PRIVACY AND COOKIES POLICY
The site is owned and operated by InTouch Games Limited with registered office at Fountain House, Great Cornbow, Halesowen, West Midlands, B63 3BL. The company number is 04629082.
When this policy mentions “InTouch Games”, “we”, “us”, “our”, all of the following terms refer to InTouch Games Limited.
The Data Protection Officer is responsible for data protection. You can contact by emailing at [email protected] or by writing to them at Fountain House, Great Cornbow, Halesowen, West Midlands, B63 3BL
We may update, amend or modify this policy from time to time. Any change in this policy will depend on current and future applicable data protection laws, business requirements and any modification to this website including the addition of new features.
This policy was last updated on 01/05/2019
Purpose of this policy
The objective of this policy is to give clear indications on how InTouch Games processes your personal data when you visit this website and become a partner with us.
It also gives you the necessary information with regards to the way your personal data is being processed when:
- You submit a request to be contacted
- You submit a request for a call-back
- You join the InTouch Games partnership
- You visit/browse the website
Data protection laws
We process your personal data in line with current applicable UK legislation and more specifically: The General Data Protection Regulation (GDPR 2016), The Data Protection Act (DPA 2018), The Privacy and Electronic Communications Regulations (PECR 2003).
If you are located overseas, your personal data will also be processed in line with the above regulations and regardless of your geographical location.
Under the General Data Protection Regulation, consent should be given in a positive and affirmative way by individuals who share their personal data with organisations. According to the European Data Protection Directive, consent means: “any freely given specific and informed indication of his wishes by which the data subject signifies his agreement to personal data relating to him being processed.”
When you submit your personal data on the website to become an InTouch Games partner, you must accept the terms and condition agreement. With regards to marketing content, you will have the option to opt-in for such communications. Please note that you are free to opt-out from marketing at any time if you do not wish to receive marketing communications anymore. Your data will be retained according to our data retention policy and it will only be processed for the purposes that we have detailed in section 6 of this policy.
We gather a certain amount of personal data from the website. This data is the data that you submit to us on the “Join” section when you decide to become an InTouch Games partner. Please note that only certain fields are mandatory (those marked with a red star). However, if you decide to input data in a field that is not mandatory, we will also collect and process that data.
In order to become an InTouch Games partner, we have a business requirement to collect and process the following data:
- Website account
- First name
- Last name
- Affiliate / business name
- Email address
- Country dial code
- Contact number
- Full address
- Zip code
- Preferred language
- Payee name
- Payment method
- Bank name
- Confirm password
Purposes for processing
The following information give details on the purposes for which your personal data is processed:
- Contact you with regards to the query you have submitted
- Contact you because you have requested a callback
- Create a partner account with the data that you have submitted on the “Join” section of the website
- Administer your account and troubleshoot any issues
- Issue you commission payments in line with our agreement
- Contact you with regards to our agreements
The data that you have submitted to us will never be sold to third parties, marketing or analytics companies or used for any other purposes than those listed in this section.
Should any of the above purposes change, we will update this section accordingly and indicate the date when the update was done in Section 1 of this policy.
International data transfers
When your personal data needs to be transferred to an overseas country that is not part of the EEA (European Economic Area), we will always ensure that there are adequate levels of protection and a similar legislation with regards to data protection. Each country might have different laws and regulations with regards to data protection, however there are some agreements in place, e.g. the privacy shield for the United States of America.
Third Parties and Service Providers
We use the services of various third parties and service providers for our business operations. We have carefully conducted our due diligence to ensure that those third parties are compliant with current applicable data protection legislations and that they have implemented appropriate organisational and technical controls to safeguard your data. Those third parties will only process your data according to the directions that we have provided them as the “data controller”.
Data Security Safeguards
We have implemented a number of organisational and technical controls to ensure that the confidentiality, the integrity and the availability of your data is always safeguarded.
Our staff members are aware of the current data protection laws and we ensure that best security practices are always followed. All our systems processing data are protected with antivirus and firewall protection. We have implemented different levels of access for our systems to ensure that access to data is restricted to authorised staff only. All our datasets are regularly backed up to ensure that they are available in the event of a technical issue or disaster recovery. This website has an SSL certificate installed to ensure that network communications are encrypted and to avoid any interception of data.
Your rights under the General Data Protection Regulation
You also have all of the following rights:
- The right to rectification
- The right to access (also known as Subject Access Request)
- The right to erasure
- The right to restriction
- The right to object
- The right to lodge a complaint
If you wish to exercise your rights, please contact our data protection officer who will answer your query in due course. If at any point in time you decide to exercise your right to erasure, please note that we might not be able to deliver our services to you to their full extent.
Subject Access Request
You have the right to ask us to provide you a copy of the personal data we hold about you. Before we are able to answer your request, we must verify certain elements about your request including your identity before any data is transmitted to you. This is necessary to comply with our internal policies and for obvious security related reasons. We will aim to get to answer your request within 30 calendar days.
