Privacy Policy

General

www.lightseekers.com, www.playfusion.com, www.lightseekers.cards, www.warhammerchampions.com and related websites (the “Sites”) are owned and/or operated by PlayFusion Limited, a company registered in England and Wales (registered number 9413757). Our registered office is at St John’s Innovation Centre, Cowley Road, Cambridge, CB4 0WS. Through the Sites and through certain other third-party channels, we operate and offer certain games and products, such as the “Lightseekers Awakening” multiplayer online role player game, the “Lightseekers Digital and Physical Collectible Card Game”, and the “Warhammer Champions Digital and Physical Collectible Card Game(s)” and Community Forum (the “Services”), together with our interactive Smart Figures and Card Game (the “Materials”).

This policy (together with our Terms and Conditions and any other documents referred to in it or herein) sets out the basis on which any personal data we collect from you, or that you provide to us, will be dealt with by us. We may also make specific statements available from time to time relating to the collection and use of your personal information. Where we do so, this policy and those statements are intended to supplement or complement each other, and are not intended to conflict or override each other.

For the purposes of the General Data Protection Regulation (EU) 2016/679 (and the Data Protection Act 1998 where relevant), and any related legislation, the data controller is PlayFusion Limited whose registered office is at St John’s Innovation Centre, Cowley Road, Cambridge, CB4 0WS, United Kingdom. We have appointed an internal data protection officer who is responsible for overseeing questions and concerns relating to this privacy policy and our use of data. If you have any questions specific to privacy, data protection and related laws, you may contact our designated data protection officer at GDPR@playfusion.com.

We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this Site and/or Services, then you should be assured that it will only be used in accordance with this privacy statement and any applicable laws.

PlayFusion Limited may change this policy from time to time by updating this page. Any changes to this policy are effective when published here. We will endeavor to give users notice of any material changes in a suitable form and format.

In this privacy policy, we note a number of potential uses of your personal information, which may occur on certain of the Sites and/or Services.  Any use of your personal information, however, would require you first providing such personal information to us, and granting us permission to use such information in the ways specified. You should also note that this is a privacy policy intended to cover a variety of products, and a particular type of data being noted in here does not mean it is definitely collected or otherwise processed by or on our behalf in connection with, any, some or all of the Sites and/or Services. We will always endeavor to inform you as to the collection and use of your personal information, will not predicate the operation of our Sites and/or Services on more information than is reasonably necessary.

Generally, we do not seek to rely on your consent as the legal basis for our processing of your personal information, although we may seek consent where appropriate and lawfully required.

For example, in the Lightseekers RPG application published on Google, Apple and Amazon, we do not collect or use any personally identifiable information from users, and do not intend to do so. If we want to change our position on this, we will prominently notify users of the application in certain places. If you have any questions about our use of personal information, please contact us at contact@playfusion.com or GDPR@playfusion.com.

If you are subject to English Law, you have the right to make a complaint to the Information Commissioner’s Officer (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would always prefer you contacted us first to give us a chance to deal with any concerns you may have.

Types Of Information

We may collect and process the following data about you and your visit to Sites and/or use of Services under our control (for an explanation of why we may collect this information, see the following section):

Information you voluntarily give us – This is information you provide to us deliberately when accessing the Sites and/or Services. You are free to choose not to provide this type of information to us, but may need to provide it if you wish to use the Sites and/or Services. This may include information you provide when you register for the Sites and/or Services, such as your email address, your name, address, phone number, financial and credit card information, personal details and photographs.

Information about your visit – This is information we may collect in the background when you visit the Sites and/or use Services. It may include your IP address, a unique user ID, technical information about your visit, and information about how you accessed and used the Sites and/or Services.

Information from third parties – This is information we receive about you from third parties that you may access or use through the Sites and/or Services. This may include parties such as payment service providers, advertising networks, platform providers and publishers and data and analytics service providers.

