Spawnpoint: Privacy Notice

A quick summary:

• This notice tells you what you need to know about the information relating to you that we collect as well as how, when, and why we collect it, what we do with it and how long we keep it for (this information is known as personal data).
• Basically, we collect personal data to provide our services to you, improve those services, and run our business
• We collect personal data when you sign up or use our services, and when you contact us (eg. by email or social media), or interact with us at a venue.
• We don’t sell it your personal data to anyone, but we do have to share it with some other companies so that they can help us run our business.
• We only keep your data for as long as we need it, and you have rights to ask us to do things like delete it, give you a copy of it, or correct it where it’s wrong.

About this Privacy Notice

Purpose - this privacy notice explains how we collect and process your personal data through your use of this website or our services, including any data you provide when you create an account, sign up to our mailing list, book our services, or interact with us at a VR venue.

Controller - Fennec Labs Ltd (Fennec House, Anson Court, Staffordshire Technology Park, Stafford, United Kingdom) is the controller and responsible for your personal data (referred to as "Spawnpoint", "we", "us" or "our" in this privacy notice). Our ICO registration number is ZA937147.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details below.

Children - Legally, you must be at least 13 to use our services. However, we don’t collect or store your age or date of birth. If you don’t understand something on this page, then please ask your parent or guardian to help. We do not knowingly collect personal data of anyone under the age of 13 without parental or guardian consent. If you’re a parent or guardian and are concerned about how we process your child’s personal data, please do get in touch at legal@spawnpoint.io.

Contact Details - if you have questions about this privacy notice or our privacy practices, please contact us at legal@spawnpoint.io or via our trading office address above.

Complaints - you also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.

Data we collect about you

Personal data, or personal information, means any information relating to an identifiable individual and information 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 (such as your name, display name, and password)
• Contact data (such as your email address)
• Gameplay data (such as scores, history, and statistics)

This list is non-exhaustive and through your communications with us (eg. through this website or social media) you may provide us with further information which we do not actively collect.

We do not collect any sensitive ('special category') data about you (i.e. 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).

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 provide you with goods or services). 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.

How do we collect your personal data?

We only collect information about you including through direct interactions (i.e. when you interact with us by creating an account, making a booking, or sending us an email). We may also collect some information from venues, including when you provide your contact details to a venue representative, so that we can send you a follow-up email.

How do 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 the contract we are about to enter into or have entered into with you (to provide our services).
• 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 although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

See the Glossary at the bottom of this Privacy Notice for more information on the types of lawful basis that we will rely on to process your personal data, including performance of a contract and legitimate interests.

Specific purposes - please see below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us for more information.

Purpose / Activity	Lawful basis for processing
To register you as a new customer	To register you as a new customer Performance of a contract with you.
To process and deliver orders and services	Performance of a contract with you. Necessary for our legitimate interests in recovering any money owed to us.
To manage our relationship with you including notifying you about important changes or asking for feedback.	Performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests in improving our services.
To administer and protect our business and this website	Necessary for our legitimate interests (for running our business).

Who do we share your personal data with?

We don’t sell your personal data to anyone, but we do sometimes need to share it with others so that we can provide our experiences to you. These third-parties are:

• Service providers including our website and server hosting providers
• Our professional advisors (including legal and tax advisors)
• Our partners, promotors, venues, and other providers who make our experiences possible
• Services that help us track bugs and errors

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.

We do not transfer your personal data outside the EEA.

How do we keep your personal data safe?

We have 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 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.

How long do we keep your 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 believe there is a prospect of a related dispute.

What legal rights do you have regarding your personal data?

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are (with more detail on each set out in the Glossary):

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to the processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent

To exercise any of the rights set out above, please contact us. 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.

GLOSSARY

Lawful Basis

Legitimate Interest - means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract - means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation - means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Your Legal Rights

In some circumstances, you have the right to:

• 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. 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.