It applies whenever we collect your personal data, including when you use our website, social media or other digital platforms, collectively known as our ‘channels’, so please read it carefully.
Purpose of this Policy
This website may be used by both adults and children however we do not knowingly collect data relating to children.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Email address: firstname.lastname@example.org
Postal address: Unit D, Mill Court, Featherstone Road, Wolverton Mill, Buckinghamshire, MK12 5EU.
Information we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may supplement the information that you provide with other information that we obtain from our liaison with you or which we receive from other organisations, for example, our partners.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details however this data will typically be collected by a third party payment service, SAGE Pay.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes 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). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal 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 we collect personal data
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below. Technical Data from the following parties:
(a) analytics providers such as Google;
(b) advertising networks; and
(c) search information providers
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from data brokers or aggregators.
- Identity and Contact Data from publicly available sources
How 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.
- 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 obtain 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.
We plan to use your data for the following purposes:
- To register you as a new customer.
- To administer and provide products and services you request or have expressed an interest in.
- To enable us to administer any competitions or other offers/promotions which you enter into.
- To communicate with you in the event that any products or services you have requested are unavailable.
- For record keeping purposes.
- To carry out market research so that we can improve the products and services we offer across our channels.
- To track your activity on our channels.
- To create an individual profile for you so that we can understand and respect your preferences.
- To personalise and improve your experience on our channels.
- To personalise and tailor any communications that we may send you.
- For profiling purposes to enable us to personalise and tailor any marketing communications that you may consent to receive from us.
When we provide you with products or services we may collect and store any personal information that you provide to us.
We may, for example, keep a record of your name, address, delivery address, email address, telephone number and payment card details.
When you sign up with us for an online account, register to receive marketing communications from us (and/or our partners), enter one of our competitions, fill in one of our forms (whether online or offline) or otherwise expressly provide us with your personal information, we may collect and store any personal information that you provide to us and may use it to personalise and improve your experience on our channels, provide products and services you request from us, and carry out profiling and market research.
When you interact with our channels, we may also automatically collect the following information about your visit. This is primarily to help us better understand how our customers use our channels to enable us to create better content and more relevant communications:
- How you have reached our digital platform and the internet protocol (IP) address you have used.
- Your browser type, versions and plug-ins, and your operating system.
- Your journey through our channels, including which links you click on and any searches you made, how long you stayed on a page, and other page interaction information.
- Which videos you have watched and for how long.
- What content you like or share.
- Which adverts you saw and responded to.
- Which pop up or push messages you might have seen and responded to.
- Your subscription status.
- Information collected in any forms you complete.
We may also infer your country of location from the IP address you have used to access our digital channels and we may analyse which marketing activity led to your taking specific action on our digital channels (e.g. downloading an app).
News, offers and opportunities
We want you to be the first to know about new games and activities, new products, our latest news, competitions and updates, and any special offers we may have.
If you have not already signed up to receive these exciting communications from us, please email email@example.com. You can unsubscribe at any time.
Please note, if you do not choose to receive this information, we will be unable to keep you informed of new games and activities, new products, our latest news, competitions and updates, and any special offers we may have.
We may also participate in Facebook’s ‘Custom Audience’ service from time to time. This service enables My Cheeky Monsters to display to you personalised advertisements when you visit Facebook’s social media platforms.
It works by converting your email address to a unique number that Facebook uses to match to unique numbers that Facebook generates from email addresses of its users. Where we use Facebook Custom Audiences, we will only include you if you have consented to receive marketing from us. If you have given us your consent, you can change your mind at any time by unsubscribing.
Disclosure of your information
In order to provide our products and services to you or to otherwise fulfil contractual arrangements that we have with you, we may need to appoint other organisations to carry out some of the data processing activities on our behalf. These may include, for example, payment processing organisations, delivery service organisations, fraud prevention and screening and credit risk management companies, and mailing houses.
We may share your data with advertising networks and/or social media platforms for the purposes of selecting and serving relevant adverts to you via those networks/platforms, and to search engine and analytics providers.
We may share your data with our carefully selected partners (as may change from time to time) but we will only do this if you have consented to receive marketing relating to our partners.
In all instances where we disclose your information to third parties, we will ensure that your information is appropriately protected.
Cookies are small pieces of information that are stored by your browser on your computer’s hard drive. They are often used as a mechanism for websites to remember things that a website browser has done there in the past, for example, clicking on particular buttons, logging in, or having read pages on that site months or years ago.
In general, we use the following types of cookie:
Strictly Necessary Cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log in to secure areas of our website, use the shopping cart feature when buying products etc.
Analytical/Performance Cookies: These allow us to recognise and count the number of visitors and see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users can find what they are looking for easily.
Functionality Cookies: These are used to improve the functional performance of the website and make it easier for you to use. For example, they are used to remember that you have previously visited the website and asked to remain logged in to the website.
Targeting Cookies: These cookies record your visit to our website and your browsing habits, such as the pages you have visited and the links you have followed. They are used to deliver advertising which is more relevant to your interests and also may be used to limit the number of times that you see an advertisement. They may be placed by us or by advertising networks with our permission. Please note, these cookies do not contain any of your personal information.
By continuing to use our website without choosing to delete/block cookies, you agree that we can place these types of cookies on your device.
You can manage cookies by activating the setting on your internet browser that allows you to refuse the setting of all or some cookies.
For further information visit www.aboutcookies.org.
Please refer to the instructions or the online help files available via your relevant browser if you wish to manage cookies in this way.
To manage cookies relating to targeted advertising activities, you can visit www.youronlinechoices.com.
To opt-out of being tracked by Google Analytics across all websites you can visit tools.google.com/dlpage/gaoptout.
Changes to this Cookies Policy
We aim to meet high standards and our policies and procedures are, therefore, constantly under review. From time to time we may change how we use and place cookies. We recommend that you check this page periodically in order to review our current policies and practices.
Security of information
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
When you submit your credit/debit card details to us, we use industry standard Secure Sockets Layer (SSL) encryption technology to guard your information.
In addition, we have security procedures in place to protect our paper-based systems and computerised databases from loss and misuse, and only allow access to them when it is absolutely necessary to do so. 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Where a password is required to access certain areas of our channels, you are responsible for keeping your password secure and confidential. Please do not share or disclose your password to any other person.
Where to make a complaint
How long will you use my 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 reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. They include rights to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
Further details are set out in the Glossary. If you wish to exercise any of your rights, please contact us.
No fee usually required
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 is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service 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.
External Third Parties
- Service providers who provide IT and system administration services and payment processors.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities.
YOUR LEGAL RIGHTS
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.