Please note that we reserve the right to charge a small administrative fee to answer a subject access request for repetitive requests.
We do not knowingly collect any data categorized as “sensitive”, including children data or criminal data. This website and the services we provide are not designed or directed to children. You must be at least 18 years of age to become a partner with InTouch Games. In the event that such type of data is accidentally collected, we will ensure that it is securely deleted as soon as we are aware of such occurrence.
If you have any questions with regards to this policy, the way your data is processed or if you would like to exercise any of your rights under the General Data Protection Regulation, please contact our Data Protection Officer at [email protected]
You can submit a complaint to the Information Commissioner’s Office if you have any concerns with regards to the way we process your personal data. However, we would prefer that you contact us before doing so.
Data Protection Legislation
If you would like to learn more about the General Data Protection Regulation, you can visit the ICO’s website following this link: https://ico.org.uk/.
With regards to the other UK data protection laws and regulations, you can find more information on the following links:
General Data Protection Regulation: https://ico.org.uk/for-organisations/data-protection-reform/overview-of-the-gdpr/
Data Protection Act: https://ico.org.uk/for-organisations/data-protection-act-2018/
Privacy and Electronic Communications Regulations: https://ico.org.uk/for-organisations/guide-to-pecr/what-are-pecr/
CHANGES AND UPDATES TO THIS POLICY
Last update: 01/05/2019
WHAT IS A “COOKIE”?
There are two main types of cookies used on websites:
- Persistent cookie which are stored on a user’s device from the first visit of the website
- Non-persistent cookie (also known as session cookie) are only in use for the duration of the internet session. Non-persistent cookie are never stored on a user’s device
Within the above types of cookies, there are several kind of cookies as listed below:
- Cookies that are “strictly necessary” for the website to work properly and offer basic browsing functionalities. Without those cookies, the website would not function properly and it
would be impossible to browse it and navigate through the different section.
- “Performance” cookies which collect basic information about how the website is used and which web pages are visited. Performance cookies also collect general information about the user’s
device (such as IP address, browser versions etc). The data collected is anonymous and is used for analytical purposes to improve the services we provide
- “Functionality” cookies which allow the websites to remember choices you make and your preferences as a logged in user
- “Targeting or advertising” cookies which are used to deliver relevant adverts to specific devices for a more tailored user experience
The cookies that are used on our websites do not collect any personally identifiable information from the website usage. The technical data that is collected is used for analytical purposes. This data helps us understand how we can enhance the browsing experience by providing more suitable content to the users of the website.
All of the following cookies are currently in use on the website:
|Cookie Name||Purpose||Persistent or Session|
|PHPSESSID||This cookie is associated with PHP. It is used by the website to store serialised state data||Expires when the session ends|
|__utma||This cookie is associated with Google Analytics. It collects analytical data about the way a user browses this website. This specific cookie records the number of visits, the length of the visit and whether or not the user has previously visited this website.||Expires after 2 years|
|__utmv||This cookie is associated with Google Analytics. It collects analytical data about the way a user browses this website. This specific cookie is used to for user-custom variables in Google Analytics.||Expires after 2 years|
|__utmz||This cookie is associated with Google Analytics. It collects analytical data about the way a user browses this website. This specific cookie records where the visitor initially came from (a link, a previous page, a search engine etc…)||Expires after 1 year|
|__cfduid||This cookie is related to Cloudflare (website cyber security solutions provider)||Expires after 1 year|
|Wordfence_verifiedHuman||This is a third party cookie set by Wordfence. This is a security plugin aimed at protecting this website against cyber attacks||Expires when the session ends|
WHAT INFORMATION IS GATHERED?
The data gathered revolves around the way the users interact with the website during their visit. This includes: what pages and sections of the website are visited, what links are being clicked on, how many users are currently logged in, whether or not content is being shared on social media. As mentioned previously, this data is purely technical and it does not allow us to identify an individual.
CONSENT FOR COOKIES
Any strictly necessary cookies that are in use on this website will not give the ability to opt-out. If you wish to opt-out of third party cookies, please refer to the following section. A pop up banner will appear on your first visit of this website to inform you about cookies and prompt you whether or not you agree. If you do not agree with cookies, please refer to the following sections.
HOW TO OPT OUT?
To opt out of Google Analytics cookies, visit the following link. All the information required to opt out of Google Analytics are detailed: http://tools.google.com/dlpage/gaoptout
HOW TO DELETE THE COOKIES THAT ARE STORED ON YOUR MACHINE?
If you want to delete the cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies. You can also access them through your internet browser.
ADDITIONAL INFORMATION ABOUT COOKIES
Please refer to the ICO’s following page for more information about cookie policies: https://ico.org.uk/for-organisations/guide-to-pecr/cookies-and-similar-technologies/
Please refer to the following page for general information about cookies and guidance on how to delete cookies that are stored on your machine: https://www.aboutcookies.org/
Please refer to the following page for more information about Google Analytics:https://www.google.com/analytics/#?modal_active=none