Privacy Policy - Memory Lane Games

PURPOSE OF THIS PRIVACY POLICY

We have the utmost respect for your privacy and understand that your personal information is important to you.

This privacy policy aims to give you information on how Memory Lane Games Limited and its subsidiaries and affiliates (“MLG”, “we”, “us” or “our”) collects and processes your personal data through your use of this website and our App. The basis on which any personal data we collect from you, or that you provide to us will be processed by us on a lawful basis is set forth in this privacy policy, our terms of use (link), and the EU General Data Protection Regulation 2016/679 (“GDPR”) as implemented in the Isle of Man (link).

Please read the following carefully to understand our views and practices regarding your personal data and how we will collect, use and disclose such information.

It is important that you read this policy 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.

1. Who to contact about your Personal Identifiable Information (PII)

MLG is the controller and responsible for your personal data . Our contact details are available in the contact section of our website. If you have any questions about our use of your PII you can email [email protected] .

2. Links

This site may contain hyperlinks to other sites and applications as a convenience to our users. If you contact these subsidiaries, the entity you contact will be the controller of your personal data. MLG is not responsible for the privacy practices or the content of other sites and applications and you visit them at your own risk. We recommend you read the privacy policies of such sites and applications. This privacy policy applies solely to PII collected by us through this site.

3. Enforcement

MLG regularly reviews its compliance with this privacy policy. Please feel free to direct any questions or concerns regarding this privacy policy or our treatment of PII by contacting us. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of PII that cannot be resolved between MLG and an individual.

If you are based within the European Economic Area and think that we haven’t complied with data protection laws, you have a right to lodge a complaint with the Isle of Man Information Commissioner or with your local supervisory authority.

We may update this Privacy Policy from time to time in its sole discretion and without notification. You are bound by such updates and we encourage you to periodically review this Privacy Policy for the latest information about our privacy practices. Your use of the Apps following these changes means that you accept the revised privacy policy.

4. Data integrity, accessing and updating personal information

MLG processes PII only for the purposes for which it was collected and in accordance with this privacy policy or any applicable service agreements. We require our data collection, storage and processing practices to ensure that we only collect, store and process the PII needed to provide or improve our services. We take reasonable steps to ensure that the PII we process is accurate, complete, and current, but we depend on our users to update or collect their PII whenever necessary.

It is important to us 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.

Nothing in this privacy policy is interpreted as an obligation to store information, and we may, at our own discretion, delete or avoid from recording and storing any or all information.

Upon receipt or your written request and enough information to permit us to identify your PII, in accordance with the instructions further detailed here (link to GDPR page), we will disclose to you the PII we hold about you. Upon your request we will also correct, amend or delete any PII that is inaccurate about you, and notify any third party who received this PII from us of the necessary changes.
We do not charge for complying with a correction request, however, for all other requests, we may charge a small fee to cover its cost. Requests to delete PII are subject to any applicable legal and ethical reporting or document retention obligations imposed on MLG.
We ask individual users to identify themselves and the PII request to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical, or for which access is not otherwise required.

4. How we use your PII

We will only use your Personal data when permitted by the law, and in particular in order to conduct our correspondence with you or to carry out the effective management of our business and our website. We may also use your personal data where it is necessary for us to do so in order to comply with our legal or regulatory obligations.

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 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.

