- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- CALIFORNIA CONSUMER PRIVACY ACT
- CONTACT A DATA PROTECTION AUTHORITY
1. Important information and who we are
- purchase or download our products;
- use our services;
- create an account on our website or one of the apps;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- We also collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology
The website is not intended for children and we do not knowingly collect data relating to children on there.
The apps are meant to be played by children, and we carefully control and limit what information we collect.
An Adult User can review or change the information they provided when registering for a Service, including by adding or removing Child Users to the Account, by updating information through the Parent or Guardian Section of the Service.
When we change or delete any Personal Information at your request, we will make good faith efforts to make the changes in our then-active databases as soon as reasonably practicable. Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules.
- Email address: firstname.lastname@example.org ;
- Postal address: Hatch House Farm, West Woodhay, Newbury, Berkshire, RG20 0BH.
You have the right to make a complaint at any time to the Information Commissioner’s Office (the 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 or another supervisory authority so please contact us in the first instance.
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 your relationship with us.
Third party links
The apps do not have external third party links, but we do collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (i.e. anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Contact Data includes billing address, delivery address, email address and telephone number(s);
- Identity Data includes first name and last name when given; we only collect a child's first name when this is entered
- Marketing and Communications Data includes your preferences in receiving marketing from us.
Profile Data includes:
- your email address and password;
- purchases/orders placed by you or downloads of apps or digital content from our website;
- your interests, preferences, feedback, reviews and survey responses;
Technical Data includes:
- internet protocol (‘IP’) address;
- your login data;
- your browser type and version;
- your time zone setting and location;
- your browser plug-in types and versions;
- your operating system and platform; and
- other technology on the devices you use to access our website;
- unique user IDs that we ascribe to you;
Transaction Data includes details about:
- payments to and from you;
- deliveries to you and any returns;
- details of products you have purchased/ordered or downloaded from us;
Usage Data includes information about how you:
- use our products and services;
- respond to direct marketing that we send to you.
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.
If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products/services). In this case, we may have to cancel the provision of the products/services but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
direct interactions. You may give us your Identity, Contact and Transaction Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- purchase or download our products;
- create an account on our website or in an app;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
third parties. We will receive personal data about you from various third parties as set out below:
- Technical Data from:
- analytics providers;
- advertising networks; and.
- search information providers.
- Transaction Data from payment processing and delivery service providers such as Shopify and PayPal.
- Technical Data from:
4. 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 we need to perform a contract we are about to enter into or have entered into 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 obligation.
Click ‘lawful basis’ to find out more about the types of lawful basis that we will rely on to process your personal data.
Purposes for which we will use your personal data
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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose / Activity
Type(s) of Data
Lawful Basis for Processing, Including Basis of Legitimate Interest
To register you with a customer account on our website or app.
Performance of a contract with you.
To process and (where applicable) deliver your orders, including managing payments, fees and charges. For delivery and returns, we will share your personal data with our delivery providers. For payments, we will share your personal data with one of our payment providers.
Performance of a contract with you.
Recovering money owed to us.
Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship with you, which will include:
To enable you to partake in a prize draw, competition or complete a survey.
To administer and protect our business, our website, and apps including:
To deliver relevant website and app content and advertisements to you and to measure and understand the effectiveness of the advertising we serve to you.
Necessary for our legitimate interests (to study how customers use our products and services, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our:
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website and apps updated and relevant, to develop our business and to inform our marketing strategy).
To form a view on what products and services you may want, need or be of interest to you and to make suggestions and recommendations (via our website or apps) to you about products and services that may be of interest to you.
Necessary for our legitimate interests (to develop our products and services and to grow our business).
To send you suggestions and recommendations about products and services that may be of interest to you (i.e. marketing).
To create aggregate data.
Necessary for our legitimate interests (to understand users of the website and apps – e.g. which demographics purchase which products, where they are located etc.).
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
You will only receive marketing messages from us if you have permitted these or requested these from us.
You can ask us to stop sending you marketing messages by:
- following the opt-out links on any marketing message sent to you; or
- contacting us at any time.
However, where you opt out of receiving these marketing messages, we may still continue to process your personal data for other purposes.
