Live as of 25/05/18
At Game Esports and Events (GEE) we are committed to protecting your privacy. We will only use the information that we collect about you in accordance with all applicable data protection and privacy legislation, regulations and guidance.
Our Websites and any of our online services are not intended for children and we would not knowingly collect data relating to children without parental consent
Postal address: Unity House, Telford Road, Basingstoke, RG21 6YJ
Telephone number: +44 (0) 1256 784164
You have the right to make a complaint at any time to the 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 NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This policy was last updated on the date shown at the top of the document. We reserve the right to make further changes to this policy from time to time. We will always notify you in advance of any changes that involve a new use of your data that may not be compatible with the purpose for which we originally collected them. See Change of Purpose for more details.
It is important that the personal data we hold about you is accurate and current so please keep us informed if your personal data changes during your relationship with us.
Our Websites, www.insomniagamingfestival.co.uk (“Insomnia Website”), www.bricklive.co.uk (“Brick Live Website”) and others we may operate from time to time may include links to third-party websites, plug-ins and applications (”Our Websites”). 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 Our Websites, we encourage you to read the privacy notice of every website you visit.
2. HOW WE COLLECT YOUR DATA
Your personal data, is any information that can be used to identify you directly or indirectly. It does not include data where the identity has been removed (anonymous data). We collect your personal data in a number of ways. You can expand each of the sections below for more details.
Most of the personal data that we process is collected via third party processors or controllers as follows:
OTHER COMPANIES IN THE GAME GROUP PROVIDING SHARED SERVICES TO GEE
- If you buy a ticket in a GAME Retail Ltd store.
- GAME Retail Ltd also undertakes insight and analysis on our behalf.
THIRD PARTY SOURCES EXTERNAL TO THE GAME GROUP
- Our Brick Live Website is hosted by Brick Live Limited who will process any data that you submit using forms on the website. This includes forms used to; contact us; sign up for volunteering opportunities or to exhibit at Brick Live; or to make a carer enquiry.
- When you fill in forms on Our Websites we may use third parties who interact with Our Websites and collect that data on our behalf, for example when you: submit an “under 18 consent form” for Bring Your Own Computer (BYOC); fill out a “Press and YouTuber” application; sign-up for our mailing list or register for a volunteering opportunity at our events.
- We use promotion networks to support our “Insomniac” programme (whereby customers can sign up to become an ambassador and promote and market tickets for our Insomnia events).
- Ticket agents and event hosting organisations for events where GEE is the licensor.
- Third party event licensors where GEE is the licensee/ contracted event organiser.
- Social media organisations
- Customer research agencies we may appoint from time to time
TECHNICAL DATA WE COLLECT ABOUT YOU WHEN YOU BROWSE OUR WEBSITES
3. THE TYPE OF DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
|Identity Data||We collect your name and title, and age, gender (if you supply this information) when you buy a ticket for one of our events via our third-party ticketing agencies. We may capture photos and video images when you attend our events for marketing purposes. You may be asked to provide proof of identity (passport or driving licence) in order to access certain areas within our events such as Bring Your Own Computer, or if you try to purchase alcohol but we do not store copies of this data.|
|Contact Data||When you buy tickets for our events we receive your address, email and telephone number so we can send you service communications about the event in question.|
|Financial Data||Your payment card data is processed by third party ticketing agencies and is not shared with GEE.|
|Transaction Data||Details about tickets you have purchased from us.|
|Technical Data||Internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, device ID, operating system and platform and other technology on the devices the data subject uses to access Our Websites.|
|Sensitive Data||We may require you to disclose any criminal convictions, in accordance with the law, if you apply to volunteer at one of our events and are likely to be working closely with children. We may also collect data about any health needs or disabilities that we should be aware of when you complete a volunteer application form.|
|Profile Data||Includes your interests, preferences, feedback and survey responses, your experience if you are applying to volunteer at our events.|
|Usage Data||Information about your use of Our Websites and attendance at our events.|
|Marketing and Communications Data||Includes your acceptance or otherwise in receiving marketing communications from us and your communication preferences.|
We also collect, use and share anonymised and aggregated data for statistical analysis purposes. For example, we may anonymise and aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
We do not require you to disclose any Sensitive Data to us other than when you apply for a volunteering opportunity at one of our events and this information is necessary to assess your capacity to work and to ensure your health, safety and well-being. We may ask you to disclose any criminal convictions or to undergo a criminal record check, in accordance with the law, if you are likely to be working closely with children.
IF YOU DO NOT PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you 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 sell you tickets for an event). In this case, we may have to cancel your order but we will notify you if this is the case at the time.
4.OUR PURPOSES AND LAWFUL BASES FOR PROCESSING YOUR DATA
LAWFUL BASES AND PURPOSES
We will only use your personal data when the law allows us to. Most commonly, we rely on the following lawful bases when processing your data. You can expand each section below to find out more about the purposes for which we rely on each of these bases.