5. PII we collect

When you use this site, we may automatically collect the following types of PII

We may automatically receive and record information from your device and browser, including your cookie information, your country, regional and language settings, device model, operating system, IDFA, mobile carrier, and software and hardware attributes.
Our systems may automatically record and store technical information (software, hardware and regional settings) regarding the method and nature of your use of the website, including, without limitation, the date on which you entered and viewed the site, which parts of the site our users view and/or use and the dates and times on which they viewed or used such parts of the site, impressions, the number of views they get and any actions they make in the site.
Third party providers that work with us use your IP address to help us with server problem diagnosis and administer the site. An IP address is a numeric code that identifies your device on a network, or in this case, the internet. Your IP address is also used to gather broad demographic information. We may also perform IP lookups through third party providers to determine which domain you are coming from (eg. aol.com, yourcompany.com) to more accurately gauge our users’ demographics. We may also share PII with third parties for their direct marketing purposes.
As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies and other similar technologies. Most major websites use cookies; a cookie is a small text file that our site may place on your computer to remember your preferences. Cookies by themselves cannot be used to discover the identity of the user. Cookies do not damage your device. Most browsers allow you to block cookies by selecting the appropriate settings on your browser. However, please note that if you disable the use of cookies you may not be able to use the full functionality of this website.
We may also use web beacons to collect information. Web beacons or “gifs” are electronic images that may be used on our site or in our emails. We may use web beacons to deliver cookies, count users and to tell if an email has been opened and acted upon.
When you send an email or other communication to MLG, we may retain those communications in order to process your inquiries, respond to your requests and improve our site. We may also send newsletters and promotional communications if you joined our mailing list, you may opt-out of this service at any time by clicking UNSUBSCRIBE at the bottom of each email or by submitting a request to [email protected] .
We sometimes supplement the information that you provide with information that is received from third parties. For illustration by way of an example, if you interact with Facebook and/or Whatsapp and/or any other social media network or any other social media plug-in on the site, we may receive information from your respective app platform account, including your name, profile, picture, email address, and any information defined as public pursuant to the policies of such app platforms.
- MLG is not responsible for the privacy practices of such third parties and/or app platforms. We recommend that you carefully read the terms of use and privacy policies of such third parties and/or app platforms before using their services and connecting to the apps. This privacy policy solely applies to PII collected by us through this site or otherwise in accordance with the terms of use.
We do not knowingly 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 offenses.

6. Dependents

We care about the safety of children. Therefore this site is not directed toward children under 18. If you are under the age of 18 or the age of legal majority where you reside if that jurisdiction has an older age of majority, you must obtain parental consent (or consent from your legal guardian) prior to using our website.

We do not knowingly contact or engage with children under the age of 18 (or the age of legal majority where you reside if that jurisdiction has an older age of majority) without said parental consent (or consent from your legal guardian. If you have reason to believe that a child under the said age has provided us with their PII, please contact us at the address given above and we will endeavor to delete that PII from our databases

If you are a parent or guardian who knows or has discovered that your child or dependent under the age of 18 or someone else has submitted your child’s PII or other information without your consent, permission or authorisation; upon request, we will promptly remove your child’s PII or other information from out databases, cease the use of such information and direct with any other party with access to such information to do the same.

Additionally, we do not purposely contact or engage with vulnerable adults without consent by an appropriate third party. If you have reason to believe that a ‘vulnerable adult’ (under the safeguarding act 2018) has provided us with any PII, please contact us at the email address given above and we will endeavor to delete that PII from our databases. Upon request, we will remove the PII of the vulnerable adult from our databases and cease to use such information.

7. Purposes of processing your PII

We process your PII for specific and limited purposes. We ask only for PII that is adequate, relevant and not excessive for those purposes and internally to help us improve our services and to help resolve any problem with our services. In particular, and without limitation, we may use PII held about you in the following ways and for the following purposes:

To enable us to carry out the main purpose of the website and our App
Your mobile device configuration (for further information please see “user information”);
Submitted content such as personal photographs (as defined in the terms of use) uploaded in the app; and
App usage patterns (for further information please see “traffic data collected through the App”) All the above mentioned PII are saved to the cloud for backup (for further information please see section 4 of this policy)
In order to provide you with information, support, or products or services that you request from us which may be of interest to you, where you have consented to be contacted for such purposes, including information about new products, features or special offers we ask you for your: (1) first and last name; and (2) email address. Please note that you do not have to provide the above mentioned PII but in such case your usage may be restricted.
To enable internal record keeping.

8. Information security

We follow generally accepted industry standards to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of PII. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security.

We limit access to PII about you to employees, contractors and service providers who we believe reasonably need to come into contacts with that PII. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
We have physical, electronic, and procedural security measures and safeguards in place to reasonably protect PII. Our servers and our databases are protected by industry standard security technology, such as industry standard firewalls and password protection.
Although we cannot guarantee any loss, misuse, unauthorized disclosure, alteration or destruction of data we try to prevent such unfortunate occurrences, including by implementing corporate procedures in this regard. If you have reason to believe that your use of our services is no longer secure, please immediately notify us of the problem by contacting us.

