SNATCH PRIVACY NOTICE
Thank you for visiting our website and even bigger thanks if you’re going to pre-register for our new game. We have outlined our privacy notice below, please take a look.
WHY YOU NEED TO READ THIS
It’s a bit like telling you to eat your vegetables. We want to do what’s best for you. When you visit our website or download our game, you will be giving us your information in a variety of ways as described in this policy (your personal data). This isn’t about giving you the small print. It is our commitment to you that we want to protect and respect your privacy. We want to try and make it as clear as possible to you what you are agreeing to when you visit our site and when you download our game. If you have any questions, just email us at DPO@snatchhq.com and we will try and answer them!
We respect your privacy and make the following privacy commitments to you:
We will only collect, keep, use and share your personal data when the law allows us to.
We will be as clear and open as we can with you on what personal data we collect and how it will be processed.
For as long as we maintain records of your personal data, we will keep it up to date and protect it with appropriate safety measures.
This privacy notice will inform you how we fulfil those commitments and tell you about your privacy rights and how the law protects you.
1. INTRODUCTION, WHO WE ARE AND HOW TO CONTACT US
Purpose of this privacy notice
This privacy notice gives you information on how we collect and process your personal data through your use of our Snatch App (“the App”), our website at www.snatchhq.com (“the Site”) and our social channels (“the Channels”), including any data you may provide through the App, the Site or the Channels when you sign up to our marketing emails or take part in a competition.
The App, the Site and the Channels are not intended for anyone under the age of 18 and we do not knowingly collect data relating to anyone under 18.
Bandana Media Group Limited is the controller and responsible for your personal data.
We have appointed a data privacy officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy officer using the details set out below.
Our full details are:
Full name of legal entity: Bandana Media Group Limited, a private limited company registered in England and Wales under company number 11427544.
Name of Data Privacy Officer: Vaida Petrosiute
Email address: DPO@snatchhq.com
Postal address: Bandana Media Group Limited, 3rd Floor, 56a Poland Street, London, England, W1F 7NN
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.
Changes to this privacy notice
We will update this privacy notice from time to time to reflect changes in our business. All such changes will be posted to the Site and if we consider it to be appropriate we will notify users of any material changes in the App. This version was last updated on 18th September 2018.
The App, the Site and the Channels 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, plug-ins and applications and are not responsible for their privacy statements. When you leave our App, Site and Channels, we encourage you to read the privacy notice of every third-party website, plug-in and application you visit.
2. THE PERSONAL DATA WE COLLECT
Personal data is any information about an individual from which that person can be identified.
We may collect, use, store and transfer the following different kinds of personal data about you:
Identity Data includes first name, last name, title, date of birth and gender.
Contact Data includes delivery address, email address and telephone number including country prefix.
Technical Data includes internet protocol (IP) address, login data, device type (e.g., mobile handset or tablet), connection type (e.g., mobile data or WiFi), access status/HTTP status code, browser information (language, type and version), time zone setting, the date and time of interactions with the App or Site, current and historic location, browser plug-in types and versions, operating system and platform, other technology on the devices you use to access the App or Site, and App version.
Profile Data includes your username (or similar identifier) and password, brands you interact with, competitions you enter, your interests, preferences, in-game friends, feedback and survey responses.
Usage Data includes information about how you use the App and Site.
Marketing Preferences Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Social Media Data includes your social media account name, gender, general interests, location and age.
We also collect, use and share anonymised aggregated data such as statistical or demographic data for any purpose i.e. Men aged 25-35 liked this prize. Anonymised aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
We do not collect any financial data (i.e., information used to make financial transactions such as bank account and payment card details) or any sensitive categories of personal data about you.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
Direct interactions.You may give us your Identity, Contact, Profile and Marketing Preferences Data by filling in forms (e.g., when you register on the App or the Site) or by corresponding with us by post, phone, email or otherwise.
Automated technologies or interactions.As you interact with the App or the Site, we may automatically collect Technical, Profile and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third party sources.We may receive personal data about you from the following third parties:
Technical, Profile and Usage Data from Google Analytics: Google Analytics, a web analytics service provided by Google, Inc. (“Google”) also places cookies on your computer, to enable Google to provide us with activity reports relating to the Site. Google uses this data only to provide us with information on how users use the Site and does not associate your IP address with any other data held by Google. The information generated by Google cookies about your use of the platform (including your IP address) will be transmitted to and stored by Google on servers in the United States. You may refuse these cookies by selecting the appropriate settings on your browser or by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB.
Social Media Data from social media providers: The social media sites we received Social Media Data from, and their respective privacy statements, are Facebook (https://www.facebook.com/privacy/explanation) and Twitter (https://twitter.com/en/privacy).
