Last updated: June 22, 2020

Introduction

Welcome to Gameroo! Gameroo Ltd (“Company”, “We”, “Us”, or “Our”) is the owner and operator of the website located at www.gameroo.co.uk (“Website” or “Site”) and the Gameroo mobile app (“Mobile App”). The Website, Site and App are hereinafter collectively referred to as the “App”.

We respect your privacy, and we are committed to only collecting and using your personal data in compliance with applicable privacy laws and regulations, including the General Data Protection Regulation 2016/679.

This Privacy Policy informs you (hereinafter “User,” “You” or “Your”) of how we process your personal data when you make use of our Service, who we share it with, how we secure it, how long we retain it for and your rights as a data subject.

Please read this Privacy Policy carefully before proceeding to use the App. You are advised to read this Privacy Policy in conjunction with our Terms and Conditions. Your continued use of the App will be deemed as your acceptance of our privacy practices. If you do not agree with our privacy practices, please do not access our App.

The Scope of this Privacy Policy

This Privacy Policy applies to you when you create a user account, visit our Website or otherwise make use of any Services offered by the Company. Please do not provide us with any personal information, if you disagree with our privacy practices as outlined in this Privacy Policy. 

This Privacy Policy does not extend to your use of any Website, App, or Service that is not owned or controlled by the Company.

Definitions

Any use of the following terms in this Privacy Policy shall have the meaning as defined hereunder:

Account Holder

Means a User who registers a User Account on the App;

Data Controller

Means “the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law” as defined in Article 4(7) of the General Data Protection Regulation;

Data Subject

Means a natural person whose personal data is processed by the Company and its processors;

Personal Data

Means “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person” as defined in Article 4(1) of the General Data Protection Regulation;

Processing

Means “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction” as defined in Article 4(2) of the General Data Protection Regulation.

Buyer

Refers to a User who purchases a product through the App.

Seller

Means a User who scans and lists a product for sale on the App.

Gameroo Credits

Refer to the virtual currency required for conducting any transaction on the App.

Service

Means all the App features/functionality and support services offered by the Company through the App.

User

Means a Data Subject (Sellers and Buyers) who makes use of the App.

User Account

Means the App account provided by the Company, which enables a User to securely log in and make use of the Services.

Updates to this Privacy Policy

From time to time, we may amend this Privacy Policy to reflect our new privacy practices and commitment to compliance with applicable privacy laws and regulations. We will post the updated Privacy Policy on this page and notify you of such amendments by changing the last updated date on the top. You should review this Privacy Policy regularly to ensure that you are familiar with any changes. You understand and accept that your continued use of the App after the effective date of the update will be deemed as your tacit acceptance of any updated privacy practices.

Data Controller

For the purposes of this Privacy Policy, the Company is the data controller for personal data you submit through the App. We can be contacted at help@gameroo.co.uk.

Personal data we process and our purpose of processing

We believe in the principle of data minimisation, which is why we only collect the personal data that is necessary for us to deliver our Service to our Users.

User Account Data

When a User downloads the App and registers a user account, we collect the user’s full name and e-mail address to create their User Account and to enable them to make use of the App features and functionality.

Legal Basis of Processing

The legal basis of our processing of this personal data is the performance of our contract with the user as set out in Article 6(1)(b) of the GDPR.  

Data Retention Duration

We will retain this personal data for the entire duration that a User Account is active on the App. We will delete this personal data from our records within two years from the date of user account termination except in cases where we are required to keep such personal data for compliance with our legal obligation or to assert our legal rights under the Gameroo terms and conditions.

Gameroo Credits - Sales Data

When a user purchases Gameroo Credits on the App, we may collect the user’s billing address if required by our payment processor. Please note that we do not collect any sensitive payment details such as credit card data from our users and all payment data is collected directly by our payment processor Paypal, Inc in accordance with their own legal agreement.

Legal Basis of Processing

The legal basis of our processing is our legitimate interest, which does not override our users’ data rights as set out in Article 6(1)(f) of the General Data Protection Regulation.

Data Retention Duration

We will retain this data for the entire duration that a user’s account is active on the App.  We will delete this data within two years from the date of User Account termination except where we are required to keep this data for our business or legal compliance purposes.

Support Requests Data

When a user sends support requests or inquiries to us through our contact page or via e-mail, we collect such user’s name, e-mail address and the content of their support request. We process this information to respond to their inquiries/requests and to contact them if required.

Legal Basis of Processing

The legal basis for our processing of this personal data is our legitimate interest which does not override the data subject’s rights, as provided in Article 6(1)(f) of the General Data Protection Regulation.

Data Retention Duration

We retain the personal data associated with a support request for the entire duration that a user’s account is active on the App. We will remove all support request data within two years from the date of account termination except in cases where we are required to keep this information on other lawful grounds.

Seller’s Inventory Data

When a seller lists a product on the App or sells/ships a sold product to the Buyer, we process such Seller’s inventory data which includes the products currently available for sale, as well as products sold through the App.  

Legal Basis of Processing

The legal basis of our processing of this personal data is our legitimate interest which does not override a user’s rights as set out in Article 6(1)(f) of the GDPR.  

Data Retention Duration

We will retain this data for the entire duration that User Account is active on the App. If the User Account is terminated, we will not retain their personal data for longer than necessary for our business purposes and compliance with the law.

Transaction Data

When a product is sold/purchased through the App, we collect some transaction-related data from our users including the Buyer’s shipping address, the product sold, the sale price, date and time when the shipping label is downloaded by the Seller, and any order-related disputes raised by a user.

Legal Basis of Processing

The legal basis of our processing of this personal data is the performance of our contract as set out in Article 6(1)(b) of the GDPR.  

