Crayta Legals - Privacy Policies

Crayta Privacy and Cookie Policy

ISSUED BY UNIT 2 GAMES LIMITED (“UNIT 2”, or “we” or “us”).

Welcome to Crayta's privacy policy. Crayta is owned and licensed by Unit 2 Games Limited.

Unit 2 Games Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use Crayta and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Unit 2 Games Limited collects and processes your personal data through your use of Crayta and Crayta.com, including any data you may provide through Crayta or we may receive via Google Stadia or the Epic Games Store when you register an account, purchase Crayta Credits or otherwise use Crayta.

Crayta is not intended for anyone under the age of 13 and we do not knowingly collect data relating to anyone under this age.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Unit 2 Games Limited is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Unit 2 Games Limited

Email address: dataprotectionofficer@unit2games.com

Postal address: 2 Jephson Court, Tancred Close, Leamington Spa, Warwickshire, England, CV31 3RZ, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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.

Changes to the privacy policy

We keep our privacy policy under regular review. This version was last updated on 27th April 2021.

Third-party links

Crayta may include links to third-party websites, plug-ins and applications, including but not limited to Google Stadia and the Epic Games Store. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave Crayta, we encourage you to read the privacy policy of every website you visit.

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 title, first name and last name.

“Contact Data” includes email address, mobile number and telephone number.

“Transaction Data” includes details about Crayta Credit payments to and from you and other details of items you have purchased from the Crayta Store.

“Account Data” includes your unique Crayta account ID and your Google Stadia/Epic Games Store username.

“Financial Data” includes your PayPal email address (please note that this will only be processed as part of providing you with a prize when you partake in and win a prize draw or competition).

“Usage Data” includes information about how you use Crayta.

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Crayta feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the Crayta Terms of Service, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to Crayta). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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, Contact Data and Transaction Data by using Crayta, accessing our support service, giving us feedback or when you otherwise correspond with us by phone, email or otherwise.

In respect of Account Data, we will automatically collect your Google Stadia/Epic Games Store username as part of our account authentication process, where we will also generate and provide to you your Crayta account ID. As you use Crayta, we will automatically collect Usage Data about your browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Usage Data about you if you visit websites employing our cookies. Please see our cookie policy below for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties, including Google Stadia and the Epic Games Store (both based in the USA) and analytics providers such as Google Analytics (based in the USA).

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 we need to perform our obligations under our Terms of Service, which form the contract between you and us when you create a Crayta account via Google Stadia or the Epic Games Store.

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.

Generally, we do not rely on consent as a legal basis for processing your personal data.

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 lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful basis 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.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new user

(a) Account

(a) Performance of a contract with you

To enable you to use Crayta in accordance with our Terms of Service, for example by using your Account Data in high score tables within games

(c) Transaction

(d) Account

(e) Usage

(a) Performance of a contract with you

To manage our relationship with you, including providing you with customer support in respect of Crayta

(a) Identity

(b) Contact

(c) Account

(d) Usage

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how our users use Crayta)

To enable you to use Crayta Credits to purchase items in the Crayta Store

(a) Transaction

(b) Account

(a) Performance of a contract with you

To administer and protect our business and the Crayta platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Account

(d) Usage

(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 use data analytics to understand how you use and interact with Crayta, to improve Crayta, user relationships and your experiences of Crayta

(a) Account

(b) Usage

Necessary for our legitimate interests (to define types of users of Crayta, to keep the Crayta platform updated and relevant, to develop our business and to inform our marketing strategy)

To enable you to partake in a prize draw or competition

(a) Identity

(b) Contact

(c) Account

(d) Usage

(e) Financial

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how users use Crayta, to develop Crayta and grow our business)

To provide you with special items to use within the Crayta platform where you have requested this.

(a) Identity

(b) Contact

(c) Profile

(d) Account

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (for running our business, provision of administration and IT services, to develop Crayta and grow our business)

In limited circumstances (as set out below), to deliver relevant marketing communications to you and measure or understand the effectiveness of the advertising we serve to you.

(a) Identity

(b) Contact

(c) Profile

(d) Account

(a) Necessary for our legitimate interests (to study how users use Crayta, to develop them, to grow our business and to inform our marketing strategy)

Marketing

We do not, as a general rule, use any of your personal data collected via our site to send you marketing communications. However, where you have a Crayta account and you have provided us with your Contact Data in order to receive special items to use within the Crayta platform, you will receive marketing communications from us via our third party marketing email delivery service provider Twilio Inc. operating as SendGrid (based in the USA) unless you opt out of receiving such marketing.

