ScaleMyGames Privacy Notice

Last updated: 23 October 2020

OUR PRIVACY PROMISE

Your privacy is important to ScaleMyGames ("we", "us" and "our"). We are committed to protecting your personal data and being transparent about the personal data we hold and use and, wherever possible, giving you control over how we use your personal data.

This notice is intended to be communicated to you in a concise, transparent, intelligible, and easily accessible manner, but we appreciate that you may have queries or want to seek clarification as to its terms. If so, please contact us (using the details set out at paragraph 2 below) and we will endeavour to respond to you as soon as possible.

We may make changes to this notice from time to time, including as may be necessary or prudent to reflect any changes in the ways in which we process personal data or any changes in data protection laws. Any changes and updates to this notice will be posted on the ScaleMyGames Website. Please check this notice regularly so that you are aware of any changes.

1. INTRODUCTION

Please read this notice carefully. Among other things, it explains:

What personal data we collect about you;
Why we collect and use your personal data and the legal bases we rely on for processing;
Who we disclose your personal data to;
Where we store your personal data;
How long we keep your personal data; and
Your rights regarding the personal data you provide to us.

2. WHO WE ARE AND OUR CONTACT DETAILS

For the purposes of data protection laws, the data controller is ScaleMyGames Limited, a company registered in England and Wales (company no. 11974510) with its registered office at New Broad Street House, 35 New Broad Street, London EC2M 1NH.

If you have any queries regarding this notice or the way in which we process your personal data, please contact us at:

Email: terms@scalemygames.io

Address: Data Protection, New Broad Street House, 35 New Broad Street, London EC2M 1NH

3. CHANGES TO YOUR PERSONAL INFORMATION

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes or if you become aware that any personal data that we hold about you is not accurate.

4. WHEN DO WE COLLECT YOUR PERSONAL DATA

We may collect information direct from you and use, disclose and store it when you:

access, use or create an account on the ScaleMyGames website at https://scalemygames.io/, our video game(s), platform and apps;
correspond/interact with us via email, phone, social media or other channels;
make any enquiry;
purchase, request or subscribe for a product or service from us;
request technical support or other customer care support;
participate in competitions, surveys and questionnaires or provide us with a review or feedback;
post content on our social media pages or any of our other channels.

Where lawful, we may also obtain personal data from third parties (including third party platforms) and we may process that information where it is needed in order to provide our products and services to you, including access to our games or where it is needed for our internal administrative purposes or for marketing and business development purposes.

We may also automatically collect certain Technical Data relating to your device and your activities on the ScaleMyGames Website and/or within our video games or apps. We may also collect such data from third parties such as analytics providers (including Google) and third party platforms and organisations within advertising networks (including Facebook).

5. WHAT PERSONAL DATA WE COLLECT

The type of personal data we process may include (as applicable) the following:

Categories of Data	Description of Data
Identity Data	Name, address, date of birth, age, marital status, title, gender, nationality, country of residence, job title, role, employer, company/organisation details in an email signature, user name, bio and any profile data that is publicly available eg. in your Facebook profile.
Contact Data	Email address, address, telephone number, mobile number, social media handles, other information in an email signature.
Employment Data	CV, résumé, educational background, employment history and any other information you provide in connection with the same.
Correspondence Data	Information which you provide in, or we learn about you from, any correspondence or communications with us, including details of any enquiries or requests for technical support or customer care support and any other information you provide to us.
Usage Data	Device IP address, the pages of the ScaleMyGames Website that you visit, usage information for the ScaleMyGames Website and details of your activities in any of our video games and apps, your use of social sharing features such as Likes, comments and links that you share (eg. via Facebook Comment or Share).
Technical Data	Type of device, unique device identifier (e.g. an IMEI number, IDFA, IP, or Mac address), network information, the type of operating system, platform and browser you use, location, time zone settings and other device related information and online identifiers.
Marketing and Communications Data	Your marketing preferences and communication preferences and any information that you may provide to us in any reviews or feedback.
Financial and transaction data	If you make any payments in respect of one of our video games, your payment details (such as bank account and payment card details) will be collected by the platform provider or an external payment service provider. We will not collect or access any such details and you should contact the relevant third party for information relating to use of your financial and transaction data.
Children	you must be 13 years old or over in order to play any of our video games. We do not knowingly collect any personal data relating to anyone under this age.
Analytics Data	we may receive aggregated statistics and insights from advertising, analytics and attribution providers and third party platforms on which our video games and apps are available. We use this information to help us to understand how people are using our products and services and how our ads are performing. This information does not contain any personally identifiable information.

6. WHY WE COLLECT AND USE YOUR PERSONAL DATA

6.1 We use your personal data for a number of purposes but only where we are allowed to by the law.

6.2 We may process your personal data in any circumstances where such processing is necessary:

in order to perform any agreement we have entered into with you or in anticipation of any agreement we may enter into with you;
to comply with any applicable law or regulation; and/or
for the purposes of the legitimate interests pursued by us or a third party. These legitimate interests include the purposes identified in the table below at paragraph 6.5 but also include other commercial interests and our internal administrative purposes. Where we rely on legitimate interests as the lawful basis for processing your personal data, we will put in place appropriate safeguards to protect your data and to ensure that your interests or fundamental rights and freedoms are not overridden by those legitimate interests.

6.3 We may also process your personal data where we have your consent. Where we rely on consent as the lawful basis for processing your personal data, you have the right to withdraw your consent at any time and if you wish to do so, you should contact us using the contact details set out in paragraph 2 above. Where we obtain your consent to send you marketing communications, you can unsubscribe by following the unsubscribe link within the communication. The withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal or the lawfulness of processing based on other lawful grounds.

6.4 We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

6.5 Information about the purposes for which we use your personal data, the types of personal data we process to achieve these purposes, and the lawful basis by which we process it, is set out in the table below:

Purpose/Activity	Type of Personal Data Processed	Lawful Basis for Processing
Registration	Identity Data Contact Data Correspondence Data Usage Data Technical Data Marketing and Communications Data	Consent Performance of a contract Compliance with a legal obligation Our legitimate interests to operate our business and fulfil our legal and contractual obligations
Provision of our products, services and games	Identity Data Contact Data Correspondence Data Usage Data Technical Data	Performance of a contract Compliance with a legal obligation Our legitimate interests to operate and improve our business, fulfil our legal and contractual obligations
Business Operation and Maintenance	Identity Data Contact Data Correspondence Data Usage Data Technical Data	Performance of a contract Compliance with a legal obligation Our legitimate interests to operate and protect the ScaleMyGames Website, apps, games and our social media channels (including troubleshooting, incident management and data breach management, data analysis, product and system testing, system maintenance, support, reporting and hosting of data)
Customer Relationship Management	Identity Data Contact Data Correspondence Data Usage Data Technical Data Marketing and Communications Data	Consent Performance of a contract Compliance with a legal obligation Our legitimate interests to respond to enquiries, messages and requests, operate, develop and improve our business and to fulfil our legal and contractual obligations
Business Development	Identity Data Contact Data Correspondence Data Usage Data Technical Data Marketing and Communications Data	Our legitimate interests to define types of customers for our products and services, develop and improve our business and to inform our marketing strategy
Business Management	Identity Data Contact Data Correspondence Data Usage Data Technical Data	Performance of a contract