Data Retention Duration

We will retain this personal data for the entire duration that the user accounts associated with those transactions are active on the App and for a period of two years thereafter.

Sharing your personal data

We do not sell or rent your personal data to any third party. We may disclose your personal data only as described hereunder:

Sellers who ship the product

When you place an order through the App, we will share your shipping address with the Seller who is selected by the Company to fulfil your order. Sellers are only authorised to process your personal data for the purposes of shipping the ordered product to you, and they are not authorised to use your personal data for any other purposes.

Company Employees and Contractors

Your personal data will be shared with our employees on a need to know basis to enable them to deliver our Services to you.

Merger or Acquisition

In the future, if we undergo a merger or acquisition, your personal data will form part of our business assets and may be transferred to the new entity. Please note that any transfer of your personal data as a result of a commercial transaction will not negatively impact your privacy rights as specified in this privacy policy.

 Compliance Obligations

If we are required to disclose your personal data to local and international government authorities, law enforcement bodies, courts of law, or other government agencies, we reserve the right to disclose this personal data for compliance with our legal and regulatory obligations, as well as for asserting or defending our legal rights and interests.​​​​​​​

We may also disclose your personal data to:

  • To prevent or investigate possible wrongdoing in connection with the Service;
  • To protect the personal safety of our users or the public; and/or
  • To protect against legal liability.

​​​​​​​Third-Party Processors

We may use third-party companies during the course of delivering our Services, and your personal data may be shared with these third-party processors. Please note that we enter into appropriate data processing agreements to limit any unauthorised use or access to your personal data. We may use third-party processors including:

​​​​​​​Google Analytics

We may use third-party analytics tools such as Google Analytics to evaluate the usage of our App. Google Analytics SDK collects non-personal information about app usage. We are committed to complying with Google’s Privacy Policy. To learn more about Google Analytics’ privacy policy, please visit their Privacy Policy by clicking on this link.

​​​​​​​Payment Processors

We currently use Paypal payment processors to process all Gameroo Credit purchases on the App. All our users’ sensitive financial data is collected and processed by Paypal Inc in accordance with their own legal agreements. To learn more about Paypal’s privacy practices, please visit the link provided here;

​​​​​​​E-mail distribution tools; and

​​​​​​​Customer support tools

Sharing Anonymous User Data

We may share anonymous statistical data we collect from you during the course of your usage of the App with third parties for business purposes. We aggregate this data to ensure no personal information about any user is disclosed to any third-party that we share it with.

Third-party website links

Our App may contain links to third-party websites that are not owned or operated by us. Should you decide to click on any such third party links, you will be directed to such a third party’s Website. These third-party websites have their own Terms and Conditions and Privacy Policy. We encourage our Users to review the third-party website Terms and Privacy Policy prior to using such a Website or acquiring any services offered by them. We only provide such links for your convenience, and the presence of any third party links on our App does not constitute an endorsement or recommendation of such third party Website.

We cannot be held responsible for any content made available by these third-party websites or their practices.

Transfer of Personal Data

We may transfer and process your personal data outside of the United Kingdom to countries where data protection laws are less stringent than those in the UK. When we transfer your personal data outside of the UK, we only do so to entities that offer our users the same level of data protection as that afforded by the UK Data Protection Act 2018 and the GDPR. All our Non-EEA data processors use appropriate measures such as compliance with EU-US Privacy Shield Frameworks to ensure that your personal data receives the same data protection that you enjoy within the UK. By accessing or in any way interacting with our Website, you give us your express consent to transfer and process your personal data in and outside the country of your current residence for the purposes outlined in this Privacy Policy or those that are compatible with the specified purposes.  

Your Rights  

Our users have the following personal data rights:

Right to access your personal data

As a data subject, you may ask us to provide you with a copy of all your personal data that we hold.

Right to rectification

You have the right to rectification of any incorrect or incomplete information on your User Account. You can exercise your right by logging into your User Account and editing the relevant information. If you require our assistance, you can also contact us at the contact information provided at the bottom of this Privacy Policy.

Right to data portability

You also have the right to receive the personal data concerning you, which was provided to us in a structured, commonly used, and machine-readable format.

Right to withdraw consent 

You have the right to withdraw your consent from receiving any direct marketing material from us by clicking the “unsubscribe” button at the bottom of our marketing e-mail alternatively by contacting us with your request. 

Right to erasure of personal data

In limited circumstances, you may have the right to request the erasure of your personal data, such as where you have a reason to believe that your personal data is being processed unlawfully or where the personal data is retained for longer than specified in our data retention policies.

Right to lodge a complaint

If you believe that our processing of your personal data is infringing your rights as a data subject, you have the right to file a complaint with the Information Commissioner’s Office at:

The Information Commissioner’s Office

Water Lane, Wycliffe House

Wilmslow - Cheshire SK9 5AF

Tel. +44 1625 545 745

e-mail: international.team@ico.org.uk 

Storage and Security  

The security of your personal data is important to us, and we are committed to maintaining the confidentiality of the information you provide us. We take all reasonable and commercially viable measures to protect your personal data. However, as with any software service, there may be vulnerabilities that we are not yet aware of; therefore, we are unable to offer any guarantees as to the security of your personal data.

Children’s Privacy  

We do not knowingly collect any personal information from children who are under the age of thirteen (“Child” or “Children”). If you become aware of any information to suggest that a Child has provided his/her personal information to us, please immediately contact us. We will investigate the matter and take appropriate action.

Contact Us     

If you have any questions, comments, or inquiries regarding this Privacy Policy, please contact us at help@gameroo.co.uk