Last update: 13 June 2021
Firstly, in this modern age privacy should be a major concern not just for the few but for everyone. This is why we have developed this privacy statement. Here we both explain how we collect and manage information and explore how to use the website whilst maintaining your privacy. We think this second point is important because we want our customers to have a good experience visiting our website but also to be aware of what information may be being used to understand who our customers are whilst maintaining a healthy distance between knowing enough from knowing too much.
We would prefer to not use any tracking or measurement other than the communication we receive from people. However we have to compete on the world stage of commerce. And to do that we have to gain a better insight of where are customers are coming from without knowing anything about them that is not absolutely vital. That second part is really important. We do not wish to know anything more than what country someone is from, what pages they are interested in and how they found us. Much like when someone comes to our stand at an exhibition. What was it you were interested in that you wanted to find out more about us. Unfortunately the service provides that we need to use want to know way too much information about our visitors and customers – surely that’s not fair or right unless visitors provide informed consent? Informed consent is difficult to protect. It shouldn’t be. It should be an essential part of business practice. Visitors and customers should know and understand what information they are providing and how it will be used. And if they do not wish to give it there needs to be an options to make sure the user has control. At the end of the day, we provide a service and you pay us money. This website provides you with information about the product and service and you then decide if you are interested in it. We are not here to covertly collect and maintain information to sell it as an information broker. Therefore we recommend you take a look at this notice and also take time to consider using the following services to help protect your privacy:
1.Operating System – make sure you know how your computer is collecting data about you. For example, Microsoft Windows will collect information about. You can control this by going to the Privacy settings
2. Web browser – make sure you know how your data is being protected with the choice of web browser. Chrome will collect a wide range of information about you. There are different versions of Chrome. It is based on the open source version called Chromium. This is what Microsoft Edge is based on. But if you want good privacy practice, use the Chromium verion or another browser that has clear privacy policies such as DuckDuck go for mobile, Mozilla Firefox for desktop and mobile, Opera, Vivaldi or if you use Linux there are a multiude of browsers available that a privacy conscious.
3. Browser Plugins – make good use of the fantastic plugins for Firefox and to make Chrome and Edge more secure and privacy focused we would reccomend using EFF’s Privacy Badger, Ghostery, DuckDuckGo plugins. Also be aware of open source projects such as ToSDR (Terms of Services Didn’t Read)
4. Facebook Container – Facebook has poor privacy practice as you may know from the range of news stories around the world. In response to this Mozilla developed Facebook Container, a plugin that stops Facebook from tracking people outside of Facebook. More information about this tool is available from Mozilla.
Concerns over Facebook and the reality of doing Online Business
Our website does use analytics. However, we do not live by analytics. The most important thing we use is feedback from customers! We like to hear from you and you can connect with us through our website. We have had to come to terms with the fact that people use social media platforms now more than websites. We think that this will hopefully change in the future. For the present however, we have had to be visible in such platforms such as Facebook. It is great to be able to see people come to us and talk to use through the platform but we urge caution. Make sure you know that your privacy is safe and be careful using any online platform.
When you use this website you know are aware of what data is used and that this website is now connected to Facebook. This is why we want to make you aware that if your are concerned about your privacy, there are systems available to help protect it and we encourage you to use them. If you are not concerned about your online privacy or you just want to know more, we suggest visiting:
- The UK Data Protection Act (We are based in the UK therefore governed by British Law)
- The Internet Society
- Family Friendly
- The European Union Priavacy Information Reference
There are many more services and tools that can keep you and your family safe. We hope you find this informative and that it helps to improve your online privacy and security.
Below is our statement regarding European and UK Law around information collection, storage and management.
General Data Protection Regulations Notice
What is this for?
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act [1998 OR 2018] and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Who we are
Blue Donut Games Ltd & Blue Donut Studios Ltd, is a multimedia development and publishing company. We are registered in England and Wales as a limited company under numbers are: 13340157 and 09592070 and our registered office is at 8 Spur Road, Cosham, Portsmouth, England, PO6 3EB
For the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice. Our ICO Data Controller Registration Number is: ZA218782
We have appointed a Data Protection Officer. Our Data Protection Officer is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted in this document (Contact Us), below.
How we collect personal data
We obtain personal data about you, for example, when:
- you request a proposal from us in respect of the services we provide;
- you OR your employer OR our clients engages us to provide our services and during the provision of those services;
- you contact us by email, telephone, post or social media (for example when you have a query about our services); or
- from third parties and/or publicly available resources (for example, from your employer or from Companies House).
