Privacy Policy

In this Privacy Policy, terms such as "we", "us, "our" or similar expressions shall mean Grappl.

We take your privacy very seriously and are committed to protecting your personal data (meaning any information about you from which you can be identified). This Privacy Policy explains what personal data we collect when you: access the Grappl websites at http://grappl.co or use the Grappl official app; (the Services) or engage with Grappl on social media platforms (including the our Facebook, Twitter and Instagram pages); and/or when you otherwise interact or communicate with us. It also explains how we may use this data, and what rights you have in relation to such data.

If you are aged 12 or under (a child), or you are reading this on behalf of a child for whom you have parental responsibility, please refer to 11. CHILDREN AND PRIVACY.

We keep our privacy practices under review and may change this Privacy Policy from time to time by posting changes on the Services or otherwise notifying them to you. This version of the Policy is dated 06 August 2018.

Please read this Privacy Policy carefully:

1. Background

We are a "controller" under the General Data Protection Regulation (the GDPR) and other applicable data protection legislation (Data Protection Law). This means we are responsible for deciding how we use the personal data that we collect about you and, in accordance with the Data Protection Law, we will ensure that the personal data we hold about you is, at all times:

1. used fairly, lawfully, and transparently;

2. collected for limited, specific purposes only;

3. adequate, relevant to and limited to what is necessary for those purposes;
 4. kept accurate and up-to-date;

4. not kept for longer than is necessary; and

5. held securely.

We shall be accountable for and able to demonstrate our compliance with our obligations under the Data Protection Law, and this Privacy Policy is one of the ways in which we do that.

We have appointed a Data Protection Lead to oversee compliance with this Privacy Policy and our data protection compliance activities. The Data Protection Lead has also established a dedicated data protection team to provide the necessary support.

Personal Data We Collect About You

Personal data means any information about an individual from which that person can be identified. We may collect and use various types of your personal data:

• Registration Data: To access and use some elements of the Services you must create a Grappl account, by providing us with the information which is identified on the relevant registration page. We will also collect a username and password. Please note that some elements of the Services will not be available if you do not provide the required information. We may also ask or allow you to submit other optional information, including your gender, phone number, UK post code.

• Identity Data: We may also ask you to provide identification information when we provide other elements of the Services now and in the future: name, age, gender and social media handles/ usernames.

• Contact Data: When we want to communicate with you, or you with us, we use your email address, telephone numbers, social media handles/ usernames and location (country/ place of residence).

• User Data: We collect your usage and preference details related to your use of the Services such as language, game-play statistics, rankings, time spent playing, game profile, preferences, survey responses (as provided), feedback and other data that you provide to us as part of your account.

• Marketing and/ or Communications Data: We retain your preferences in receiving marketing messages from us and our commercial partners, and your communication preferences.

• Technical Data: Certain data is automatically generated and collected by us when you use the Services such as your IP address, MAC address and other device identifiers; your clickstream to, through and from the Services (including date and time); pages you viewed or searched for; length of visits to certain pages;

page interaction information (such as scrolling, clicks, and mouse-overs); methods used to browse away from the page.

Not all of the list above will necessarily apply to you - it depends on your use of the Services and your particular interaction and communications with us.

3. How We Collect Your Personal Data

You provide us with your personal data when you:

• access, use or play the Services;

• create a Grappl account for the Services;

• request information, marketing and other communications to be sent to you;

• enter a competition, promotion or survey;

• complete surveys or provide us with your feedback; and

• otherwise interact or correspond with us (including via email, social media or telephone).

We collect the Technical Data automatically as you interact with our Services by using cookies and other similar web technologies. Please refer to our Cookie Policy for more information.

We also use third party tools to help us manage and analyse our social media presence, and report on comments, mentions and other content that is posted about us on social media sites and other public channels and forums. These third parties’ activities, and their information collection and sharing practices, are subject to the terms of the relevant social media site, channel or forum. We will use this information in accordance with this Privacy Policy.

We use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to certain parts of the Services. This information is only used by us in a way which does not identify you. We do not make, and do not allow Google to make, any attempt to find out the identities of anyone visiting our website.

4. How and Why We Use Your Personal Data

We will only use your personal data where Data Protection Law allows us to. Data Protection Law says we can collect and use personal data on the following bases:

1. it is necessary for us to be able to perform an agreement with you.

2. it is necessary for our legitimate interests (and your interests and fundamental rights do not override those interests);

3. if we have your consent (which you can withdraw at any time); or

4. to comply with a legal obligation e. rules laid down by courts, statute or regulation.