Opting-Out

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 us at any time.

Cookies

Our website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you use our site and also allows us to improve it.

A cookie is a small file of letters and numbers that we, subject to your approval, store on your browser or the hard drive of your computer or other device with which you are accessing Crayta. Cookies contain information that is transferred to your computer's or other device’s hard drive.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

We use analytical or performance cookies, such as those deployed by Google Analytics. These allow us to recognise and count how many people are using our site and to see how everyone uses our site. This helps us to improve the way our site works.

Please note that Google may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies. You can deactivate the use of third party advertising cookies in your internet browser settings.

All cookies will expire after 365 days.

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.

Other users of Crayta who have created the games and experiences you use on the Crayta platform.

Zendesk Inc. and BugSplat LLC (both based in the USA) which both provide customer support services in respect of Crayta.

Twilio Inc. operating as SendGrid (based in the USA) which provides marketing email delivery services on our behalf.

Google Stadia and Google Inc. (both based in the USA), Google Ireland Limited and Google Commerce Limited (both based in Ireland), all of which may provide the platform on which Crayta is provided to you.

Google Analytics based in the USA who provide cookies and analytics services to Crayta.

Service providers such as Microsoft Office, Forum and Keywords International (based both inside and outside the EEA) who provide IT and system administration services in respect of Crayta and our business.

Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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 are based in the United Kingdom. If:

you are based in the EEA; and

the United Kingdom ceases to be a member of the European Union; and

the United Kingdom is not subject to a finding by the European Commission under EU data protection laws that it provides adequate protection for the privacy rights of individuals based in the EU,

then unless and until such finding is made by the European Commission, our processing of your personal data will involve a transfer of data outside the EEA.

Some of our external third parties are also based outside the EEA so their processing of your personal data will also involve a transfer of data outside the EEA.

With respect to the degrees of protection we afford your personal data when we process it, please see section 7 “Data Security” below.

Whenever we transfer your personal data out of the EEA to our external third parties, 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 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.

Please contact us via dataprotectionofficer@unit2games.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We process your personal data in accordance with the UK’s Data Protection Act 2018. 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.

We retain your personal data until we or you decide to close or delete your Crayta account, at which time we will delete all personal data we hold about you within 30 days.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will 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:

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. Please 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.

If you wish to exercise any of the rights set out above, please contact us at dataprotectionofficer@unit2games.com.

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.

© 2021 Unit 2 Games Limited. All trade marks are the property of the relevant owners. All rights reserved.

CRAYTA WEBSITE PRIVACY AND COOKIE POLICY

ISSUED BY UNIT 2 GAMES LIMITED (“UNIT 2”, or “we” or “us”).

Last updated 12 May 2020

INTRODUCTION

Welcome to Crayta's website privacy policy. Our website crayta.com (our “site”) is owned by Unit 2 Games Limited.

Unit 2 Games Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our site and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Unit 2 Games Limited collects and processes your personal data through your use of our site.

CONTROLLER

Unit 2 Games Limited is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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.

CHANGES TO THIS PRIVACY POLICY

We keep our privacy policy under regular review. This version was last updated on 9th March 2021.

THIRD PARTY LINKS

Our site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave Crayta, we encourage you to read the privacy policy of every website you visit.

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 relating to how you use our site (“Usage Data”).

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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:

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:

Generally, we do not rely on consent as a legal basis for processing your personal data.

Purposes for which we will use your personal data

We plan to use your Usage Data in order to use data analytics to:

We process your Usage Data in these ways on the lawful basis that this is necessary for our legitimate interests (to define the types of visitors to our site, understand how visitors interact with our site, to keep our site updated and relevant, to develop our business and to inform our marketing strategy).

MARKETING

We do not use any of your personal data collected via our site to send you marketing communications.

Cookies

Our website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you use our site and also allows us to improve it.

A cookie is a small file of letters and numbers that we, subject to your approval, store on your browser or the hard drive of your computer or other device with which you are accessing Crayta. Cookies contain information that is transferred to your computer's or other device’s hard drive.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our site may become inaccessible or not function properly.

We use analytical or performance cookies, such as those deployed by Google Analytics. These allow us to recognise and count how many people are using our site and to see how everyone uses our site. This helps us to improve the way our site works.

Please note that Google may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies. You can deactivate the use of third party advertising cookies in your internet browser settings.

All cookies will expire after 365 days.

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 above.

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 do not transfer your personal data outside the European Economic Area.

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.

We retain your personal data for a period of 26 months from when such personal data is first collected via our site.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will 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 click on the links below 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.