This privacy policy highlights a number of potential ways in which personal information may be collected from you. We operate a number of Sites and/or Services, and the operation of these will change from time to time. We try to provide a broad statement of the potential types of information that we might collect, this does not mean that we do in fact collect or use such information. We will always design our offering with your control in mind, although note that if you don’t provide us with certain personal information, then you may not be able to use certain aspects of our offering.

Please note that personal data or personal information is information about an individual from which that person can be identified. It would not include data where a real living individual cannot be identified or where the identity has been removed or obscured. We may collect and use aggregated data, such as statistical or anonymized demographic data, but this is not personal data and cannot be used to identify a single individual.

Cookies

Websites uses cookies for a number of reasons in order to enhance your experience on the Sites and your experience whilst on them. For more detail on what we use, please see our Cookie Policy.

Use Of Information

We use information about you and your visit to Sites and/or use of the Services in a number of ways:

Information you voluntarily give to us – We use this information to provide the Services to you that you have requested from us in connection with your provision of information, such as access to our forums, completion of orders, and providing information about and access to our products. We may also provide you with information regarding goods and services we offer that are the same as or similar to those you have expressed an interest in. If we contact you, we will only typically contact you using email or a similar electronic communication method, and will generally offer you the opportunity to not receive further communications, both at the time you had the opportunity to provide the information, and subsequently thereafter. We may pass such information onto third parties in order to provide the Services you have explicitly requested, and only as reasonably necessary to provide the goods or services you have asked for. We may also use such information to customise and present the Sites and/or Services in the most effective manner possible.

Information about your visit – We use this information to administer the Sites and/or Services, including optimising the Sites’ experience for you and other users and to improve Sites and/or Services. We also use this information to present our content in the most effective manner possible, and to enable interactive features to operate effectively.

Information from Third Parties – We may use information provided to us by third parties in suitable conditions and circumstances. We will only use this information where we are generally satisfied that it is lawfully obtained. Typically, you will be able to control the use and/or collection of this sort of information by customizing your settings in connection with these third-party sites or services.

We may share information about you with members of our corporate group, and certain third parties such as business partners, suppliers and contractors, for ordinary business purposes, and to enable us to provide Services to you that you have requested you receive. If we buy or sell any business or assets, we may be required to disclose data relating to you to the seller or purchaser.

In certain instances, we may disclose information to advertisers. This will generally be in an anonymised form, either for general optimisation and analytics, or to customise your experience.

We may have to disclose data where required by law, by court order, in order to comply with our Terms and Conditions and/or Privacy Policy or to protect the rights or safety of you or our visitors and customers, or in order to assist law enforcement. This may involve exchanging information with other companies for the purpose of credit and fraud prevention and reduction.

We only use information we have about individuals to the extent necessary, and always take security and confidentiality relating to such information seriously. We will also endeavor, wherever possible to take account of why you have provided information and afford you as much control and say in how your information is used as possible.

Your personal information may be transferred to, stored and processed in countries outside your country of residence both in and outside of the European Economic Area, including the United States, and used for the purposes set out in and/or envisaged by this Privacy Policy. Whenever we transfer any of Your data outside of the EEA, we ensure a similar degree of protection is afforded to it as data we hold, by ensuring: we only allow the transfer of data to countries that have been deemed to have an adequate level of protection for personal data; where we use third party service providers in the transfer of such data, we incorporate suitable contractual protections (or other legal frameworks) with such third parties, or we utilize certain rules, principles and frameworks to protect such transfers as appropriate, in accordance with applicable law. We also incorporate encryption protocols to protect transferred information. If you want further information about this, please contact us at GDPR@playfusion.com.

Security And Safety

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place commercially reasonable physical, electronic and managerial procedures to safeguard and secure your information.

Despite this, transmission of data via the internet or through applications is not completely secure. Although we will use industry standard practices and equipment to protect data, we cannot guarantee the security of data, and accordingly any such transmission is at your own risk.

Certain aspects of the Sites and/or Services may involve the use of a password and/or unique user ID, which is generally chosen by you. You are responsible for keeping this password confidential, and we ask you not to share this with anyone.