- you place an order through our e-commerce system
- you interact through social media.
What personal data we collect and why we collect it
The information we hold about you may include the following:
- your personal details (such as your name and/or address);
- details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
- details of any products or services you have received from us;
- our correspondence and communications with you;
- information about any complaints and enquiries you make to us;
- information from research;
- Information we receive from other sources, such as publicly available information, information provided by your employer OR our clients.
Ordering from Us
We collect only information needed to process your order and contact you to advise of delivery and any issues regarding your order. We then retain this information under the requirements of English law. We will not knowingly forward to third parties who do not have adequate privacy protection. We will also only use your private information for marketing and sales if explicit consent has been given and is recorded.
We do not store credit card details on any of our services.
Our transaction processing partners are:
For more information about ordering from us visit our Terms and Conditions Page.
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
How we use personal data we hold about you
We may process your personal data for purposes necessary for the performance of our contract with you OR your employer OR our clients and to comply with our legal obligations.
We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
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.
Situations in which we will use your personal data
We may use your personal data to:
- carry out our obligations arising from any agreements entered between [you OR your employer OR our clients] and us (which will most usually be for the provision of our services);
- carry out our obligations arising from any agreements entered between our clients and us which will most usually be for the provision of our services where you may be a subcontractor, supplier or customer of our client;
- provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have given us explicit consented to be contacted for such purposes;
- seek your thoughts and opinions on the services we provide; and
- notify you about any changes to our services.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are required or permitted to do so by English Law.
How long we retain your data
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected and by the requirements dictated by English Law.
When assessing what retention period is appropriate for your personal data, we take into consideration:
- the requirements of our business and the services provided;
- any statutory or legal obligations;
- the purposes for which we originally collected the personal data;
- the lawful grounds on which we based our processing;
- the types of personal data we have collected;
- the amount and categories of your personal data; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.
Account and Website Registration
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
Change of Purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
Why might we share your personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
Which third-party service providers process your personal data?
“Third parties” includes third-party service providers and other entities within our group OR the members of our firm’s network. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking services.
All our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
We will not transfer the personal data we collect about you outside of the EEA unless it is using an approved Privacy Shield partner within the United States of America. This will only be in the case of storing data
OUTSIDE OF THE EEA
If you use place an order on our website or use our contact form and you are outside of the EEA there are no restrictions on the transfer of personal data to EEA countries. We will however place the same consideration on oversees customer’s data as those within the UK and the EEA where possible and where required, to ensure that we remain compliant with the law of the EEA and the UK.
We have put in place commercially reasonable and 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 data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Right of access, correction, erasure and restriction
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
- Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you.
- 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 exercised your right to object to processing (see below).
- 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 basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our data protection point of contact firstname.lastname@example.org.
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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
What rights you have over your website data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Your right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us) you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact at email@example.com.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Changes to this notice
Any changes we may make to our privacy notice in the future will be updated on our website at: www.bluedonutstudios.com/privacy-policy
This privacy notice was last updated on 23 May 2018.
Contacting us and making a complaint
If you have any questions regarding this notice or if you would like to speak to us about the way we process your personal data, please email firstname.lastname@example.org or telephone +44 (0)2392 162 101.
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner’s Office
- Rules for the protection of personal data inside and outside the EU: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
- Data Protection principles: https://ico.org.uk/for-organisations/guide-to-data-protection/data-protection-principles/
- Information about Privacy Shield: https://ico.org.uk/media/for-organisations/documents/2014413/data-transfers-to-the-us-and-privacy-shield.pdf
Points that companies need to consider as part of GDPR
We take your privacy as seriously as we do our own. Here are a few points to consider that companies need to be aware of and doing when you engage their services.
- Appoint an internal data privacy team to oversee GDPR activities and raise awareness with staff and customers.
- Review the current security and privacy processes in place & where applicable, revise company contracts with third parties & customers to meet the requirements of the GDPR
- Identify all Personally Identifiable Information (PII)/Personal data that is being collected and stored.
- Have a clear policy on how this information is being processed, stored, retained and then securely deleted.
- Assess the third parties with whom you disclose data
- Establish a clear procedure to respond to people’s rights under the European and English law regarding GDPR
- Establish and conduct annual Privacy Impact Assessments (PIA)
- Create clear and legally complaint processes for data breach notification actions
- Continuous employee awareness is vital to ensure continual compliance to the GDPR
- Transparency with Customers and the Public when collecting information.
- Consent needs to be explicit and not implied when collecting data and carrying out services.