We will also tell you about your privacy rights and how the law protects you.
1. Important information and who we are
We do not knowingly collect or receive data relating to children.
Full name of legal entity: MilkBubblesGames Limited
Email address: firstname.lastname@example.org
Postal address: Preston Park House, South Road, Brighton, United Kingdom, BN1 6SB
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.
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.
2. The data we collect about you
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 (anonymous data).
We may collect, use, store, transfer or receive from third parties’ different kinds of personal data about you which we have grouped together as follows:
Identity Data includes names, titles, dates of birth and other identifiers (such as usernames you use to play our published games or that you use on third party platforms such as the Epic Games Store).
Contact Data includes your address and email address or telephone number, if you provide these.
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, and other technology on the devices you use to access our website.
Usage Data includes information about how you use our website.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
We do not 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.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, email or otherwise. This includes personal data you provide when you:
subscribe to our mailing list or request other marketing to be sent to you;
provide us with any services;
enter any competition or promotion that we may run from time to time; or
give us feedback or otherwise contact us.
Collection from Third Parties. We may also receive your Identity and Contact Data from third parties (such as the Epic Games Store) that you have provided your personal data to through direct interactions.
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.
When you download and play our games, we may also automatically collect generic, non-personal data about your in-game preferences.
This data will show generic trends in relation to our published games and will be anonymised (meaning that identification of any player from that generic data will not be possible). More information can be found under the heading “Collection of Anonymous Game Related Data” below.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where you give consent for us to use your personal data.
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.
Where we need to comply with a legal obligation.
Please refer to the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
We will get your consent before sending any marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us or following the unsubscribe prompts on any marketing communications we may send to you via email or by contacting us via email at email@example.com.
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.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
You will receive marketing communications from us if you have signed up to our mailing list and have not opted out of receiving our newsletter or other marketing material.
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.
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 analytical cookies on our website via Google Analytics, which have a duration of 1 year 1 month and 4 days. These cookies allow us to recognise and count the number of visitors to our website, to see how visitors move around our website when they are using it, and to see how much time is spent on our website. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. In addition to collection of the above, Google Analytics also collects Technical Data, including your IP address, and shares this data with Google in the United States of America. For more information about how Google uses Technical Data obtained via Google Analytics, and how this data is protected, please click here.
We also use strictly necessary cookies on our website which are required for the operation of our website, including for security and stability purposes. These cookies include svSession, XSRF-TOKEN, ssr-chasing, hs, _wixCIDX, _wix_browser_sess, SmSession, TS, consent-policy, bSession & fedops.logger.defaultOverrides (amongst others).
You can use your browser settings to block all cookies (including essential cookies). However, you may not be able to access all or parts of our website if you choose to do this.
Collection of Anonymous Game Related Data
When you play our published games, we may use certain technology (contained within the games’ files) to automatically collect generic, anonymous, non-personal data about your activities within any particular game. This may include (but is not limited to):
Which characters a player chooses to play as the most
How well the player performed in the game.
Details about when the game is opened and closed (including how long it is played for);
Details about performance and achievements throughout various parts of the game;
User settings opted for; and
the resulting information being referred to below as “Game Data”.
Game Data will be shared with us when you access our published games with an internet connection.
The Game Data collected whilst you play our games will be both generic and anonymised, meaning that we cannot identify you from it directly. Accordingly, it will not constitute personal data. Our collection of Game Data through our published games will be limited to information relating to both in-game preferences and game-related information.
We do not combine generic and anonymised Game Data with any personal data.
We collect Game Data in this manner for the purpose of improving our games and our players’ enjoyment of the games. We will always ask you for permission to collect Game Data before we do so, and we will also provide you with an opportunity to opt-out of collection at any time. For further information, please refer to the user settings menu in our games, or contact us via email at: firstname.lastname@example.org.
Change of purpose
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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above:
External Third Parties as set out in the Glossary.
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 with third parties. It may be the case that some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
Where we use certain service providers outside of the UK that are not located in an area that has been deemed to provide an adequate level of protection for personal data, we will use specific contracts approved for use in the UK which give personal data the same protection 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.
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.
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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
Please see the Glossary for further information. You may also wish to visit the Information Commissioner’s Office website to find out more about these rights.
If you wish to exercise any of the rights set out above, please contact us.
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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are
External Third Parties
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
IT service providers in the event that any enquiry requires investigations by such providers.
HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data 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. 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) and there is something about
your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in 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.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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. 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.