PRIVACY POLICY
Privacy Policy for users :
1 Introduction
This Privacy Policy sets out how your personal information is collected and processed by the company named in the Identity Information when you visit our website “Justwin”, if you attend one of our events or purchase our products, and by continuing to use this website, you acknowledge that you have read this policy.
2 Information we collect
2.1 Information you give us. You may give us information, including information that can identify you (“personal information”), when you use our Website, correspond with us, enter into any of our competitions, promotions or surveys, post on our websites, subscribe to receive our newsletter, purchase our goods or services, book events via the Website, create an account or use our Apps or when you communicate with us and at us through one of our social media platforms, for example through our chatbot tools. Where we request required information from you, we will collect the information contained in the relevant forms or pages. You may choose to provide additional information to us when you contact us or otherwise interact with us.
2.2 If you are a regular user of our Website or App, you may wish to create an Account (“Account”) with us. The information that you provide when setting up your Account may include your name, Account username, email address, gender, country of residence, telephone number or if applicable, your social media credentials. If you register to hold an Account with us, you will also create a unique password, which enables you to access your Account. We will also collect information regarding your favourite content on our Apps and Website (such as video you like) and information relating to content you have selected for offline access (such as videos on our Apps which you download to watch later).
2.3 If you purchase any games, services, apps (including in-app purchases) or other goods on our Website, we will also collect your delivery address, billing address and payment information. Please note that we will not be storing your payment information, this will be done via a third-party payments company.
2.4 If you visit one of our restaurants, we may also collect information about your preferences associated with your restaurant visit, such as dietary requirements or your visit preferences.
2.5 If you subscribe to receive one of our newsletters or receive other forms of direct communications from us, then you may provide us with your name, email address, gender, date of birth and interests.
2.6 When you use our Websites or Apps, we may use your personal information to create specialised recommendations to enhance your user experience. This can include recommending content for you to watch based on your viewing history or Facebook “likes” and interests (as applicable). We will not collect your Facebook, Twitter or Google+ username or password, but we may collect details from these websites that confirm whether you are logged-in to the App using your Facebook, Twitter or Google+ accounts. This information is used to access and extract certain information about you from your Facebook, Twitter or Google+ profiles to enhance your user experience and provide you with meaningful content. This is information that you make available to the public on your profile. We do not access your personal account settings.
2.7 With your consent, our Apps may make use of GPS tracking in order to provide you with location-based functions and the Apps may also access the photos and videos that you store on your mobile device to allow you to upload videos and photos for use within the Apps. Finally, the Apps may use push notifications to send you notifications, for example, the App may send you a notification when another player beats your high score. When you first use the App, you will be asked if you want to activate these functions in your settings menu. If you choose not to activate these functions, or to deactivate them later on, you may not be able to use the App’s full scope of services.
2.8 Information we collect automatically. When you visit our Website, use our Apps, we may automatically collect the following information: your IP address, log-in information, location information, browser type and version, browser plug-in types and versions, operating system and platform, information about your visit including the URL clickstream to, through and from our Website, your advertising ID (if this is supported by your device such as an Apple product or Google product),products you viewed or searched for, videos you have accessed, download errors, length of visits to certain pages, page and App interactions, media download for offline access, screen resolution, device processing power and memory, playback errors and buffering issues, user behaviour such as length of Apps use, and unique device identifiers (for example an IMEI address (a unique number assigned to mobile phones that is used by GSM networks to help them identify valid mobile devices)). We collect information automatically through the use of various technologies, including through “cookies” and “web beacons”.
2.9 We may also collect information about you through our security systems when you visit our premises or attend our events.
3 Why we use your information
3.1 We use the information we collect in order to provide you with the best possible experience when you access our Website and Apps and engage with us, including by using our services and products. This includes using your information for the following purposes:
• (a) providing and improving our products and services: we use your information in order to provide you with the products and services you have requested, including when making a purchase, booking an event, sending you confirmation emails or contacting you regarding your Account. We use your information to improve and adapt our Website, Apps, products and services to better suit the behaviours and technical capabilities of our users;
• (b) creating and managing your Account: we use your information in order to create your Account and manage our relationship with you. We also use your information to communicate with you regarding your Account and our services;
• (c) administering the Website and Apps: we use your information in order to administer our Website and Apps for internal operations, including troubleshooting purposes and to understand any errors you may encounter when using our Website and Apps;
• (d) improving use and content of our web pages and Apps: we use your information in order to improve the content of our web pages and Apps and ensure that it is presented in the most effective manner for you and your devices;
• (e) safety and security: we use information collected on our Website and Apps as part of our efforts to keep our Website and Apps safe and secure and to help manage and administer our IT systems. We use information collected through our security systems to help keep our premises and individuals attending our events safe and secure.
• (f) marketing: we use your information in order to communicate with you and keep you up to date with our activities and events and those of third parties that you may be interested in and to make suggestions and recommendations to you on our Website and Apps about goods or services that may interest you. We will provide you with this information via email (subject to your prior consent if legally required), push notifications on our Apps, personalised notifications on our websites, targeted ads on our Website and Apps and third party platforms, text, social media or telephone;
• (g) online advertising: we use your information in order to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you. We also use your information when communicating with you through social media in order to build and maintain our social media brand;
• (h) personalising and tailoring your experience: where permitted by law, we may combine information we receive from third party sources, including from social media websites, with information you give to us and information we collect about you, including cookie and web beacon information. We may use this information and the combined information for learning more about your preferences as our customer, for enhancing your user experience on our Website and Apps and for providing you with information, content and offerings tailored to your needs;
• (i) providing a consistent experience across devices and platforms: we will match information collected from and provided by you on one device or platform with information collected from and provided by you on other devices and platforms;
• (j) providing customer service and managing any complaints or requests: we may use your information in order to provide you with a more efficient customer care service and managing any complaints or requests on your behalf;
• (k) to make necessary disclosures and law enforcement: we may use your information in order to make necessary disclosures in response requests which We are legally required to comply with, to law enforcement or regulatory authority, body or agency or in the defence of a legal claims. Furthermore, to enforce our Terms and Conditions and/or this Policy; and
• (l) administering a sale, transfer or reorganisation of one of our business entities.
4 Information security
4.1 We apply physical, technical and administrative measures to protect your personal information that is under our control from unauthorised access, collection, use, disclosure, copying, modification or disposal. All information you provide to us is stored on secure servers.
4.2 Where you have a password, which enables you to access our Website or App, you are responsible for keeping this password secure and confidential.
5 International transfers
5.1 Given that the Internet is a global environment, using the Internet to collect and process personal information necessarily involves the transmission of data on an international basis. While we generally store all of the personal information that we collect about you through our Website or App in your region (for example for European visitors, in the European Economic Area), it is possible that your personal information will be transmitted to parties outside your region (where data protection laws may be different e.g. in the United States) including our affiliates.
5.2 If such transfer happens, we have implemented safeguards and data protection solutions to ensure your information is adequately protected in any third countries e.g. by using standard contractual clauses or relying on Privacy Shield where relevant. If you would like to obtain the details of such safeguards, you can request these by contacting us by email detailed in section 11.
6 Questions, Concerns, Complaints about this Policy and DPO Contact Details
6.1 If you have a question, concern or complaint about this Policy or our handling of your information, you can contact us: Data Privacy, justwin@justwincompany.com
