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”).

We respect your privacy, and we are committed to only collecting and using your personal data in compliance with applicable Data Protection laws, including the UK Data Protection Act 2018 and the UK GDPR. 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. You are advised to read this Privacy Policy in conjunction with our Terms and Conditions.

Data Controller

For the purposes of this Privacy Policy, Gameroo Ltd is the data controller for personal data where we carry our services to you. We can be contacted at [email protected].

The Scope of this Privacy Policy

This Privacy Policy applies to the processing of personal data by us in connection with any:

• Subscribers for the provision of services by us.
• Visitors on our website.

Types of personal data

Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed. This is known as anonymised data. Anonymised data falls outside the scope of Data Protection Laws.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together:

• Identity Data includes first name, last name, username or similar identifier and title.
• Contact Data includes email address.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
• Profile Data includes your username and password, searches made by you, your ratings and comments, playlist, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website and service.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

How we collect your personal data

Directly from you: You give us your personal data in your direct interactions with us. Such personal data includes Identity Data, Contact Data, Profile Data, Usage Data, Technical Data, Marketing and Communications Data (i) by filling in forms on our website (ii) by leaving ratings and comments (iii) by corresponding with us by email or post (iv) by calling us over the telephone.

This includes personal data you provide when you:

• Sign up to our website.
• Subscribe to our service or publications.
• Request marketing to be sent to you.
• Give us feedback or contact us.
• Participate in our marketing or other promotional events.

We do not collect personal data from you from indirect source.

From use of our website

Gameroo gathers information and statistics collectively about visitors to the Gameroo website. Analysis of this information demonstrates the most frequently used sections of the website and assists us in continually improving the online service. You give us your personal data, which includes Profile Data, Usage Data, Technical Data and/or Marketing and Communications Data when you use our website or which we have agreed with you to use or when you review any publications or marketing material we send you. Please see our cookies notice for more information.

Providing personal data Where we need to collect personal data by law or under the terms of a contract we have with you and you do not provide that information when requested we may not be able to perform the contract we have or are trying to enter into with you for example to provide you with our services. In this case we may have to cancel our service but we will notify you if this is the case at the time.

How we use your personal data

Gameroo will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:

• Performance of a contract: Where we need to perform the contract we are about to enter into or have entered into with you. For example when you sign up to our services.
• Legal obligation: Where we need to comply with a legal obligation. For example for accounting or legal purposes.
• Legitimate interests: Where it is necessary for our legitimate interests or those of a third party and your interests and fundamental rights do not override those interests.
• Consent: We do not generally rely on consent as a legal basis for processing your personal data. Where we do rely on consent you have the right to withdraw consent at any time. Please contact us at [email protected] to withdraw consent. Please also see Marketing communications.

Purposes for which we will use your personal data

We have set out below in a table format a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing communications

Gameroo may send you marketing communication. You have the right to object to processing of your personal data for direct marketing purposes. You can unsubscribe from receiving marketing communications from us by using the unsubscribe methods contained in communications we send to you or by contacting us. See Contact us.

Where you opt out of receiving marketing communications this will not apply to personal data provided to us as a result of registering for or using our service, your service experience or other interactions with this website.

How we share your personal data

We may have to share your personal data with the parties set out below:

• 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.
• Suppliers: This would include service providers who support our business including IT and communication suppliers and outsourced business support to ensure our service runs smoothly.
• Professional advisers: This would include lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• 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.
  
  
• Law enforcement bodies, regulators and other authorities: This is to comply with our legal requirements or adhere to good practices.
• Advertising networks and analytics service providers: This is to support and display ads on our website and other social media tools.
  We use third-party analytics tools such as Google Analytics to evaluate the usage of our Website. We are committed to complying with Google’s Privacy Policy. To learn more about Google Analytics’ privacy policy, please visit their Privacy Policy.
• 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.

Third-party website links

Our Website 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 website 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 UK GDPR.

1. We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information; or
2. 2. We will use specific contracts approved for use in the UK which give personal information the same protection it has in the UK. For example, the use of Article 46 UK GDPR safeguard mechanisms to transfer personal data.

To find out more about the transfer mechanism used please contact us at [email protected]

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

The transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your personal data, Gameroo cannot guarantee the security of your information transmitted and any transmission is at your own risk.

Data retention

Gameroo will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal, regulatory, tax, accounting or other requirements.
Gameroo may 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.

Your Rights

Under certain circumstances you have rights under Data Protection Laws. Some of these rights are not absolute.

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 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

Object to processing of your personal data

This is where we are processing your personal data based on a legitimate interest or those of a third party and you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to any legal claims. See also Marketing communications.

Request restriction of processing

This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the information's accuracy (b) where our use of the information is unlawful but you do not want us to erase it (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

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.

Automated decision making

This is where decisions are made about you by automated means. We do not carry out automated decision making.

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.

Carrying out your rights

You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information or to exercise any of your other rights. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you wish to exercise any of the rights set out above, please contact us at [email protected].

Concerns and complaint mechanism

We would appreciate the chance to deal with your concerns so do contact us in the first instance. 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

Children’s Privacy

If you have any questions, comments, or inquiries regarding this Privacy Policy, please contact us at [email protected].

Contact Us

If you have any questions, comments, or inquiries regarding this Privacy Policy, please contact us at [email protected].

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.