We will not share your personal data with third parties for marketing purposes.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- External Third Parties as set out in the Glossary;
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 (where they are acting as our processors) 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
Whenever we transfer your personal data out of the UK (including where the source of that data is the USA), we must have a lawful basis on which to do so. For those third parties outside the UK to whom we transfer your personal data (listed in the External Third Parties), we ensure a similar degree of protection is afforded to it by:
- transferring to countries that have been deemed to provide an adequate level of protection for personal data (an ‘adequacy decision’); or
- where there has been no adequacy decision, using a standard contract that has been approved for use in the UK and which ensures personal data has the same protection as it has in the UK.
Please contact us if you want further information (including a copy of the standard contract, where applicable) on the specific mechanism used by us when transferring your personal data out of the UK.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used/accessed in an unauthorized way, altered or disclosed. 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. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for (including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements). We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Otherwise, we will erase your personal data promptly once it has been (so far as we are able to establish) over 12 months since you last visited our website.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- request access to your personal data;
- request correction of your personal data;
- request erasure of your personal data;
- object to processing of your personal data;
- request restriction of processing your personal data;
- request transfer of your personal data;
- right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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 fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
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). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- App or Apps means the Readiculous or Word Tag games available for download on the Apple iOS App Store and the Google Android Play Store.
- 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.
- Legitimate interest means processing your personal data to pursue a particular legitimate interest (whether ours or those of third parties). 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 personal 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.
- Complying with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
EXTERNAL THIRD PARTIES
Hatch House Games Limited uses a variety of third-party service providers to help us provide services related to our own services. Service providers may be located inside or outside of the UK, and the European Economic Area (“EEA”). We hold Data Processing Agreements (DPA) in place with all the third-party services, that guarantee that adequate safeguards are put in place with respect to the protection of such Personal Data as required by EU’s GDPR Data Protection policies. We do not sell personal information to third parties.
The following are examples of these:
- Payment processing providers (acting as controllers):
- PayPal, Inc. (incorporated and registered in Delaware, USA with company number C3842984 and whose registered office is at 2221 North 1st Street, San José, CA 95131);
- Shopify Inc. (incorporated and registered in Canada with company number 847871746 and whose registered office is at 151 O'Connor Street, Ground Floor, Ottawa, ON, K2P 2L8);
- Stripe Inc. (incorporated and registered in Delaware with company number 270465600 and whose registered office is at 510 Townsend Street, San Francisco, CA 94103);
- Delivery service providers (acting as controllers):
- Shipbob Inc. (incorporated and registered in Delaware, USA with company number 5531564 and whose registered office is at 120 N. Racine Avenue, Suite 100, Chicago, Illinois).
- Service providers (acting as processors):
- Amazon Web Services EMEA SARL (incorporated and registered in Luxembourg with company number B186284 and whose registered office is at 38, Avenue John F. Kennedy, L - 1855), a provider of cloud computing and storage services;
- Appsflyer UK Ltd (incorporated and registered in England and Wales with company number 10246990 and whose registered office is at 5th Floor Merck House, Seldown Lane, Poole, BH15 1TW), a provider of data analytics services;
- Google UK Limited (incorporated and registered in England and Wales with company number 03977902 and whose registered office is at Belgrave House, 76 Buckingham Palace Road, London, SW1W 9TQ), a provider of data analytics services.
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 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;
- you have objected to our use of your personal 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.
At this time, we do not respond to internet browser ‘do not track’ requests/signals.
We use the following cookies:
strictly necessary cookies. These are cookies that are required for the operation of our website. They include (for example) cookies that:
- enable you to log into secure areas of our website;
- use a shopping cart; or
- make use of e-billing services;
- analytical or performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works. For example, by ensuring that users are finding what they are looking for easily;
- functionality cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region);
- targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.
If you would like more information about the cookies used on our website, please contact us.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to use some or all of our website.
All cookies will expire after 12 months (at the latest).
12. California Consumer Privacy Act
Californian consumers can access our California Consumer Privacy Act notice by clicking here.
13. Right to Contact a Data Protection Authority
You have the right to contact your Data Protection Authority.
If you have a concern about how we collect and use information, please contact us. You also have the right to contact your local Data Protection Authority if you prefer. Contact details for Data Protection Authorities in the EEA are available here.
To contact the Swiss authorities please visit this website. To contact the UK authority please visit this website. Where appropriate, your local data protection authority may also forward the matter to the Department of Commerce or FTC for consideration.