Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data when you interact with or use our website or if you use any of our services in any manner. It also explains your rights in relation to your personal data and how to contact us in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to applicable data protection laws, including the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA).
1. Key Terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our
Entity Games Limited, a company registered in Ireland under company number 764276
Personal data
Any information relating to an identified or identifiable individual
Special category personal data
Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership; Genetic and biometric data (when processed to uniquely identify an individual); data concerning health, sex life or sexual orientation
Date subject
The individual who the personal data relates to
2. Personal Data We Collect About You
We may collect and use the following personal data about you:
- website information such as time and date of your visit, and the pages you visit along with your physical location when you visit them.
- contact information such as name, email address and telephone number
- billing and financial information such as billing address, bank account and payment information
- services information such as details of services we provide to you and information we receive from you to allow us provide that service.
3. How Your Personal Data Is Collected
We collect most of this personal data directly from you either in person, by telephone, email and via our website.
However, we may also collect information from other sources such as:
- directly from a third party e.g. our service providers, credit reference agencies, customer due diligence providers;
- from publicly accessible sources, e.g. Companies Registration Office, Companies House;
- from cookies on our website—for more information on our use of cookies, please see our cookie policy.
4. How and Why We Use Your Personal Data
Under data protection law, we can only use your personal data if we have a proper reason or ‘lawful basis’, such as:
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
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. You have the right to withdraw consent to marketing at any time by contacting us at the notified email address.
For ease of reference, 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.
| Personal Data | Purpose of use | Lawful basis for processing |
|---|---|---|
| Identity, contact and financial information | Providing our services to you. Recruitment and selection of employees. Administering billing, processing payments etc. in connection with the services we provide; To comply with our legal and compliance obligations including with regard to record keeping, anti-money laundering and tax laws; | Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how clients use our services) Necessary for prevention and detection of fraud, money laundering and other crimes or for the purpose of responding to a binding request from a public authority or court |
| Identity and website information | To administer and protect our business To deliver relevant website content To use data analytics to improve our website, services, marketing, customer relationships and experiences | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) |
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, for example:
- we have your explicit consent;
- the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
- the processing is necessary to establish, exercise or defend legal claims
5. Marketing
We may use your personal data to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or services.
We have a legitimate interest in using your personal data for marketing purposes (see How and why we use your personal data). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.
We may ask you to confirm or update your marketing preferences if you ask us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations outside our group for marketing purposes.
6. Who We Share Your Personal Data With
We routinely share personal data with:
- third parties we use to help deliver our products and/or services to you, e.g. payment service providers;
- other third parties we use to help us run our business, e.g. IT and IT security, telecommunications, data storage or website hosts.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure compliance with applicable data protection laws and that they can only use your personal data to provide services to us and to you.
We may also need to disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations, or share information with other parties, such as potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.
If you would like more information about who we share our data with and why, please contact us (see How to contact us below).
7. How Long Your Personal Data Will Be Kept
We only keep your personal data for as long as is necessary for the purpose for which it was originally obtained, and/or in accordance with any requirements imposed by the law. This means that the period of time for which we store your personal data may depend on the type of data we hold. To determine the appropriate retention period of personal data, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process your personal data and any legal requirements to retain your data. We will not keep your personal data for longer than necessary. When it is no longer necessary to keep your personal data, we will delete or anonymise it.
8. Transferring Your Personal Data
On occasion, we may need to transmit your personal data outside of the European Economic Area. In these circumstances, we will ensure that the transfer complies with our data protection obligations, and we will ensure that the transfer agreement is based on an approved transfer mechanism, such as the European Commission’s standard contractual clauses or an adequacy decision.
9. Your Rights
You have the following rights which you can exercise:
| Access | The right to be provided with a copy of your personal data |
| Rectification | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data, in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party, in certain situations |
| To object | The right to object: – at any time to your personal data being processed for direct marketing (including profiling); – in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests |
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
For further information on each of those rights, including the circumstances in which they apply, please see guidance available from the Data Protection Commission at https://www.dataprotection.ie/.
If you would like to exercise any of those rights, please:
- email, call or write to us — see below: ‘How to contact us’; and
- provide enough information to identify yourself (e.g. your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you;
- let us know what right you want to exercise and the information to which your request relates.
We will only charge you for requests to access your personal data where they are unreasonable, unfounded or excessive. If, after contacting us, you are still not satisfied with our response, you have the right to lodge a complaint with the Data Protection Commission. Please see www.dataprotection.ie for further information.
10. Keeping Your Personal data Secure
We have appropriate technical and organisational measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
11. Changes To This Privacy Policy
We may make changes to this policy from time to time. To ensure that you are always aware of how we use your personal data we will update this policy from time to time to reflect any changes to our use of your personal data. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Where it is practicable, we will notify you by email of any significant changes. However, we encourage you to review this policy periodically to be informed of how we use your personal data.
12. How To Contact Us
You can contact us by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are: dataprivacy@entitygames.com