Accordingly, we lawfully use your personal data in the following ways:

Delivering the Services: We use the Registration Data, User Data and Communications Data so that we can deliver the Services to you in an effective, efficient and accurate way. Without it we would not be able to deliver a tailored service to you or respond to issues with these Services that are identified by us or you, or ensure you get the most out of your experience. Therefore, we use this data on the basis that it is necessary for us to be able to perform our agreement with you (i.e. the terms and conditions of the relevant Services) and for our legitimate interests of delivering the Services in this way.

Operating the Services: We use the Technical Data in order to operate and administer the Services including as necessary for testing, analysis, maintenance, support, reporting and hosting of data. Therefore we use this data on the basis that it is necessary for our legitimate interests of operating the Services in this way. We also use Technical Data together with certain Identity Data and Contact Data to assist in security and fraud prevention, system integrity (such as preventing hacking, cheats and spam) and/ or to facilitate our response to a legal process. Therefore we use this data on the basis that it is necessary both for our legitimate interests in protecting the Services in this way and in order that we can comply with a legal obligation.

Competitions and promotions: We use Identity Data and Contact Data and any other personal data related to the entry (for example, a photograph) in order that we can administer contests, prize draws or other promotions including selecting the winners, delivering the prizes and publishing the results (as required by UK advertising regulations). Therefore, we use this data on the basis that it is necessary for us to be able to perform our agreement with you (i.e. the terms and conditions of the relevant promotion) and in order that we can comply with a legal obligation. If we want to use the personal data for any other purpose we will notify you and, if necessary, seek your consent at that time.

Marketing communications: We use the Identity Data and Contact Data to inform you of news, offers, events, competitions and promotions by specified media (including, if requested, by way of calendar notifications) which may be of interest to you and/ or we provide such data to our Clubs and/ or our official commercial partners so that they can do this. We give you the option of providing opt-in consent to receive different kinds of direct marketing communications from us or these third parties or deciding not to do so.

OPT-ING OUT: You can withdraw your consent and opt-out of marketing communications from us at any time by updating your Email Preferences (where you have signed up to our website) or by following the instructions provided to you in the relevant communication (for example, the 'unsubscribe' link in an email). Alternatively, you may contact us at info@grappl.co.uk. We may still need to send service emails to you from time to time.

Other purposes: We could have to use your personal data which we hold to protect your or someone else's vital interests for example to make contact in rare emergency situations. We could also have to use your personal data in connection with legal and regulatory matters such as our maintenance of business records, compliance with external reporting requirements and internal policies and procedures and responses to requests by government, law enforcement, regulators, courts, rights holders or other third parties including in respect of the use or misuse of intellectual property, such as our brand or media rights, or those of our licensees/commercial partners or their parties. Therefore we use this data on the basis that it is necessary both for our legitimate interests in protecting, defending and enforcing rights and interests in this way and also so that we can comply with legal obligations.

We will only use your personal data for the purposes for which we collected it as described above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

What if you do not want to share your personal data?

Unless otherwise specified above, generally we collect your personal data on a voluntary basis. However, please note that if you decline to provide certain mandatory personal data, you may not be able to access certain Services and we may be unable to fully respond to any inquiries you make.

5. Disclosure of Your Personal Data

We may disclose or share your personal data in the following circumstances:

Third Party Service Providers. We engage third party businesses to provide services to us or to you on our behalf, such as support for the internal operations of our Services (and related services), communications, data storage and delivering communications.

In providing their services, they may access, receive, maintain or otherwise use personal data on our behalf. Our service providers only use your personal data in accordance with our strict instructions to provide the relevant services and are not permitted to use your personal data for their own purposes, unless authorised by us to do so. Where this is the case you will be notified by us and provided with their privacy policies so you can understand how they will treat your personal data.

Commercial Partners. We may also disclose your personal data to our commercial partners where you have consented or requested that we do so. For example, when you enter a competition or sweepstake which is a joint promotion, or you request to receive certain marketing communications. You will be given clear information in each case before we disclose share your personal data.

Publicity and media. We may disclose your personal data publicly via the media, social media or on the Services. For example, when sharing a comment or opinion you have provided, or if you win a competition or promotion we may disclose your name online. In such cases, we will clearly notify you of the sharing, and you will have the choice not to participate or to otherwise object to such sharing, subject to our other legal obligations.

Legally Required. We may also disclose your personal data if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes.

Notwithstanding anything else in this Privacy Policy, we may share aggregate or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual and the individual cannot be re-identified.