4. HOW WE USE YOUR PERSONAL DATA
This section explains the reasons why we process your personal data and our legal bases for doing so.
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 we need to perform the contract we are about to enter into or have entered into with you.We process your personal data (including location data, which is required to play Snatch) when necessary for contractual reasons, such as to administer your account registration and competition entries and to provide services that you have requested.
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. For example, your personal data may be used:
to create in-App gameplay (for example, where parcels are in relation to your location);
for the administration of your prizes and to contact you (directly or indirectly (via secure service) through third party brand partner) about prizes you have won (for example a postal address to send your prize to);
to gain insight into your behaviour and preferences (for example by analysing the prizes you like). Outside of prize fulfilment we will never share your personal data with brand partners, but may share aggregate information e.g., “Men 25-30 where the biggest redeemers of this prize”;
to contact you with surveys and feedback requests;
to analyse your in-App activity and the way you use the Site;
to provide bespoke social media content (for example by analysing your general interests);
to create targeted advertising across all our social media channels (for example by analysing responses to posts and existing advertisements);
to find out more about our digital community (for example by analysing the age ranges of our followers).
Where we need to comply with a legal or regulatory obligation, such as where we are legally required to respond to certain requests by government or law enforcement authorities.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. To contact you with marketing messages which you have requested or agreed to receive from us (for example via a branded newsletter).
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered a competition and, in each case, 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 Contacting us at any time.
5. HOW WE SHARE YOUR PERSONAL DATA
Snatch will not sell your personal data. However,we may have to share your personal data with third parties for the purposes set out above(e.g.,as required to operate the Site or the App, to provide our services to you or to administer your account).
We may share your personal data with social media sites to enable them to provide marketing messages that you have agreed to receive from them.
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
Our backend servers are located in London and Ireland.
We use third party processors to collect, export, process and store personal data on our behalf. We use data processors located outside the European Economic Area (the “EEA”) only after taking such steps as are required to ensure that personal data they process on our behalf that is a transferred outside the EEA receives protection equivalent to that provided in the EEA.
Our processors are either certified as compliant with the EU-U.S. Privacy Shield Framework where they are located in the USA (see European Commission: EU-US Privacy Shield) or have entered into an agreement with us containing the model clauses approved by the European Commission as providing contractual protection equivalent to that provided by the data protection regulations applicable in the EEA (see European Commission: Model contracts for the transfer of personal data to third countries).
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. HOW WE LOOK AFTER YOUR PERSONAL DATA
We have put in place appropriate security measures that are designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These measures include data encryption for communications between device and data centres, hardened security zones and restricted access policies. Where we keep your personal data files on local devices these devices are protected by Apple or Google’s app packaging security requirements for publishing to App Stores, and the hardware security native to the device. We regularly review our security systems to ensure that your personal data remains safe and secure.
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. HOW LONG WE RETAIN YOUR PERSONAL DATA
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
If we regard you as an inactive user, we will delete your personal data except where retention is necessary to enable us to enforce our legal rights, to comply with any laws or regulation or to protect the rights, property or safety of our employees.
Generally, we will not regard you as an inactive user, if:
you remain a registered subscriber to our mailing list;
you remain a registered user of the App; or
have won a prize in the last 3 months.
We will regard you as an inactive user, if you have not opened any email communication from Snatch or interacted in any way with the App for 24 months.
In some circumstances we 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.
9. YOUR LEGAL RIGHTS
Your rights to withdraw consent and to object
Wherever we rely on your consent to process personal data, you always have a right to withdraw that consent.
You also have the right to object to any use of your personal data for direct marketing purposes, as well as to processing that we undertake based on our legitimate interests (including profiling).
You can withdraw consent at any time by contacting us at firstname.lastname@example.org, via the App or the Site: http://www.snatchhq.com/contact/
Your other personal data rights
In addition to your rights to withdraw your consent and to object, you have the right to ask us:
for access to information about your personal data or for a copy of your personal data
to correct or delete (“to be forgotten”) your personal data
to restrict (i.e. stop any active) processing of your personal data
to provide you with certain personal data in a structured, machine readable format and to transmit that data to another organisation
These rights may not always apply, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have a compelling legitimate interest in keeping. If this is the case, then we’ll let you know when we respond to your request.
If you wish to exercise any of the rights set out above, please contact our data privacy officer.
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 administration fee if allowed by applicable law. Where allowed by applicable law there may be an administrative charge for supply of copies of data.
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). 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.
Well done! You’ve read the whole thing, or just skipped to the end. Remember that this document is here to help you understand our commitment to protect your data and privacy, and to ensure you know how we are using any information we collect or need to store. If you have any questions or need more information, please do get in touch…