You may interact with other users on the Sites or in connection with Services. We cannot be held responsible for the actions of other users on the Sites and/or Services. If you are the victim of offensive or other inappropriate behaviour or receive unwanted or inappropriate communications, please “Contact Us” or use the appropriate report abuse function where one is present.

How Long Will You Use My Personal Data For?

We will only retain your personal information 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.

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.

In some circumstances we will anonymise your personal information (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.

Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal information. These may include the following rights: (a) the right to request access to your personal information; (b) the right to correction of errors in your personal information; (c) the right to request anonymization or erasure of elements of your personal information; (d) the right to object to further use of your personal information by us; (e) the right to request more restricted use of your personal information; and/or (f) the right to withdraw consent, if you have given any, to what you have previously consented to. Your rights are dependent on what personal information you have provided to us, what information we may have relating to you, and what the circumstances in which we have this information are.

If you want further information about these rights, please contact us at GDPR@playfusion.com.

You will not have to pay a fee to access your personal information (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.

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.

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.

Advertising And Marketing

We may have relationships with external companies who will market appropriate products and Services through the Sites and/or Services. These companies may use information (not including personal information) about your use of the Sites and/or Services in order to customise your experience and collect and use data relating to you and your visit to the Sites and use of the Services. We do not have access to or control over the cookies and/or other technologies that these third parties use, and the information practices of these advertisers is not covered by this policy. You should review such other third party’s privacy practices if you wish for more information on their use of data, and utilise your web browser or security software to ensure you have a suitable level of security and protection, depending on your preferences. Likewise, you can normally log in to and/or access such services and customize how they share your information with other services. We do not control any such third-party services, so cannot provide any input in connection with them.

Some examples of third parties that may be present on the Sites and in the Services include the following: Facebook Pixel (https://www.facebook.com/customaudiences/app/tos/?ref=u2u_); Google Analytics (https://www.google.com/policies/privacy/ and https://www.google.com/analytics/terms/us.html); CrazyEgg (https://www.crazyegg.com/privacy/); Vanilla Forums (https://vanillaforums.com/en/legal/privacy-policy/ and https://vanillaforums.com/en/legal/vanilla-forums-terms-of-service/); Yoast SEO (https://cdn.yoast.com/docs/Yoast-Terms-and-Conditions.pdf); Apple iOS (https://www.apple.com/uk/legal/sla/); and Google Play (https://play.google.com/about/play-terms.html).

We may use your information to market the same or similar Services to you as are offered on the Sites, depending on what information you have provided to us. Third parties may assist us in the delivery of such communications. We design the Sites and/or Services so it is clear if this will happen and will give you the opportunity to agree to it. You will be afforded an opportunity to stop receiving any such communications at the time you provide your information to us and with every subsequent communication.

Children’s Privacy

The Sites and Services are intended for a general audience, and are not designed nor intended to collect personal information from children under the age of 13. We do not knowingly collect personal information from anyone under the age of 13.

We do not use such information, and will take reasonable measures to delete such information if we discover that it has been provided. Neither the Sites, nor Services, are intended to be child-directed, in whole or in part. The Sites and Services do not target children under the age of 13 as a primary or secondary audience. To respect the privacy of children, children under the age of 13 should not provide any personal information on the Sites.

If you are under 18, by using the Sites or Services you are making a promise that you have permission from your parent or guardian to use the Sites and/or Services.

We ask that parents or guardians supervise their children while online.

Contact Us

You may contact us at contact@playfusion.com if you have any questions or concerns, and we will endeavour to answer any questions you have in a timely fashion.

Websites under our control uses cookies. This helps us to provide you with a good experience when you browse websites under our control and also allows us to improve websites under our control. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of websites under our control. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around websites under our control when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to websites under our control. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to websites under our control, the pages you have visited and the links you have followed. We will use this information to make websites under our control and the advertising displayed on them more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of websites or services under our control.

We value your privacy.

We use cookies to ensure that we give you the best experience on our website. If you continue to use this site we will assume that you are happy with it.

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