Outright Games privacy policy
(November-2024)
This privacy policy sets out how Outright Games Limited uses and protects your personal data. You can click through to the specific areas set out below.
1. IMPORTANT INFORMATION AND WHO WE ARE (paragraph 1)
2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU (paragraph 2)
3. HOW IS YOUR PERSONAL DATA COLLECTED? (paragraph 3)
5. DISCLOSURES OF YOUR PERSONAL DATA (paragraph 5)
6. INTERNATIONAL TRANSFERS (paragraph 6)
7. DATA SECURITY (paragraph 7)
8. DATA RETENTION (paragraph 8)
9. YOUR LEGAL RIGHTS (paragraph 9)
10. CONTACT DETAILS (paragraph 10)
11. COMPLAINTS (paragraph 11)
12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES (paragraph 12)
13. THIRD PARTY LINKS (paragraph 13)
1. IMPORTANT INFORMATION AND WHO WE ARE
Privacy policy
This privacy policy gives you information about how Outright Games Limited collects and uses your personal data through your use of this website, including any data you may provide when you sign up to our newsletter or take part in one of our prize giveaways.
This website is not intended for children and we do not knowingly collect data relating to children.
Controller
Outright Games Limited is the controller and responsible for your personal data (collectively referred to as “Outright“, “we”, “us” or “our” in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 10).
2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name, title, date of birth.
• Contact Data includes delivery address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
• Usage Data includes information about how you interact with and use our website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. If you contact us to provide feedback or otherwise to communicate with our business, we will collect this information.
We may also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
• Your interactions with us. You may give us your personal data by submitting your details on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• subscribe to our publications;
• request marketing to be sent to you;
• enter a competition or promotion; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
• Technical Data is collected from the following parties:
• analytics providers such as Google based outside the UK.
4. HOW WE USE YOUR PERSONAL DATA
Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
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 the various categories of 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.
1- Purpose/Use
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Dealing with your requests, complaints and queries
Type of data
(a) Identity
(b) Contact
(c) Marketing and Communications
Legal basis
(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 manage our relationship with you
2- Purpose/Use
To enable you to partake in a prize draw, competition or complete a survey
Type of data
(a) Identity
(b) Contact
(c) Usage
(d) Marketing and Communications ç
Legal basis
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to understand how customers use our products/services, to develop them and grow our business)
3- Purpose/Use
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data
(a) Identity
(b) Contact
(c) Technical
Legal basis
(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
4- Purpose/Use
To use data analytics to improve our website, customer relationships and experiences and to measure the effectiveness of our communications and marketing Type of data
(a) Technical
(b) Usage
Legal basis
Necessary for our legitimate interests (to define types of customers for our products, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
5- Purpose/Use
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods that may be of interest to you
Type of data
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Marketing and Communications
Legal basis
Consent, having obtained your prior consent to receiving direct marketing communications
Direct marketing
You will receive marketing communications from us if you have indicated you would like to via our website or other sign-up method of communication.
We may also analyse your Identity, Contact, Technical, and Usage Data to form a view which products and offers may be of interest to you so that we can then send you relevant marketing communications.
Third-party marketing
We will not share your personal data with any third party for their own direct marketing purposes without your express written consent.
Opting out of marketing
You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us privacy@outrightgames.com.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.
Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
• Necessary cookies. These are cookies that are required for the operation of our website. These essential cookies are always enabled because our website won’t work properly without them. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website.
• Statistics cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Preference cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Marketing cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. [We may also share this information with third parties for this purpose so that they can serve you with relevant advertising on their websites.
Choices about cookies
You can choose which analytical, functionality and targeting cookies we can set by clicking on the button(s) contained in the Cookie settings pop-up:
Strictly Necessary cookies
Statistics cookies
Preference cookies
Marketing cookies
You can also choose to “Reject All” cookies in the cookie banner.
However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
• Internal Third Parties, being Outright Games SL, a company based and registered in Spain which is within the Outright Games group of Companies.
• We may share your personal data with external third parties for the purposes set out in the table “Purposes for which we will use your personal data” above. For example, when you sign up to receive a newsletter, we may share your personal data as necessary for third parties to provide the service on our behalf.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We may share your personal data within the Outright Games group of companies. This will involve transferring your data outside the UK to our overseas offices in Spain.
Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:
We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.
Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:
• We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK.
7. 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.
8. DATA RETENTION
How long will you use my personal data for?
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: see paragraph 9 below for further information.
9. YOUR LEGAL RIGHTS
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
• Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in paragraph 4 for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
• If you want us to establish the data’s accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us. See contact details (paragraph 10).
No fee usually required
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. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
10. CONTACT DETAILS
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
• Email address: privacy@outrightgames.com
• Postal address: Unit 54 Merlin House, Meteor Way, Lee-On-The-Solent, Hants, England, PO13 9FU
11. COMPLAINTS
If you are in the UK, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
If you are outside of the UK you have the right to make a complaint at any time to your national Data Protection Authority (DPA), this is the body that protects privacy rights in your country or location (see a list of EU DPAs here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en).
We would, however, appreciate the chance to deal with your concerns before you approach the ICO or DPA so please contact us in the first instance.
12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new email address.
13. THIRD PARTY LINKS
This website 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. When you leave our website, we encourage you to read the privacy policy of every website you visit.