6. Transferring Your Personal Data Outside the EU

Some countries outside of the European Union (EU) do not have laws that protect privacy rights and personal data as extensively as the UK and other countries within the EU. We do not generally or routinely transfer personal data outside of the EU but some of the organisations to which we may disclose personal data may be situated outside of the EU. If we do transfer your personal data outside of the EU, we will ensure that your personal data is protected to a similar degree, in accordance with Data Protection Law. We do this by ensuring one of the specific safeguards approved by the European Commission is in place. You can find further information about these safeguards at https://ec.europa.eu/info/law/law-topic/data- protection_en.

If you would like further information on the specific mechanism used by us when transferring your personal data out of the EU you can contact us using the details provided below.

7. Security of Your Personal Data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed (a Data Security Breach). In addition, we limit access to your personal data to those employees, contractors and other third parties who have a business need to know. They will only use 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 Data Security Breach and will notify you and any applicable regulator where we are legally required to do so.

Where we have given you or you have chosen a password which enables you to access certain Services, you are responsible for using reasonable care in keeping this password confidential.

8. Links to Other Sites

The Services may contain links to other websites, applications and environments that are not owned or controlled by us (the Other Sites). The owners and operators of those Other Sites are responsible for their collection or use of your personal data and you should check their respective privacy policies. Unless specifically referred to otherwise, this Privacy Policy applies to the Services only and not the Other Sites.

9. Data Retention

We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any accounting, reporting or other legal requirements, in accordance with our Data Retention Policy.

To determine the appropriate retention period, we review - in addition to the purposes of use and how we can achieve them - other relevant factors such as the nature and scope of the personal data, the potential risks to data subjects from a Data Security Breach, and the applicable legal requirements, for example the limitation period for which legal claims can be made in court.

For example, all non-activated Grappl accounts are deleted after 21 days and all non-authorised child accounts are deleted immediately if a parent withholds consent and after 21 days if a child’s account is not verified.

10. Your Rights

Under Data Protection Law, you have certain rights (depending on the circumstances) in connection with your personal data, which include:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are using it lawfully, provided always that this does not adversely affect the rights and freedoms of other people;

• Request correction of the personal data that we hold about you. Where any of the information we hold about you is incorrect or incomplete we will act promptly to rectify this, including where you have requested us to do so;

• 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 use it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to our use (see below);

• Object to use of your personal data where we are relying on our legitimate interests (see above) and there is something about your particular situation which makes you want to object to our use on this ground;

• Withdraw your consent to our use of your personal data where we do so in reliance on your consent. Once we have received notification that you have withdrawn your consent, we will no longer use your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law;

• Request the restriction of use of your personal data. This enables you to ask us to suspend the use of personal data about you, for example if you want us to establish its accuracy or the reason for using it; and

• Request the transfer of the personal data you have provided, on the basis of consent or for a contract with us, to you or a third party where technically feasible.

We are committed to respecting your rights. You may action your rights (as may be applicable) by contacting us using the details provided below and we will comply with your requests within a reasonable period unless we have a lawful reason not to do so.

Requests should be made in writing and to ensure that personal data is dealt with carefully and confidentially we will require the requestor to provide verification of their identity and all applications must be accompanied by copies of at least two official documents, which show your name, date of birth and current address (for example, driving licence, birth/ adoption certificate, passport, recent utility bill).

In responding to such requests, we will explain the impact of any objections, restrictions or deletions requested.

We will not charge you a fee to exercise your rights unless your request is clearly unfounded or excessive, in which case we may charge you a reasonable fee. Alternatively, we may refuse to comply with the request in such circumstances.

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK data protection authority. The ICO's contact details as are follows: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; Tel: 0303 123 1113 (local rate) or 01625 545 745; https://ico.org.uk/global/contact-us/

11. Children and Privacy

It is important to us that children can enjoy our Services in a responsible manner. We encourage parents and guardians to supervise their children's online activities by, for example, adopting control tools available from online services and software suppliers that help provide a child-friendly online environment including by preventing children from disclosing their personal data online without parental permission.

We are committed to safeguarding children's personal data collected online, and to helping parents and guardians and their children learn how to exercise control over personal data while exploring the Internet.

If you have parental responsibility and would like to review any personal data that we have collected online from your child, have this information deleted, and/or request that there be no further collection or use of your child’s personal data or if you have any questions about our Privacy Policy or practices, you may contact us at info@grappl.co

12. Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us using the following contact details: info@grappl.co