Privacy | BULKHEAD

PRIVACY POLICY

1. INTRODUCTION AND GENERAL TERMS

These terms apply to the use of games and other products developed by BULKHEAD Limited. (“BULKHEAD” / “we” / “us”). Our office is at Cardinal Square, 10 Nottingham Road, Derby, DE1 3QT

We are a company registered in England, with company number 09877574.

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of our website (bulkhead.com) (the “Website”)

If you have any questions or comments about this Privacy Policy, please contact us at privacy@bulkhead.com

We are committed to protecting and respecting your privacy. The Privacy Policy explains the basis on which personal information we collect from you will be processed by us. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

Please read this Privacy Policy carefully as it contains important information about the following:

• What information we may collect about you;
• How we will use information we collect about you;
• Whether we will disclose your details to anyone else; and
• Your choices and rights regarding the personal information you have provided to us.

The Website may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate, we may notify you of changes by email or through the website.

2. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information, which may include your personal data.

Contact information provided by you when using the Contact Form on the Website

Contact Information

We may ask you for, or you may submit, certain contact information to us whenever you contact us through the Website.

This may include:

• your email address;
• your username;
• your password; and
• any details you voluntarily submit in the contact form.

You are under no obligation to provide us with any details, but if you don’t provide all relevant information, we may not be able to help.

Information provided by you when using the Website

Analytics

We may collect technical information about your use of the Website through the use of tracking technologies and analytics.

This may include:

• your IP address;
• user interface usage (e.g. buttons clicked, screens viewed);
• hardware or device information (e.g. CPU, RAM, video card configuration, screen size, resolution);
• your location;
• identification of crashes and bugs.

We use the following third party analytics providers when conducting our analysis:

• Google Analytics – google.com/policies/privacy.

Please see the section on “CONSUMER CONTROL AND OPT-OUT OPTIONS” below for details on how you can control whether this information is collected.

3. WHY WE COLLECT INFORMATION ABOUT YOU

We may process information about you (including Analytics and Contact Information) for the following reasons:

• Analytics: We would like to collect and use information about your use of the Website, and analyse it to compile statistical reports regarding that activity (for example, your IP address is used to approximate the country from which you access our Website, and we aggregate this information together so we know that, that visitors to our Website come from a specific territory). This processing is necessary for us to pursue our legitimate interest in improving our Website, and providing a more relevant service to our customers. This information is not used to develop a personal profile of you.

• Requests for voluntary feedback: From time to time, we will offer you the opportunity to provide feedback on the Website via a free form text box. It is entirely voluntary and you are free to decide what information you provide to us. This processing is necessary for us to pursue our legitimate interest in (i) ensuring that our online services function properly so that you and other users have the best experience when using the online services; and (ii) identifying and correcting any bugs in the online services.

• Enquiries and Support: We may process Contact Information so that we are able to properly respond to your enquiries and support requests either via the Website or by email through privacy@bulkhead.com. In line with the legitimate interest we have in promoting our business, we will process your enquiries to reply and provide you with information about the services we offer. We may also process enquiries to take steps you ask of us with a view to entering into an agreement to provide you with our services.

4. DATA SHARING

We will share your information with third parties only in the ways that are described in this Privacy Policy

• Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

• Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

• Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches or to protect the rights, property or safety of BULKHEAD, our customers or others.

5. AUTOMATED DECISION MAKING

We do not use automated decision-making methods which do not involve human involvement to process your information only in the ways that are described in this Privacy Policy.

6. CONSUMER CONTROL AND OPT-OUT OPTIONS

You can opt-out of our use of Analytics to understand browsing behaviour (as described in this Privacy Policy) at any time. If you would like to opt-out of Google Analytics monitoring your behaviour on our Website please use this link: (https://tools.google.com/dlpage/gaoptout/).

You can also always choose to enable or disable cookies in your internet browser. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser. For further information about cookies, please see: www.allaboutcookies.org, and how to adjust your browser settings here: www.allaboutcookies.org/manage-cookies.

7. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have the following rights over the way we process personal data relating to you, as set out le below. These rights are not absolute and they do not always apply in all cases. We aim to comply without undue delay in response to any request by you:

• to restrict, stop processing, or to delete your personal data;
• for a copy of data we are processing about you and have inaccuracies corrected;
• for the transfer of your personal information to another party.

Please send your requests to privacy@bulkhead.com

Make a complaint to a Supervisory Authority

If you are unhappy with the way we are processing your personal data, please let us know by contacting us via privacy@bulkhead.com.

If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.

8. DATA RETENTION

We will only retain your personal information 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 information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements

9. CHILDREN

We do not use our Online Services to knowingly solicit information from, or market to, children under the age of 13. Our terms of use prohibit users aged under 13 years from accessing our Online Services. In the event that we learn that we have collected personal information from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age, please contact us at privacy@bulkhead.com.

10. SECURITY

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases are password-protected and encrypted using Transport Layer Security (TLS) and Secure Sockets Layer (SSL).

Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

11. INTERNATIONAL DATA TRANSFERS

Information we collect about you will be stored within the European Union (EU) on a secured server.

Your personal information may be transferred outside of the EU by Google.

Where we transfer your information outside of the EU, we have agreements in place with those parties which include standard data protection clauses adopted by a data protection regulator and approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to us at privacy@bulkhead.com.

CONTACT INFORMATION

If you are located in a country not included in the EEA or the UK and have questions about our handling of your personal data or for any other matters please contact privacy@bulkhead.com

If you are located in the EEA or the United Kingdom and have questions about your personal data or would like to request to access, update, or delete it, you may contact our representative at:

In the EEA:
Bird & Bird GDPR Representative Ireland
Deloitte House
29 Earlsfort Terrace
Dublin 2
D02 AY28
EUrepresentative.Splash@twobirds.com

Key Contact:
Vincent Rezzouk-Hammachi