GENBA DIGITAL LIMITED – PRIVACY NOTICE
Date of last revision: 3 May 2018
We take your privacy very seriously. Please read this privacy notice (‘Notice’) carefully as it contains important information about how your personal information will be used.
1. About us
For the purposes of data protection legislation, the “controller” is Genba Digital Limited, a company incorporated in England and Wales (company registration number 09491005) having its registered office at Genba Digital Ltd. Company No: 09491005. Registered office: 7 Bell Yard, London WC2A 2JR, i.e. this is the company who is responsible for, and controls the processing of, your personal data (“we”). If you would like to contact us in relation to this Notice please send an email to email@example.com.
This Notice uses the term “Business Representative” to refer to an individual who communicates with us in his or her capacity as an employee or representative of one of our business clients. This Notice uses the term “End User” to refer to an individual who purchases a digital video game from one of our retailer partners, or their licensed distributors.
3. Information about Business Representatives
If you are a Business Representative then we process your business contact information in order to conduct business with your employer or principal. The lawful basis for this is that we have a legitimate interest in doing so to provide our services to our business clients.
4. Information about End Users
We do not receive information that identifies End Users. We may, however, receive anonymous information from our retailer partners, or their licensed distributors when a game is purchased, including the following “Transaction Information“:
- 4.1. the game purchased;
- 4.2. IP addressof the purchaser;
- 4.3. the country in which the game was purchased;
We use this information for quality control, anti-fraud and anti-piracy purposes. We may also use it in order to comply with applicable laws.
5. Who we may provide your personal information to.
We may provide Business Representative contact information and Transaction Information to the following recipients:
- 5.1. other companies within our group;
- 5.2. our employees, consultants, agents and service providers;
- 5.3. video game publishers and retailers that we provide digital logistics services to;
- 5.4. law enforcement agencies in connection with any investigation to help prevent unlawful activity.
6. International transfers
While we are based in England, we may transfer your personal information to a location (for example to a secure server) outside the European Economic Area, where we consider it necessary or desirable for the purposes set out in this notice. In such cases, to safeguard your privacy rights, transfers will be made to recipients to which a European Commission adequacy decision applies (this is a decision from the Commission confirming that adequate safeguards are in place for the protection of personal data), or will be carried out under standard contractual clauses that have been approved by the European Commission as providing appropriate safeguards for international personal data transfers, copies of which are available to view on the Commission’s website.
7. Data retention period
We carefully consider the personal data that we store, and we will not keep it in a form which identifies individuals for longer than is necessary for the purposes set out in this Notice.
If you are a Business Representative, we may store your business contact details for direct marketing purposes and, where you have given your consent, or where we are otherwise permitted to do so, we may contact you about our products or services that may be of interest to your employer. If you prefer not to receive any direct marketing communications from us, you can opt out at any time by sending an email to firstname.lastname@example.org.
9. Data security
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way.
10. Your information rights
We draw your attention to your following rights under data protection law:
- (i) the right to request a copy of the information that we hold about you and supplementary details about that information;
- (ii) the right to have inaccurate personal data that we process about you rectified,
- (iii) the right (in certain circumstances) to have personal data that we process about you blocked, erased or destroyed;
- (iv) the right to object to the processing of your personal information for the purposes described in clauses 3 and 8;
- (v) the right (in certain circumstances) to request a copy of your personal data that you have provided to us, in a machine-readable format, in order for you to transmit those data to another organisation.
Further information about your information rights is available on the ICO’s website.
12. Changes to this Notice
We may change this Notice from time to time. You should check this Notice on our website https://www.genbadigital.com/ regularly to ensure you are aware of the most recent version.
13. How to complain
If you have a complaint about the way we handle your personal data, please contact us at email@example.com. In addition, you have a right to raise such a complaint with the UK information regulator, the ICO.
14. How to contact us
We welcome your feedback and questions. If you would like to contact us in relation to this Notice please send an email to firstname.lastname@example.org.