Where it is necessary for the performance of a contract we are about to enter into- or have entered into with you.
- To administer ticket sales for events where GEE is either the licensor (e.g. Insomnia) or the licensee (e.g. BrickLive);
- To process “Press and YouTuber” online application forms;
- To enable you to take part in a competition.
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.
- We collect your marketing and communication preferences when you buy tickets via our third-party ticketing agencies. We conduct marketing activities to promote our events and drive ticket sales;
- To process parental consent forms for a child or young person under the age of 18 to attend our Bring Your Own Computer (BYOC) zone. This is so we can ensure the safety and security of young people attending our events.;
- To sign you up for our mailing list so we can keep you informed about future events from GEE;
- To process your registration for a volunteering opportunity at one of our events;
- To process your registration to join our “Insomniac” promoter network, to help us market and sell tickets to our events;
- To handle your enquiry, compliment or complaint so that we can understand your feedback and experiences and improve the quality of our service;
- To ask you to leave a survey so that we can identify ways to improve our service;
- To administer and protect our business and Our Websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
- We use data analytics to improve Our Website, services, marketing, customer relationships and experiences;
- For insight and analysis that we use to tailor our marketing messages to you;
- For data mining and analysis to understand business performance and for the prevention and detection of crime and fraud;
- For audit and compliance purposes.
Where we need to comply with a legal or regulatory obligation.
- When you attend our events, we may need to verify your identity and/or your age, for example if you are buying alcohol or wanting to enter our BYOC zone;
- The use of analytical software and other tools for information security monitoring purposes;
- For the investigation and reporting of crime to the relevant authorities;
- Where we are obliged to share data with regulators, such as the ICO, for audit and data breach reporting purposes;
- To handle any requests you make when you exercise your legal rights as outlined in this policy.
In a limited number of scenarios and where required by law, we rely on consent as a legal basis for processing your personal data:
- We may place cookies on your personal device designed to capture Technical Data about the type of device and browser you’re using, your browsing actions and patterns;
- When we send direct marketing by email or text message and the law requires your consent;
- To take photo and video images of you at our events for advertising and marketing purposes.
In relation to the Sensitive Data we may collect about you, we rely on the additional lawful basis for processing your data:
- The processing is necessary for the purposes of carrying out obligations and exercising specific rights in the field of employment;
- The processing is necessary for the assessment of the working capacity of the employee.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We hope that you will be happy for us to send you news and promotional offers but you are free to change your mind at any time. We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. You may receive marketing communications from us if you have given us your contact details when buying a ticket to our events and have not opted out. If you sign up to our mailing list, we will ask for your consent to receive marketing from us.
We may share your data from time to time with carefully selected third parties where it is in our legitimate interest and theirs to do so. However, these third parties will have no right to send your direct marketing communications by email or text message without your consent.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting email@example.com at any time.]
5.WHO DO WE SHARE YOUR DATA WITH
We use a number of third party processors to provide and monitor our services and to comply with our legal obligations.
We have data sharing agreements in place which 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 who process data on our behalf to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
The processors we use are based in the EU or in the US where there are similar protections for personal data. For further details about the safeguards we put in place when transferring your data outside of the EU, please see International Transfers.
Below we have set out the types of organisations we share your data with:
- Third party event licensors and ticketing agents;
- Suppliers involved in the set-up and take down of our events;
- GAME Retail Limited (a GAME Group company) if you buy Insomnia tickets in one of their stores or if you visit our Insomnia website which is also hosted by GAME Retail Ltd;
- Other third parties who host Our Websites;
- Online survey providers and competition administrators;
- CRM and direct marketing providers;
- Promotion network providers;
- Providers of system integration and IT support;
- Providers of services for monitoring website performance, detecting and understanding broken customer journeys, detecting malicious log-on attempts and defending against attempted denial of service attacks;
- We share your data with GAME Retail Ltd so they can undertake insight and analysis on our behalf;
- We may share personal data with the relevant authorities and organisations for the prevention and detection of crime or if required to do so by law;
- We may also share your data with regulators, accreditation bodies and external auditors.
OTHER DISCLOSURES OF YOUR PERSONAL DATA
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the DPO.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
From time to time we may use data processors who process your personal data outside of the European Economic Area (EEA). In these cases, we will always ensure a similar degree of protection is afforded to your data by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact the DPO if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. PROTECTING YOUR DATA
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. If you are concerned about a potential breach of your data, please contact the DPO.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9.YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
Request access to your personal data (commonly known as a “data subject access request”).
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of your personal data
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data
Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data
This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time
Where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Object to automated decision-making or profiling
You can ask us not to subject you to automated decision-making or profiling with legal or similar significant effects.
If you wish to exercise any of the rights above, please contact the Data Protection Officer (see About Us for contact details).
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We will to respond to all legitimate requests within one month unless your request is particularly complex or you have made a number of requests. In this case, it may take us longer to respond but we will notify you and keep you updated.