In some cases, your data may be transferred internationally, or outside the European Economic Area (EEA). Our external third-party service providers may be based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. When we transfer your personal data out of the EEA, we will take reasonable steps to ensure that your personal information is adequately protected and transferred in line with data protection laws.

9. Data security and encryption

Data security is of utmost importance to us. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

Our storage and database solutions have custom security rules to prevent external access from any party except our development teams. However, we have put in place procedures to deal with any suspected personal data breach and will notify you or any applicable parties of a breach when we are legally required to do so.

9. Data retention

We strive to maintain the reliability, accuracy and completeness of PII that we collect and to protect the privacy and security of our users.

We keep your PII only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements. We may retain your personal data for a longer period of time 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 data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means.

10. Information sharing

MLG is a worldwide service. By providing any PII to us pursuant to this privacy policy all users fully understand and unambiguously consent to this privacy policy and to the collection and processing of such PII. Some of the uses and disclosures mentioned in this privacy policy may involve the transfer of your PII to various countries around the world that may have different levels of privacy protection than your country.

We take additional measures when information is transferred from the EEA. This includes having standard clauses approved by the European Commission in our contracts with parties that receive information outside the EEA. We also rely on European Commission adequacy decisions about certain countries, as applicable, for data transfers to countries outside the EEA. By submitting your PII, you consent, acknowledge, and agree that we may collect, use, transfer, and disclose your PII as described in this privacy policy.

Nevertheless, the company only shares PII with other companies or individuals in the following limited circumstances:

We have your consent
We provide PII to trusted service providers for the purpose of processing PII on our behalf. We require that these parties agree to process such PII based on our instructions and in compliance with this Privacy policy, any applicable laws and any other appropriate confidentiality and security measures,
We have a good faith belief that access, use, preservation or disclosure of such PII is reasonably necessary to (a) satisfy any applicable laws, regulation, legal process or enforceable governmental request; (b) enforce applicable agreements and/or their terms, including investigation of potential violations thereof; (c) detect, prevent, or otherwise address fraud, security or technical issues; or (d) protect against imminent harm to the rights, property or safety of MLG, its users or the public as required or permitted by law.
If we become involved in a merger, acquisition, or any form of sale of some or all of our assets or in the event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, you will be notified on a best efforts basis via email and/or a prominent notice on our website, of any change in ownership, uses of your PII, and choices you may have regarding your PII. In any of the circumstances above, your PII will continue to be used in accordance with this privacy Policy.
We obtain assurances from our agents that they will safeguard PII through measures consistent with this privacy policy and further privacy measures and protocols. Where we have knowledge that an agent is using or disclosing PII in a manner contrary to this privacy policy, we take commercially reasonable steps to prevent or stop unauthorized use or disclosure.

11. Your legal rights

You have a number of rights of your personal information which you can exercise free of charge by contacting us using the details above.

As mentioned above we will correct, amend or delete any PII that is inaccurate. However, for other requests, we may charge a small fee to cover its cost. Alternatively, we can refuse to comply with your request if permitted.

Right to information – You have a right to the information set out in this privacy notice. The most recent version of our privacy notice will always be accessible on our website. We have controls in place to protect your personal information and minimize the risk of security breaches. However, should any breaches result in a risk for you, we will inform you.
Right to restrict – you can restrict or object to any unfair or unlawful collection or use of your personal information. You can object to any automated decision making that has legal or similar significant implications for you and ask for the decision to be made by a person. In some cases, we may demonstrate that we have compelling, legitimate grounds to process your information which override your rights and freedoms.
Right to correct and update – As mentioned above, you can ask us to correct or update any personal information we have about you.
Right to delete and be forgotten – you can have our personal information deleted if it is incorrect, no longer needed, or has been processed unfairly or unlawfully. We will keep a record of your request so we know why your personal information was deleted. We may not always comply with your request of erasure for specific legal reasons, which will be notified to you if requested.
Right to Access – As mentioned above, you can ask for a copy of all personal information we hold about you. This right does not allow you to access personal information about anyone else. To access your personal information please use the contact details provided above. To help us respond efficiently please let us know if you are only looking for specific pieces of information.