1. INTRODUCTION AND IMPORTANT INFORMATION
At Game Retail Ltd, we are committed to protecting your privacy and will only use the information that we collect about you in accordance with all applicable data protection and privacy legislation, regulations and guidance.
This website and any of our online services are not intended for children under the age of 13 and we do not knowingly collect children’s data without parental consent. Where we offer “pay-to-play” and similar services to children in our Belong arenas, it is strictly prohibited for a child under the age of 13 to access the online element of these services such as our online booking and tournament platforms without parental consent.
Postal address: Unity House, Telford Road, Basingstoke, RG21 6YJ
Telephone number: +44 (0) 1256 784164
You have the right to make a complaint at any time to the relevant supervisory authority. In the UK this is the Information Commissioner's Office (ICO, www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This policy was last updated on the date shown at the top of the document. We reserve the right to make further changes to this policy from time to time. We will always notify you in advance of any changes that involve a new use of your data that may not be compatible with the purpose for which we originally collected them. See Change of Purpose for more details.
It is important that the personal data we hold about you is accurate and current so please keep us informed if your personal data changes during your relationship with us.
2.HOW WE COLLECT YOUR DATA
Your personal data, is any information that can be used to identify you directly or indirectly. It does not include data where the identity has been removed (anonymous data). We collect your data in a number of ways. You can expand each of the sections below for more details.
We collect and process your personal data when you engage with us directly in store, including our Belong arenas, or when you visit our websites, including any data you may provide when you:
- create an online account;
- download the GAMEApp;
- sign up to our newsletter or one of our loyalty schemes;
- pre-order or purchase a product or service;
- trade-in a pre-owned device or game;
- top-up your GAMEWallet account or buy Belong arena time;
- book a station in a Belong arena;
- register to take part in a UK Masters or any Belong Arena tournament;
- enter a competition;
- take part in a customer survey or contact customer services;
- register as a seller on GAME Marketplace.
THIRD PARTY SOURCES OF YOUR PERSONAL DATA
We may receive personal data about you from a number of third parties including:
- Providers of third party marketplaces, when you use these to buy products provided by GAME
- Social media organisations
- Customer research and feedback agencies
- Providers of tournament management services for our Belong arenas
- Providers of third party hosted IT systems such as GAME Marketplace
- Payment services providers
- GAME ESports and Events (GEE), within the GAME Group of companies
TECHNICAL DATA WE COLLECT ABOUT YOU WHEN YOU BROWSE OUR WEBSITES
3. THE TYPE OF DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We collect your name and title when we process your online order or register you for our loyalty schemes and other online services. We may need to verify your age or date of birth to comply with the law, for example to ensure the products we sell you are age appropriate or to ensure we are not collecting children’s data without parental consent. We may also capture photos and video images, for example when you visit our Belong arenas and we operate CCTV in all of our retail stores for the purpose of crime prevention and detection. You may be asked to provide proof of identity (passport or driving licence) before we can enter into a contract with you for certain services, for example ou,r care plans, customer finance and for the trade-ins.
When you shop with us online or pre-order in store, we will collect your billing address, delivery address, email address and telephone numbers so that we can take payment from you, fulfil your order and keep you updated with your order status.
We use third party hosted systems to collect your tokenised payment card data when you shop with us in store and online. We also offer certain services on direct debit and provide customer finance for certain purchases, in both instances via our third-party service providers.
We record details about payments to and from you and other details of products and services you have purchased from us.
When you browse our website we collect internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, device ID, operating system and platform and other technology on the devices that you use to access our websites or apps.
When you register an account with us or sign-up to our loyalty schemes, we collect your username and password. We build up a profile of the purchases or orders you have made, your use of our services, your interests, preferences, feedback and survey responses and in the case of our Reward and Elite customers, your loyalty number.
Information about your use of our website, products and services.
Marketing and Communications Data
Includes your acceptance or otherwise in receiving marketing communications from us and your communication preferences.
We also collect, use and share anonymised and aggregated data for statistical analysis purposes. For example, we may anonymise and aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
We do not require you to disclose any special categories of data (data concerning race or ethnicity, religious or philosophical beliefs, sexual orientation, trade union membership, health information or genetic data) or data about criminal records and convictions. It is prohibited to post special categories of data or data about criminal records and convictions on our online forums but if you do so, we will be processing this data because you have chosen to make it public.
IF YOU DO NOT PROVIDE PERSONAL DATA
Where we need to collect personal data by law (for example we need to verify your identity under second hand dealer licensing laws if you offer to trade-in a personal device), or under the terms of a contract we have- or are trying to enter into with you (for example when you place an order for our goods and services) and you fail to provide that data when requested, we may not be able to perform the contract with you. In this case, we may have to cancel a product or service you have ordered from us but we will notify you if this is the case at the time.
4.OUR PURPOSES AND LAWFUL BASES FOR PROCESSING YOUR DATA
LAWFUL BASES AND PURPOSES
We will only use your personal data when the law allows us to. Most commonly, we rely on the following lawful bases when processing your data. You can expand each section below to find out more about the purposes for which we rely on each of these bases.
Where it is necessary for the performance of a contract we are about to enter into- or have entered into with you.
