1. Important information and who we are
This website is not intended for children, and we do not knowingly collect data relating to children.
Full name of legal entity: Marvelous Europe Ltd.
Email address: firstname.lastname@example.org
Postal address: 2 Bakers Yard, Farringdon, London, EC1R 3DD.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (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.
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.
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 (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes names, title, date of birth and other identifiers (such as usernames for Discord, YouTube, Twitch, Instagram, TikTok (or of any other social media platforms) that you may provide).
- Contact Data includes your country of residence, address and email address or telephone number, if given.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
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.
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 and Contact Data by filling in forms or by corresponding with us by post, email or otherwise. This includes personal data you provide when you:
- subscribe to our newsletter or request other marketing to be sent to you;
- sign up to our content creator programme;
- pitch your video game to us via the “submit game” tab on our website;
- provide us with any services;
- enter a competition or promotion; or
- give us feedback or otherwise contact us for any reason.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Third parties or publicly available sources. We may receive Technical Data from analytics providers such as Google based outside the UK (further information can be found here).
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where you give consent for us to use your personal data.
- 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.
Please refer to the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending any marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us or following the unsubscribe prompts on any marketing communications we may send to you via email.
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 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.
Type of data
Lawful basis for processing including basis of legitimate interest
To manage our relationship with you which will include (but will not be limited to):
(b) Asking you to leave a review or take a survey
(c) Marketing and Communications
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how customers view us)
To allow us to provide you with our newsletter following your request to be added to our mailing list. This will involve the transfer of personal data to an External Third Party known as Mailchimp (more details of which can be found in the Glossary).
(c) Marketing and Communications
(a) Consent obtained from you to receiving our newsletter.
(b) Necessary for our legitimate interests (to promote our business and products, and to develop and grow our business)
To enable you to partake in a prize draw, competition or complete a survey, or sign up to our content creator programme and to interact with you in that regard.
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to promote our business and products, and to study how customers view us and to develop and grow our business)
To enable you to get in touch with us in relation to general enquiries and for us to interact with you in that regard. This will involve the transfer of personal data to an External Third Party known as Zendesk (more details of which can be found in the Glossary).
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to develop and grow our business).
To enable you to submit (and for us to consider) your video game for the purpose of review by us and for us to interact with you in that regard.
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to promote, develop and grow our business).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(d) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our website and to develop and grow our business and to inform our marketing strategy)
To use data analytics to improve our website, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products, to keep our website updated and relevant and to develop our business and to inform our marketing strategy)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Marketing and Communications Data to form a view on what may be of interest to you. However, you will receive marketing communications from us if you have signed up to our newsletter and have not opted out of receiving that newsletter.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties 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 us at any time.
We use statistics cookies via Google Analytics. These cookies allow us to recognise and count the number of visitors to our website, to see how visitors move around our website when they are using it, and to see how much time is spent on our website. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. In addition to collection of the above, Google Analytics also collects Technical Data, including your IP address, and shares this data with Google in the United States of America. For more information about how Google uses Technical Data obtained via Google Analytics, please click here.
We use the data (including Technical Data) collected by Google Analytics for analysis in Google Data Studio and to create personalised adverts via Google Ads.
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.
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 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
We share your personal data with third parties. Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it 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; or
- Where we use certain service providers outside of the UK that are not located in an area that has been deemed to provide an adequate level of protection for personal data, we will use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information 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 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.
8. Data retention
How long will you use my personal data for?
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.
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, regulatory, tax, accounting or other requirements.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- 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.
Please see the Glossary for further information. You may also wish to visit the Information Commissioner’s Office website to find out more about these rights.
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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. 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.
Comply 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
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- The Rocket Science Group LLC (trading as “Mailchimp”) based in the United States of America who provide a service for email address management and message sending. We will share your personal data, including Identity and Contact Data, with Mailchimp when you sign up to our newsletter. Mailchimp shall process your personal data in accordance with accepted standard contractual clauses which shall give your personal data the same level of protection it has in the UK. For more information on Mailchimp’s terms, please click here.
- Google LLC based in the United States of America who provide a storage service for personal data via the Google Cloud Platform. We will share your personal data, including Identity and Contact Data, with Google when you sign up to our content creator programme. Google shall act as a storage provider for your personal data and will process that personal data in accordance with accepted standard contractual clauses, which shall give your personal data the same level of protection it has in the UK. For more information on Google’s privacy terms, please click here.
- Zendesk Inc. based in the United States of America who provide a service for handling of website enquiries. We will share your personal data, including Identity and Contact Data, with Zendesk when you complete our general enquiries contact form contained within the “contact” tab on our website. Zendesk shall process your personal data in accordance with accepted standard contractual clauses, which shall give your personal data the same level of protection it has in the UK. For more information on Zendesk’s privacy terms, please click here.
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 (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:
- 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 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.