This policy applies to your access to our Site and other sites of ours (together our Site) whether through your PC, your mobile telephone or handheld device or otherwise (Device) and your use of any of the services accessible or available through our Site or other sites of ours (Services).
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Our Site is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Important information and who we are
by PLAY TRUANT LTD (registered in England and Wales is the controller and is responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this policy).
Our full details are:
- Full name of legal entity: Play Truant Ltd
- Name or title of DPO: Jono Yates
- Email address: [email protected]
- Postal address: Flat 20, 9 Balmes Road, London, N1 5TQ
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 or other competent supervisory authority of an EU member state if our Site is downloaded outside the UK.
This version was last updated on 29 January 2019. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to when you next log onto our Site. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of our Site or the Services.
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 our relationship with you.
Third party links
Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data.
- Contact Data.
- Financial Data.
- Transaction Data.
- Device Data.
- Content Data.
- Profile Data.
- Usage Data.
- Marketing and Communications Data.
- Location Data
We explain these categories of data here.
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.
How is your personal data collected?
We will collect and process the following data about you:
- Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on our Site, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use our Site, subscribe to any of our Services, search for a Service, make a Site purchase, share data via a Site’s social media functions, enter a competition, promotion or survey, and when you report a problem with a Site, or our Services. If you contact us, we will keep a record of that correspondence.
- Information we collect about you and your device. Each time you visit one of Our Services Sites we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies.
- Location Data. We may use GPS technology or other technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
- Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
|Device Data||from the following parties: analytics providers such as Google based outside the EU; advertising networks based inside or outside the EU; and search information providers based inside or outside the EU.|
|Contact, Financial and Transaction Data||from providers of technical, payment and delivery services based inside or outside the EU;|
|Identity and Contact Data||from data brokers or aggregators based inside or outside the EU;|
|Identity and Contact Data||from publicly available sources based inside or outside the EU;|
- Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract we are about to enter or have entered with you.
- 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 or regulatory obligation.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
Purposes for which we will use your personal data
|Purpose/activity||Type of data||Lawful basis for processing|
|To access our site and register you as a new Site user||Identity
|To process in-Site purchases and deliver Services including managing payments and collecting money owed to us||Identity
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you including notifying you of changes to our site or any Services||Identity
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
|To enable you to participate in a prize draw, competition or complete a survey||Identity
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)
|To administer and protect our business and this Site including troubleshooting, data analysis and system testing||Identity
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)|
|To deliver content and advertisements to you
To make recommendations to you about goods or services which may interest you
To measure and analyse the effectiveness of the advertising we serve you
To monitor trends so we can improve our site
Marketing and Communications
Necessary for our legitimate interests (to develop our products/Services and grow our business)
Disclosures of your personal data
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table:
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
Our external third parties may be based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, 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 by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our site or Our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.
In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.
In some circumstances we will 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.
In the event that you do not use our site for a prolonged period then we may treat the account as expired and your personal data may be deleted.
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; or
- 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.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at [email protected]
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal third parties:
Other companies in the Play Truant acting as joint controllers or processors.
External third parties;
Service providers acting as processors who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers based in consultancy, banking, legal, insurance and accounting services.
HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based who require reporting of processing activities in certain circumstances.
Market researchers and data analytics companies.
Advertising technology companies and agencies.
Description of categories of personal data
- Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
- Contact Data: billing address, delivery address, email address and telephone numbers.
- Financial Data: bank account and payment card details.
- Transaction Data: includes details about payments to and from you and details of in-Site purchases.
- Device Data: includes the type of device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), network information, your operating system, the type of browser you use, time zone setting.
- Content Data: includes information stored on your Device, including friends’ lists, login information, photos, videos or other digital content, check-ins.
- Profile Data: includes your username and password, in-Site purchase history, your interests, preferences, feedback and survey responses.
- Usage Data: includes details of your use of any of our Site or your visits to any of Our Services or Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
- Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Location Data: includes your current location disclosed by GPS technology or other technology.