EFFECTIVE DATE: 28 October 2020
We strive to make SimpleMMO the best text-based MMO out there and a safe environment for you to have fun. This includes respecting your privacy and our commitment to safeguarding your personal data.
This policy describes the information we collect or you share with us when you visit our website and SimpleMMO (regardless of where you visit it from), how it is used, stored and safeguarded, and your choices regarding this information.
This policy outlines how we at Galahad Creative Ltd collects and processes your personal data through your use of this website, and through SimpleMMO (whether that is the desktop or app version), including any data you may provide when you register an account on SimpleMMO and use the game.
Our website and SimpleMMO are not intended for children under 13 years old and we do not knowingly collect data relating to children.
DATA CONTROLLER AND CONTACT DETAILS
Our details are as follows:
Galahad Creative Ltd
24 Holborn Viaduct
HOW TO CONTACT US ABOUT YOUR RIGHTS AND DATA
We are regulated by the Information Commissioner’s Office and you have the right to make a complaint at any time to them. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Our website and SimpleMMO may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
INFORMATION COLLECTED ABOUT YOU
We have set out below the personal data about you we may collect, use, store and transfer when you interact with us through SimpleMMO. Personal data means any information from which you can identify you, it does not include information we collected on an anonymous basis.
• Identity & Contact Data includes your email address, username or similar identifier.
• Financial & Transaction Data includes your payment card details as well as details about payments to and from you and other details of any purchases you have made from us.
• 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 this website and SimpleMMO.
• Profile Data includes your username and password, purchases or orders made by you, information about your membership and any subscriptions, your profile and account preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, SimpleMMO and our services, including any content you post through our discussion boards.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data about you. This includes statistical or demographic data, which could be derived from your personal data but is not considered personal data in its own right as this data on its own would not allow anyone to directly or indirectly reveal your identity.
We do not knowingly collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How your data is collected
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by signing up to SimpleMMO and through your use of the game, as well as by filling any forms or by corresponding with us. This includes personal data you provide when you [:
create an account;
make in-game purchases;
request marketing to be sent to you;
communicate through our discussion boards;
enter a competition, promotion or survey; or
give us feedback or contact us.
Automated technologies or interactions. As you interact with our website and within SimpleMMO, we automatically collect about the device you use when you interact with us, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties. We will receive personal data about you from various third parties as set out below:
• Technical Data from analytics providers such as Google and DigitalOcean;
• Financial and Transaction Data from our providers of technical, payment and delivery services such as Stripe.
HOW WE USE YOUR INFORMATION
We collect, process, store and disclose personal data for a variety of different reasons, but in all cases when the law allows us to. We do not sell, share, disclose or use your data for anything else not covered by our policies.
The General Data Protection Regulation (“GDPR”) requires that companies processing personal data of EU citizens set out the specific lawful basis on which they process that data. For the personal data identified in this policy we rely on the following lawful basis to process your data:
1. Consent: when registered an account with SimpleMMO we ask you to consent to us using your data as set out in this policy. We use your consent as a legal basis for processing your personal data or for the purposes of marketing communications. You have the right to withdraw consent at any time by both deleting your SimpleMMO account and by contacting us.
2. Contractual Obligations: where we need to perform the contract we are about to enter into or have entered into with you.
3. Regulatory or Legal Obligations: where we need to comply with a legal obligation.
4. 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.
We have summarised below the various ways we use your personal data and our legal basis for doing so.
Type of data Lawful basis for processing including basis of legitimate interest
To register your SimpleMMO account (a) Identity
(b) Contact Performance of a contract with you
To facilitate and process your in-game purchases and subscriptions including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us (a) Identity
(e) Marketing and Communications (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey (a) Identity
(d) Marketing and Communications (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey (a) Identity
(e) Marketing and Communications (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(e) Marketing and Communications
(f) Technical Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(f) Marketing and Communications Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. In general we employ the following data control mechanisms when we use your personal data for the purpose of direct marketing:]
When you register for an account on SimpleMMO, you are invited to consent to receiving marketing and other promotional information from us. You may withdraw this consent at any time by contacting us. Withdrawing consent will not prevent us from sending service messaging about SimpleMMO (such as planned downtime, upgrades, patches or changes to our terms and policies).
Promotional offers from us
Where you have provided your consent, we may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or made in-game purchase from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
COOKIES AND OTHER TECHNOLOGIES
Cookies come in a variety of forms but are essentially small data files used to collect and store information about you. We use them on our website for a variety of different functions:
• for the smooth and safe operation of our website;
• to manage your preferences and remember you for future visits;
• to analyse how you use our website in order to continually make improvements.
The majority of these cookies are linked to your browser session (session cookies) and disappear once you close your browser. Others remain on your device for a longer period (persistent cookies).
INFORMATION SHARING AND DISCLOSURE
We share the information we collect or that is provided to us as follows:
Sharing with our Partners
We may share your personal data with the parties set out below for the purposes we have identified above.
• External Third Parties, who help us in providing SimpleMMO and our services. Currently, we use the following trusted Partners:
• Stripe &Google Pay: to securely process payments in respect of any purchases you make through SimpleMMO;
• Google Analytics: to help us analyse who users interact and use SimpleMMO which we then use to improve SimpleMMO and services;
• MouseFlow: to help us verify browser behaviour and help us improve our UX
• DigitalOcean: our cloud provider.
Unless identified, your data is hosted and processed within the UK or the EEA. Where we do utilize a third-party located outside the UK or the EEA, we ensure that any transfers are done on the basis of compliant transfer mechanisms.
HOW WE SAFEGUARD YOUR DATA
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.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
RETENTION AND DELETION
As a general rule, we retain your account data for as long as you keep your SimpleMMO account active. In the event you decide to delete your SimpleMMO account, we permanently delete your account data within 21 days after closure of your account.
We 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 data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for
which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data by contact us (see the below section for further information).
In some circumstances we will 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 DATA, YOUR RIGHTS
The title of this section says it all and as a citizen of an EU country you have a wide range of rights with regards to your data, which have, as of the 25 May 2018, been enhanced by the General Data Protection Regulation (“GDPR”).
You can enforce your rights by contacting us, or in most cases, by deleting your account and/or by ending your use of SimpleMMO.
1. Right to Correction: if you believe any of the information on your profile to be inaccurate you have a right to request that we correct this. This right also extends to various other information we collect about you which you can request a copy of (see Right to Copies below).
2. Right to Copies of your data: you have a right to request a copy of the information that we hold about you along with an explanation from us as to why we process that information. We will provide this information to you free of charge for a first request, but will charge for reasonable administrative costs for further requests.
3. Right to erasure: you have a right to request the deletion of your data at any time. If you submit such a request to us we will consider carefully and reply with an explanation as to why we are required to retain certain information either by law or for our own legitimate reasons. Where, after review,
we identify any data we do not need to retain for these purposes, we will delete that data as per your request.
Should you have any concerns about how we are processing your data, we invite that you submit those questions to our [email protected]
UPDATES TO OUR POLICY
As we further enhance our website and improve our services, we may make changes to this policy from time to time. If we make any major changes, or any changes which directly affect the services provided to you or the data collected or processed by us, we will notify you of those changes by a prominent banner on our website. However, we encourage you to periodically review this policy for the most up to date version.