We are Bear Group Ltd ('Bear Group Ltd') and this Privacy & Cookies policy (the 'Policy') describes the ways in which we collect and use your information (and information about you) when you play one of our games (each a 'Game' and together the 'Games') on a browser, through a social networking site (where our Games may be described as an application) or as an app.
By playing a Game you are agreeing to be bound by this Policy in respect of the information collected about you. We may change this Policy at any time. If we decide to do so we shall notify you with pop-ups or banners when you enter or begin to use a Game, we shall deem your continued use of the Game as indicating your consent to such changes.
If you have any queries about this Policy, please get in touch with us using the contact details set out below and we will do our best to answer your questions.
SECTION A: WHAT INFORMATION WE COLLECT ABOUT YOU
- Personal Information Collected: We will collect the following personal information from you when you use our Games:
- your name;
- your job title;
- your e-mail address;
- your date of birth and other such information required to prove your age and identity (for example a scanned ID). We also use third party agencies to verify data in relation to your age and identity;
- your home address;
- your mobile telephone number;
- your credit card information and bank account details;
- information about your preferences and interests;
- information in relation to your purchases;
- information which we require to ensure compliance with and assist with enforcement of the Bear Group Ltd Terms and Conditions.
- any information you choose to provide us with if you contact us or via customer surveys;
- we may record your IP address, MAC address or the internet browser which you are using when you play Games; and
We use Google Analytics cookies to collect information about how visitors use our games, which we use to help improve it. These cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited
DoubleClick collects information to make Google's advertising more relevant to you.
Social features like the Facebook Share button set cookies to smoothly integrate our site with Facebook's share functionality.
SECTION B: WHAT WE DO WITH YOUR INFORMATION
- How we use collected information: We will use the information we collect for our business management purposes and in order to provide the best service possible via the Game. We may use your information to:
- facilitate the improvement of the Games and your experience of the Games;
- internal record keeping;
- complete your transactions;
- provide technical support in relation to player enquires, resolving disputes, collecting fees and troubleshooting;
- verify your age and identity;
- prevent fraud, money laundering and other criminal activities (in accordance with our related internal policies);
- share it for the purposes described in paragraphs 6, 7 and 8 below; and
- contact you in relation to goods and services as described in paragraphs 9 and 10 below.
- Sharing information within the Games: We may share your information with other third parties in relation to your playing of the Games. For example:
- other players shall be able to see your name and profile picture if you choose to play against them, either if they are a pre-designated contact from Facebook or elsewhere, or if you have selected to play a Game against a random opponent;
- all players shall be able to see your username and profile picture as part of a high-score board; and
- Payment Processors shall be able to see your name, profile picture, email address and any other details, including your financial details which you supply them with for the purposes of processing payment.
- Sharing information with third parties: We may, subject to our obligations to comply with applicable data protection legislation, share your information with third parties including:
- in relation to the sale of some or all Bear Group Ltd's business, or its assets, to any third party, or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
- with data aggregators as part of an analysis of player metrics;
- with service providers to analyse how our Games are being used;
- with third parties in order to verify your age and identity;
- with law enforcement agencies in compliance with law enforcement (if required to do so by a court order or for the purposes of prevention of fraud or other crime) i.e. we will keep your information confidential except where requested to disclose if necessary; or
- as detailed in paragraph 10.
- Publicity: By taking part in any Bonus or Promotion (including those described in this Section C of the Bear Group Ltd Terms and Conditions) you agree that Bear Group Ltd has your permission to use your username and/or first name for advertising and promotional purposes without additional compensation or remuneration unless prohibited by law.
- Information about other products and services: From time to time we may send you information about our Games, applications, services and other digital goods which we think may be of interest to you. If you do not want to receive this information, you must unsubscribe by contacting us any time via e-mail to email@example.com.
- Information about third party products and services: With your prior consent, we may pass your information onto one of our business partners or to other selected third parties to enable them to send you information which may be of interest to you, but only if you have given us permission to do so. You can unsubscribe at any time by contacting us via e-mail at firstname.lastname@example.org.
SECTION C: WHAT IF WE CANNOT COLLECT THIS INFORMATION
- What if we cannot collect this information: Subject to the provisions of this Section C, you can tell us to stop collecting or using the information described above at any time by sending an e-mail to email@example.com. We will respond within 21 days. However, we reserve the right to close your Account under the Bear Group Ltd Terms should you decide to withdraw your consent for us to collect such information.
- Age Verification and our policy towards children under the age of 18: As detailed in paragraph 3(a) of the Bear Group Ltd Terms and Conditions, we cannot offer our service to persons under the age of 18. Therefore, we require information to verify that our players are aged 18 and over. If such information cannot be provided to our satisfaction (at our absolute discretion) we reserve the right to refuse your Account or close your Account. Our services are not directed at or directed to children under the age of 18. We do not knowingly collect personally identifiable information in relation to children under the age of 18, and such children should not use our Games. If we discover we have collected personal data in relation to any children under 18 we shall take reasonable steps to delete such information.
- Information in relation to our requirements to prevent fraud and money laundering: If such information which we require in relation to our requirements to combat fraud or money laundering cannot be provided by you then we reserve the right to refuse or suspend your Account or close your Account.
- Disabling Cookies: The use of the cookies described above improves the functionality of our Games and your experience using them. If you do not want these cookies to be served on your device, you are able to disable them by changing the settings on your browser, or on your device. Please note that if you do decide to disable cookies you may not be able to access some of the Games, some of the features of the Games or the Games may not function properly. By continuing to use the Games, including using social networking media functionality, you consent to the relevant cookies being set on your device.
- Financial Information: Your financial information is collected and used by Payment Processors (as defined in our Bear Group Ltd Terms and Conditions) to allow you to make purchases within the Games. Bear Group Ltd retains your card details (although not your CVV number), we keep a record of your purchases and your aggregate spending.
SECTION D: PROTECTING YOUR INFORMATION
- Security: We have implemented technology and policies to safeguard your privacy from unauthorised access and improper use.
- Links to third party websites and third party adverts: We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from the Games, adverts in the Games or from adverts on a webpage when you are playing the Games. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions. In addition, if you linked to the Games from a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
- Notification of the ICO: We have notified the Guernsey Data Protection Commissioner of our role as a 'data controller' under the Data Protection Law 2001 our registration number is 012758.
SECTION E: CONTACT US
- Contact details: If at any time you would like to contact us with your views about our privacy or cookies practices, or with any enquiry relating to your personal information, you can do so by sending an e-mail to us at firstname.lastname@example.org or write to us at Data Protection Officer, Bear Group Ltd, Inchalla, Le Val, Alderney,GY9 3UL.