To market our products and
●
Marketing and
develop our business and to
services
Communications
inform our marketing strategy
●
To make suggestions and
Data
recommendations to you
●
Usage Data
about other
●
Technical Data
products/services/games that
may be of interest to you
●
Asking you to leave a review or
take part in a poll/survey
●
To enable you to take part in a
prize draw or competition
including the publication of
certain details if you are the
winner
●
To deliver relevant website
content and advertisements to
you and measure or
understand the effectiveness
of the advertising we serve to
you
●
To use data analytics to
improve our business, the
GameBake Website, our
products, services and games,
marketing, customer
relationships and experiences
Recruitment
●
Identity Data
●
Consent
●
Contact Data
●
Performance of a contract
● For recruitment purposes if
●
Correspondence Data
●
Compliance with a legal
you apply to work with us
●
Employment Data
obligation
●
Our legitimate interests to
develop our business
6.6
We will only use your personal data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible
with the original purpose.
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6.7
If we need to use your personal data for an unrelated purpose, we will notify you (which may
be by way of update to this notice) and we will explain the legal basis which allows us to do so.
6.8
Please note that we may process your personal data without your knowledge or consent
where this is required or permitted by law.
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WHAT IF YOU REFUSE TO PROVIDE US WITH ANY PERSONAL DATA?
7.1
Where we need to collect personal data by law, or under the terms of an agreement we have
with you, and you fail to provide that data when requested (or fail to consent to the
processing of that data, if necessary), we may not be able to perform the agreement or
arrangement we have or are trying to enter into with you which might include enabling you to
play one of our games.
8
SHARING INFORMATION WITH THIRD PARTIES
8.1
We will not share any of your personal data with third parties except as set out in this
paragraph 8 or otherwise notified to you or agreed between you and us from time to time.
8.2
We may share personal data with our group companies (including our subsidiaries, ultimate
holding company and its subsidiaries) and partnered companies for the purposes outlined in
this notice. We may also share personal data with third party service providers who we
engage to provide services which facilitate our business or who provide access to our video
games and apps. We may also need to share personal data with other third parties in order to
comply with our legal and regulatory obligations. Below is a list of specific third parties and
other categories of third parties with whom we may share your personal data:
8.2.1
Google Analytics and Google Ads, operated by Google LLC, our provider of online
marketing tools and other analytics, advertising and attribution partners;
8.2.2
Third party platforms including Facebook, Inc.;
8.2.3
Payment service providers;
8.2.4
Any third party buyer of our business or assets;
8.2.5
Law enforcement or a regulator;
8.2.6
Legal counsel and other professional advisers including accountants and auditors.
8.3
We ensure that any third party engaged by us who processes your personal data in connection
with the purposes listed above has policies and procedures in place to ensure compliance with
data protection laws.
8.4
For any third parties that are based, or process data, outside of the EEA and the United
Kingdom, we engage such third parties in accordance with paragraph 9 below.
8.5
We will remain the controller responsible for the processing of your personal data
notwithstanding that third parties may operate as a joint controller with us. For some
processing activities we may act as a processor for a third party and, in such circumstances,
the third party will be responsible for providing you with the processing information required
under data protection laws.
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8.6
We may share your personal data with third parties where we are required to do so by law or
regulation (such as in connection with an investigation of fraud or other legal enquiry) or in
connection with other legal proceedings (including where we believe that your actions violate
applicable laws or any agreement with us).
8.7
In the event that our business or any part of it is sold or integrated with another business,
your details may be disclosed to our advisers and those of any prospective purchaser and will
be passed to the new owners of the business.
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INTERNATIONAL TRANSFERS OF PERSONAL DATA
9.1
Our servers are located in the UK but from time to time it may be necessary for us to transfer
your information internationally. In particular, your information may be transferred to and/or
stored on the servers of third parties identified in paragraph 8 which are based outside of the
UK and the EEA.
9.2
However, we will not transfer your personal data outside of the UK and the EEA unless:
9.2.1
such transfer is to a country or jurisdiction which the EU Commission or the UK has
approved as having an adequate level of protection; or
9.2.2
appropriate safeguards are in place in accordance with data protection laws. These
safeguards include the use of standard contractual clauses or binding corporate
rules; or
9.2.3
the transfer is otherwise allowed under data protection laws (including where we
have consent or the transfer is necessary for the performance of a contract with the
data subject).
9.3
We will ensure that where your personal data is transferred outside of the UK and the EEA, it
is afforded the same protection as would be afforded to it within the EEA and UK.
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YOUR RIGHTS AS A DATA SUBJECT
10.1
Subject to any conditions and requirements set out in data protection laws, you may have
some, or all, of the following rights in relation to the personal data we hold about you:
10.1.1
the right to request a copy of your personal data held by us;
10.1.2
the right to correct any inaccurate or incomplete personal data held by us;
10.1.3
the right to request that we erase personal data we hold about you;
10.1.4
the right to request that we restrict the processing of your data;
10.1.5
the right to have your personal data transferred to another organisation;
10.1.6
the right to object to certain types of processing of your personal data by us; and
10.1.7
the right to complain (please see paragraph 13 of this notice).
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10.2
PLEASE NOTE that these rights are not absolute in all situations and may be subject to
conditions and provisions set out in data protection laws. We cannot, therefore, guarantee
that we'll be able to honour any request from you in connection with the rights set out above.
(For example, even if you request that we delete your personal data, we may be required by
law to retain some personal data for accounting and record keeping purposes or in order that
we comply with our legal and regulatory obligations).
10.3
For further information, or to exercise any particular right, please contact us at
terms@gamebake.io.
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STORAGE AND RETENTION OF YOUR PERSONAL DATA
11.1
As a minimum, we need to store your personal data for as long as is necessary to enable us to
fulfil the purpose for which it is processed, including to fulfil our legal and regulatory
obligations (e.g. relating to record keeping) and to exercise or defend any legal claims.
11.2
We will notify you without undue delay in accordance with the requirements of data
protection laws, if we have reason to believe that there has been a personal data breach by us
which could adversely affect your rights and freedoms and we are required by law to notify
you.
12
LINKS TO THIRD PARTIES
12.1
The GameBake Website may link or redirect to other websites, social media accounts or other
content which is not under our control. Such links or redirections are not endorsements of
such websites or representation of our affiliation with them in any way and such third party
websites are outside the scope of this notice. Further, you may play one of our video games or
apps on a third party platform which we are not responsible for.
12.2
If you access such third party websites or platforms, please ensure that you are satisfied with
their respective privacy policies before you provide them with any personal data. We cannot
be held responsible for the activities, privacy policies or levels of privacy compliance of any
website or platform operated by any third party.
13
QUESTIONS AND COMPLAINTS
13.1
We take our data protection obligations seriously. If you have any questions or complaints
about this notice or the way that we handle your personal data, we would appreciate the
chance to deal with your concerns in the first instance before you approach the relevant data
protection authority. Please contact us using the details provided in paragraph 2 above.
13.2
You have the right to make a complaint at any time to the relevant supervisory authority for
data protection issues, which in the UK is the Information Commissioner's Office (ICO)
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