Privacy Policy

This Privacy Policy sets out how Cygames Europe Ltd. (“we”, “us” and “our”) will process as data controller the personal data of (i) consumers and (ii) employees of corporate customers, suppliers and other business partners. It also sets out the measures and processes we have put in place to ensure its adequate protection. Providing such information is one of the requirements of the UK GDPR (as defined in the Data Protection Act 2018).

This Privacy Policy does not form any contractual relationship between you and us, and we may amend it from time to time.

1. LAWFUL PROCESSING

We will only process your personal data:

where you have given your consent (you may withdraw your consent at any time, by making a request using the contact details set out below);
where the processing is necessary to provide our products or services to you (or your employer);
where the processing is necessary to respond to a request from you (or your employer);
where the processing is necessary to maintain our relationship with you (or your employer); or
where the processing is necessary for compliance with our legal and regulatory obligations.

2. WHAT PERSONAL DATA WE COLLECT ABOUT YOU

2.1 We may process the following types of personal data about you:

Consumers

Your name, email address and other contact details, and date of birth;
Details of your preferences for types of marketing events or materials;
Details of your access to our premises, systems and websites; and
Your messages, feedback or contributions to customer surveys and questionnaires.

Employees of corporate customers, suppliers and other business partners

Your name, email address and other contact details;
Your role, position and/or job title within your employment;
Details of your preferences for types of marketing events or materials;
Details of your access to our premises, systems and websites; and
Your messages, feedback or contributions to surveys and questionnaires.

2.2 It may be mandatory for you to provide us with your personal data, to enable us to manage our business and operations, to maintain our relationship with you (or your employer), to provide our products or services to you (or your employer) or to comply with our legal and regulatory obligations. If you fail to provide your personal data when requested, we may not be able to maintain our relationship with you (or your employer) or to provide our products or services to you (or your employer).

2.3 We make every effort to maintain the accuracy and completeness of your personal data which we store and to ensure all of your personal data is up to date. However, you can assist us with this considerably by promptly contacting us if there are any changes to your personal data or if you become aware that we have inaccurate personal data relating to you. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

3. HOW WE COLLECT PERSONAL DATA

Consumers

We usually collect your personal data from the information you submit during the course of your relationship with us. This will typically be through you sending us emails and other correspondence, the forms and documents used when you sign up to our marketing or market data news lists.

We may also collect your personal data from other sources such as our group companies, magazine publishers, PR firms, fraud prevention agencies, credit reference agencies and the records of governmental agencies.

Employees of corporate customers, suppliers and other business partners

We usually collect your personal data from the information you/your employer submits during the course of your/your employer’s relationship with us. This will typically be through you/your employer sending us emails and other correspondence, business cards, the forms and documents used when you/your employer signs up to our marketing or market data news lists, when you are named as an authorised person to trade on behalf of your employer, the sign up information you/your employer uses to access any of our products or services either on your own behalf or on behalf of your employer.

We may also collect your personal data from other sources such as our group companies, fraud prevention agencies, credit reference agencies and the records of governmental agencies.

4. HOW WE USE PERSONAL DATA

Consumers

We may process your personal data for the following purposes:

to respond to your messages or posts to us;
to provide you with promotional and marketing materials about products and services that we think you may be interested in;
to manage, develop and improve our product range, services, information technology systems and websites;
for monitoring and assessing compliance with law and our policies and standards;
to comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies;
to carry out money laundering checks, financial checks and credit checks and for fraud and crime prevention and detection purposes;
for administrative purposes in relation to the security of and access to our websites and applications;
to comply with court orders and exercise and/or defend our legal rights;
for any other legitimate business purpose; and
as otherwise permitted or required by any applicable law or regulation.

Employees of corporate customers, suppliers and other business partners

We may process your personal data for the following purposes:

to provide you/your employer with requested products or services;
to respond to your/your employer’s messages or posts to us;
to provide you/your employer with promotional and marketing materials about our products and services that we think you/your employer may be interested in;
to manage, develop and improve our product range, services, information technology systems and websites;
for monitoring and assessing compliance with law and our policies and standards;
to comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies;
to carry out money laundering checks, financial checks and credit checks and for fraud and crime prevention and detection purposes;
for administrative purposes in relation to the security of and access to our systems, premises, platforms and websites and applications;
to comply with court orders and exercise and/or defend our legal rights;
for any other legitimate business purpose; and
as otherwise permitted or required by any applicable law or regulation.

5. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Your personal data may be transferred to (including accessed in or stored in) a country or territory outside the UK. In particular, we may share your personal data with our group companies located in Japan. While the UK has confirmed that Japan ensures an adequate level of protection for personal data, we may also transfer your personal data to countries whose laws may not offer the same level of protection of personal data as are enjoyed within the UK. If your personal data is transferred to such countries, we will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the UK GDPR. You can obtain copies of the relevant safeguard documents by making a request using the contact details set out below.

6. WHEN WE MAY DISCLOSE YOUR PERSONAL DATA

We do not and will not sell, rent out or trade your personal data. We will only disclose your personal data to the following recipients:

to our group companies for the purposes set out in this Privacy Policy;
to companies approved or designated by you;
to third parties who process your personal data on our behalf (such as our systems providers including cloud providers);
to third parties who process your personal data on their own behalf but through providing you (or your employer) with a service on our behalf (such as our suppliers);
to companies providing services for money laundering checks, credit risk reduction and other fraud and crime prevention purposes and companies providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such information is shared;
to any third party to whom we assign or novate any of our rights or obligations;
to any prospective buyer in the event we sell any part of our business or assets; and
to any government, regulatory agency, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request.

7. HOW WE PROTECT YOUR PERSONAL DATA

We are committed to safeguarding and protecting your personal data and will implement and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect your personal data from accidental or unauthorised destruction, loss, alteration, disclosure or access.

8. YOUR RIGHTS IN RELATION TO THE PERSONAL DATA WE COLLECT

8.1 Under certain circumstances, you have the following rights in relation to our processing of your personal data:

The right of access
The right to rectification
The right to erasure
The right to restriction of processing
The right to object to processing
The right to data portability

8.2 If you wish to exercise any of your rights, please contact us using the contact details provided below. We may request that you prove your identity in order for us to comply with our security obligations and to prevent unauthorised disclosure of data.

9. HOW LONG WE WILL HOLD YOUR PERSONAL DATA FOR

We will only retain your personal data as long as necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.

10. MARKETING EMAILS

If you tell us that you do not wish us to provide you with marketing materials, we will not contact you further for the purpose of marketing emails. You can contact us using the contact details set out below.

11. USE OF COOKIES AND OTHER TECHNOLOGIES

A “cookie” is a small text file that is stored on a user’s hard drive or mobile device. Cookies are generated by web servers when the user enters an internet page, and are passed to the user’s computer or mobile device and stored for subsequent future access. They perform a number of functions associated with browsing websites and are used for a variety of different purposes, such as tracing users from page to page on an internet site. This can enhance a user’s experience on a website, enabling the site to be personalised according to, for example, a user’s preferences and browsing activities.

For more information about how we use cookies, please read our Cookies Settings.

Additionally, we use Google Analytics, a web analytics service provided by Google LLC (“Google”) to gather data about how users use our website. To find out how Google Analytics collects and processes data, please visit the website “How Google uses data when you use our partners’ sites or apps” (www.google.com/policies/privacy/partners/).

12. HOW WE UPDATE OR CHANGE THIS PRIVACY POLICY

We may change or update parts of this Privacy Policy in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. You will not necessarily be directly notified of such a change. Therefore, please ensure that you regularly check this Privacy Policy so you are fully aware of any changes or updates.

13. HOW YOU CAN CONTACT US

If you have any queries about the contents of this Privacy Policy or your personal data, or wish to make a request in relation to your personal data, please contact us using the details set out below:

Email:

14. HOW TO LODGE A COMPLAINT TO THE DATA PROTECTION AUTHORITY

We commit to resolving complaints about our use of your personal data. If you consider that we have breached your data protection rights, please contact us using the details set out above. If you are not satisfied with the response, you are entitled to lodge a complaint with the Information Commissioner’s Office.

Date Updated: 22nd March 2023