1. Who, What & Why

This Privacy Notice is produced by Wych Way Studios Ltd (“we”) for users (“you”) of our products and services (“services”). You should not use our services unless you are happy for your data to be processed in the manner laid out in this document and you also agree to the Terms of Service document.

We want you to understand how and why we collect, use or share your information when using our services. We respect your privacy and only intend to collect or use information at the level needed in order for us to deliver our services, to understand and improve our business and for any legal requirements.

2. Your Responsibilities

It is vital that the information we hold about you is accurate and current. You agree to keep us informed of any changes that happen in the information you have provided to us – for example your email address. You must not provide us with any information if you do not agree in full with this document.

If you provide any information on behalf of someone else, you must have their consent.

Children

Our services are intended for general audiences. We do not knowingly collect, use, solicit or distribute any personal information from anyone under the age of 13. Do not send us any personal information about yourself or about anyone else under the age of 13, without exception. If we learn we have collected personal information from anyone under the age of 13 it will be deleted as soon as possible. If you believe we may have any information about or from someone under the age of 13, contact us immediately.

3. Types of Information

In order to carry out our services, we must sometimes collect anonymous or personal information. Personal data is classified as that where an individual can be identified. The data we process may include (with examples of their use, as a non-exhaustive list):

Anonymous Data

Anonymised Usage Data to monitor things like the number of active players
Anonymised Tracking Cookies to understand how users are using our website

Personal Data

Name / Username to allow our services to be personalised to you
Email Address for account creation and to alert you about your account
IP Address for security monitoring

Adverts

We may display adverts within our services provided by third parties who may use cookies to collect additional information in order to serve adverts that are more relevant to you. They may be able to identify you as a unique user. You should consult and agree to their Privacy Notices before using the relevant services.

4. How Data Is Collected

We collect personal information about you through direct interactions where you provide us with information. This may be through ad-hoc communications such as email, or through a sign-up or contact form. We may obtain certain information such as your approximate geographic location via gaming markets that you may use to pay for our services.

5. How Data Is Used

We will process your data only in accordance with specific permissions. Usually these will be:

1. You have given us consent to the processing of your personal data for specific purposes.
   For example by signing up to a newsletter.
2. Where it is necessary for the performance of a contract to which you are party, or in order to take steps at your request prior to entering into a contract.
   For example to be able to provide a refund from a purchase you have made.
3. Where it is necessary for compliance with a legal obligation to which we are subject.
   For example to monitor network access to keep data secure under data protection law.
4. Where it is necessary for our legitimate interests or those of a third party, and where your interests and fundamental rights do not override those interests.
   For example we need to monitor how players are using our services.

Most of the data we process is within the remits of permissions ii, iii and iv. Contact us if you wish to obtain full details of the basis for which we process each type of personal data.

6. How Data Is Processed

We process data on secure physical devices. We also retain third-party back up data for the purposes of data resilience. We share some data with third-parties in the process of providing our services. All data is processed and transferred under conditions which we deem to provide adequate protection under data protection legislation for both privacy and security.

7. Geography

We are based in the United Kingdom. We may store or transfer data to other locations such as within the European Union or USA where we deem the data protection in place is adequate. Where we use third parties to process your data, they may also transfer your data to other countries in line with their own privacy notice.

8. How Long Data Is Processed For

We process data only for as long as required to deliver our services to you, for legal requirements and so long as we have a legitimate interest.

9. Security

We take reasonable steps to ensure the security of your data but this can not be fully guaranteed by anyone. Do not provide data to us if you do not accept this risk.

10. Requesting Data or Deletion

You may contact us at any time to request a copy of, or to request the deletion of, your data.

11. Changes to the Privacy Notice

We reserve the right to change this Privacy Notice from time to time to better reflect the current circumstances. Any changes will be made visible by revising the date on this document. We encourage you to review the Privacy Notice whenever you use our services in order to understand how your information may be collected, used or shared. If you use our services we must assume that, having agreed to these terms in the first instance, your use of our services comes after having consented to the most up to date Privacy Notice.

12. Complaints

You have the right to complain at any time and we ask that you contact us in the first instance. If you are not happy with our response, you may contact the Information Commissioner’s Office.

13. How to Contact Us

If you have any queries relating to this document or about your data, please contact us via: datarequest@wychway.studio

This is the end of the document
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