- to process your order and the associated payment and to deliver your products or services (including services in our Belong arenas);
- to register you for one of our loyalty schemes;
- when you make us an offer to trade-in a pre-owned device or game;
- if you enter a competition;
- to administer your account, monitor your sales performance and make payments to you if you are a seller on GAMEMarketplace;
- to notify you of changes to our terms and conditions.
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.
- to undertake analysis and develop insight into your interests and preferences for marketing purposes;
- to send you direct marketing communications where the law permits this;
- to share your data with carefully selected third parties who may deliver marketing or targeted advertising to you from time to time related to our products and services;
- to ensure your payment card is not being used without your consent and to prevent and detect fraud;
- for the purpose of making or defending an insurance or legal claim that may involve you;
- to seek your feedback or undertake customer research to improve our products and services;
- in order to run our business, for the provision of IT services and network security;
- to deliver relevant website content and advertisements to you and to measure and understand the effectiveness of such advertisements so we may develop our products and services and inform our marketing strategy;
- to monitor, understand and continuously improve your online experience when you browse and transact with our website;
- to manage our relationship with you and investigate and respond to your queries or complaints;
- to assess the quality of our services including the extent to which our services comply with the law;
- to undertake data mining and analysis for the prevention and detection of fraud;
- to maintain accounting records, for the analysis of financial results, for internal and external audit purposes and for the purpose of seeking professional advice on legal or tax matters;
- for quality and training purposes;
- for the purpose of bringing or defending a legal or insurance claim.
Where we need to comply with a legal or regulatory obligation.
- to comply with second-hand dealer licensing regulations in relation to our pre-owned business activities;
- to comply with regulations requiring information security monitoring systems and controls;
- where we identify a crime and have a duty to report it to the relevant authorities;
- where we are obliged to share data with regulators such as the ICO for audit or data breach reporting purposes;
- to handle any requests you make when you exercise your legal rights as outlined in this policy.
In a limited number of scenarios and where required by law, we rely on consent as a legal basis for processing your personal data
- for electronic, direct marketing communications (i.e. those we send you by email or SMS);
- to take photo and/or video images of you in our Belong arena for advertising and marketing purposes.
AUTOMATED DECISION-MAKING INCLUDING PROFILING
When you place an order with us online we use automated decision-making and profiling to determine if we should enter into a contract with you. The decision-making is based on a set of rules designed to prevent and detect fraud in combination with Identify, Contact, Transaction, Technical, Profile and Usage Data we may have previously collected about you. The consequence of any of these rules being triggered might be that your order is marked for the attention of our referrals team and eventually declined. We will inform you if there has been a problem with your order and you will have the opportunity to discuss the reasons for this with our Customer Services team who can double check the decision for you.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We hope that you will be happy for us to send you news and promotional offers but you are free to change your mind at any time. We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. You may receive marketing communications from us if you have given us your contact details when ordering a product or service from us and have not opted out. In other cases, and when required by the law, we will ask you for your consent to receive marketing from us.
We may share your data from time to time with carefully selected third parties where it is in our legitimate interest and theirs to do so. This includes third parties who may serve you with targeted media advertising, related to our products and services. However, these third parties will have no right to send your direct marketing communications by email or text message without your consent.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting Customer Services at any time.
5.WHO WE SHARE YOUR DATA WITH
There are a number of third parties with whom we share your data in order to provide our products and services; manage our relationship with you; monitor and improve the quality of our services and your experience; keep you engaged with our business through tailored marketing communications and advertising and to comply with our legal and contractual obligations.
Where we regularly share your data with processors or controllers, we have data sharing agreements in place which require them 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 who process data on our behalf to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
The processors we use are largely based in the EU or in the US where there are similar protections for personal data. For further details about the safeguards we put in place when transferring your data outside of the EU, please see International Transfers.
In the table below we have set out the types of processors and controllers who receive your data:
Type of Service Provided
Payment services providers when you pay in store or online for a product or service; direct debit service providers if you choose to pay monthly for services you take from us or our partners; providers of our console and mobile phone care plans, repairs service and customer finance.
Customer relationship management (CRM) software provider to record your communications preferences and send you our news and tailored promotions; customer service and engagement software providers to manage and record our conversations with you when you email us, call us, use “Chat” or contact us via social media; provider of the GAMEMarketplace platform; customer survey, research and competition administration service providers; providers of IT systems integration and support; systems performance monitoring and web analytics providers; data mining and analysis software providers; fraud management software providers.
Transport and Logistics
Couriers and other logistics suppliers we use to deliver your order to you.
Media and Advertising
Advertising networks providers when you browse our website; media, broadcast and advertising organisations we may share your data with from time to time.
Outsourced customer services provider.
OTHER DISCLOSURES OF YOUR PERSONAL DATA
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 the DPO.
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.
From time to time we may use data processors who process your personal data outside of the European Economic Area (EEA). In these cases, we will always ensure a similar degree of protection is afforded to your data by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact the DPO if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. PROTECTING YOUR 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. 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. If you are concerned about a potential breach of your data, please contact the DPO.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9.YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
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 your personal data
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 (or those of a third party) 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data
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.
Object to automated decision-making or profiling
You can ask us not to subject you to automated decision-making or profiling with legal or similar significant effects.
If you wish to exercise any of the rights above, please contact the Data Protection Officer (see About Us for contact details).
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 may 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 will to respond to all legitimate requests within one month unless your request is particularly complex or you have made a number of requests. In this case, it may take us longer to respond but we will notify you and keep you updated.