We collect or use the following information to provide services and goods, including delivery:

• Names and contact details
• Addresses
• Purchase or account history
• Account information
• Information relating to compliments or complaints

We collect or use the following information for recruitment purposes:

• Contact details (eg name, address, telephone number or personal email address)
• Date of birth
• National Insurance number
• Copies of passports or other photo ID
• Employment history (eg job application, employment references or secondary employment)
• Education history (eg qualifications)
• Right to work information

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details
• Address
• Account information
• Purchase or service history
• Customer or client accounts and records
• Correspondence

Under UK data protection law, we must have a "lawful basis" for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO's website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO's website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
• Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
• Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
• Your right to withdraw consent -- When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide services and goods are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract -- we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Our lawful bases for collecting or using personal information for recruitment purposes are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract -- we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation -- we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests -- we're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • Our legitimate interest in collecting and retaining personal data for recruitment purposes is to identify and evaluate suitable candidates for our organisation. This includes considering applications for current openings and maintaining a talent pool for future opportunities. We believe this benefits both our company, by allowing us to find the best talent, and potential candidates, by providing them with employment opportunities. As individuals voluntarily submit their information for job considerations, we believe this aligns with their reasonable expectations and that the potential benefit outweighs any minimal privacy impact.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract -- we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legitimate interests -- we're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • Our legitimate interest in collecting and retaining personal data for handling queries, complaints, or claims is to provide effective customer support and gain insights to improve our products and services. We believe this benefits both our business, by allowing us to enhance our offerings, and our customers, by enabling us to address their concerns efficiently and refine their user experience. As customers initiate these interactions, we believe this aligns with their reasonable expectations and that the benefit of improved service and products outweighs any potential privacy impact.

• Directly from you
• Schools, colleges, universities or other education organisations
• Councils and other public sector organisations
• Publicly available sources
• Previous employers
• Third parties:

  We may share personal data with certain third parties to facilitate our business operations and deliver our services effectively. These third parties may include: Technology service providers who assist in the development and hosting of our games and websites Educational institutions and partners for collaborative projects and initiatives Professional service providers such as legal advisors and accountants Recruitment partners to assist with our hiring processes Analytics providers to help us improve our games and services We only share personal data when necessary and with third parties who have agreed to handle the data in compliance with applicable data protection laws. We have appropriate agreements in place to ensure that any shared data is processed securely and in accordance with our instructions. The specific third parties we work with may change as our business evolves, but we are committed to always protecting your personal data in line with our privacy policy and applicable regulations.

For information on how long we keep personal information, see our retention schedule at https://badbear.games/retention

Data processors

Cloud Service Providers (IT sector, global)

This data processor does the following activities for us: They provide cloud storage and computing services for our business operations and development processes.

Others we share personal information with

• Professional or legal advisors
• Organisations we're legally obliged to share personal information with
• Suppliers and service providers
• Other relevant third parties:
  • Amazon Web Services (AWS)
  • Microsoft Azure
  • BeaBear Games CIC's Legal Counsel (to be appointed)
  • BeaBear Games CIC's Accounting Service (to be appointed)

Where necessary, our data processors may share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

Amazon Web Services (AWS)

Category of recipient: Cloud Service Provider

Country the personal information is sent to: Various (AWS Global Infrastructure)

How the transfer complies with UK data protection law: The International Data Transfer Agreement (IDTA)

Microsoft Azure

Category of recipient: Cloud Service Provider

Country the personal information is sent to: Various (Azure Global Infrastructure)

How the transfer complies with UK data protection law: The International Data Transfer Agreement (IDTA)

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we've used your data after raising a complaint with us, you can also complain to the ICO.

The ICO's address:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

Email

privacy@badbear.games