LIQUID CITY – PRIVACY POLICY

This privacy policy (“Policy”) applies to personal information held about our customers/players, suppliers and prospective suppliers, people who visit our websites, and anyone else whose personal information we hold (''you'', ''your'') when using our ''Services''. Any reference to ''Services'' in this Policy shall be deemed to be a reference to our Terms of Use.

In this Policy, references to “we”, “us”, and “our” means Keiichi Matsuda Ltd. t/a Liquid City, a company registered in England and Wales with company number 08662057 and whose registered office is at Studio 2.2, 1-5 Vyner Street, London, England, E2 9DG (“Liquid City”). This Policy set out how we process your personal data  when we act as a 'data controller' under the data protection legislation: which essentially means where we are responsible for deciding what personal information we collect and how we use it. We also may also operate as a 'data processor', meaning that we may  process personal information on behalf of another entity (for example a publisher of one of our games) - where this is the case we will only do so on the basis of a written agreement between us and the controller, setting out the controller’s instructions to us. When we refer to "personal information" we mean any details or information  from which you can be identified. Some of the information mentioned in this Policy is not 'personal information' as is meant under data protection legislation, but we may refer to it to help you understand what we do.

We are committed to protecting and respecting the personal information of everyone we deal with – that is important to us and we know it is important to you.

In this Policy you will find information about what types of personal information we hold about you, how and why we collect it, how we use it, and how we keep it secure. You will also find here information about your rights and how you can exercise them.

If you provide information to us about any person other than yourself, your employees, counterparties, your advisers or your suppliers, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.

If you are younger than 18 years of age, you must review this Policy with your parent(s) or guardian(s) and they have agreed to these terms on your behalf and take full responsibility for your compliance with them. Our websites and our games are not intended for children under 13 years old and we do not knowingly collect data relating to children under 13.

Please read this Policy carefully and if you need to contact us about anything that is in here, or for anything else related to your personal information, you can reach us by email at support@liquid.city or by post at the address above. 

You will find in this Policy information about the following: 

1 What information do we collect about you? 

1.1 What information we hold will depend on our relationship with you. Typically, this may include the following: 

2 How we collect information about you 

2.1 We will collect this information in a variety of ways depending on how we interact with you. 

3 How we use your information 

3.1 We use your personal information for the following purposes:

• To send you communications related to our Services and games, answer your enquiries or deal with your complaints;

• To provide  and manage our Services including our games;

• To allow you to participate in our website features;

• To verify  and confirm payments;

• For Account verification and clearance;

• For direct marketing letting you know about products and services that may be of particular interest to you;

• For administering surveys and opinion polls;

• For managing competitions and/or promotions and your registration for the same;

• We use technical and usage information/analytics to help us develop games that our customers want to play and to improve them and to detect cheating and activities that ruin the experience of players using our games, security risks, fraud and other unlawful activity;

• For business and website analysis and improvement;

• For the provision of social features as part of our Services;

• For customising your personal experience;

• To send you related information such as updates, security alerts and support messages;

• For on-site and in-app advertising and promotion of our goods and services and those of our service providers and trusted third parties;

• For sending you information about, and enabling you to participate in events (including online events) organised by us (with or without another party), including leisure, sports and/or charity events; prize draws and competitions; and surveys, marketing campaigns, market analysis or other promotional activities;

• For website, system administration and account verification;

• To publish leaderboards, community information, nicknames and club name/club information;

• To moderate communications between players either automatically or manually;

• To answer or satisfy legal or regulatory requirements; and

• When you interact with third party social networking features, to serve you with advertisements and engage with you on third party social networks (we encourage you to review the privacy notices/policies of these social networks to enable you to opt out of such activities).

4 Legal bases for processing 

4.1 There are a number of different legal grounds for processing personal information. Which one is applicable will depend on how we are using your information and for what purpose. In the majority of cases this condition will be that: 

• You have provided your consent to us using your personal information in that way. Generally, we do not rely on consent as a legal basis for processing your personal information although we will get 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; 
• Our use of your personal information is in our legitimate interest as a commercial organisation. For example, we use cookies to track information about how our website is used in order to continually improve its layout based on how you and other users interact with its content, and to personalise it to the user (for example, by showing content or a language which is relevant to your geographic location), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights;
• Our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to manage your account); and/or
• Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation (e.g. iv. for ensuring security of your personal data by preventing unauthorised access to it).

4.2 In relation to any processing of 'special categories' of personal data (including information regarding your health, religious or political beliefs, ethnic background, sexual life and sexual orientation) we will generally rely on obtaining specific consent from you at the time we collect the information unless there is a legal requirement or other justification for processing that information. 

4.3 We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the rules set out in this section, where this is required or permitted by law.

5 Sharing your information 

The personal information you provide to us may be shared with third party companies, agents, contractors, service providers or affiliated companies if this is necessary to provide you with our Services, respond to your inquiries or for any of the purposes described in this Policy. This may include: 

• Our business partners and service providers. We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you; 
• Sub-processors who store or process information on our behalf, in particular data analytics providers and data storage providers. Information shared with such providers is supplied in an anonymised format such that, that data cannot be linked to any particular individual and is therefore not considered to be 'personal data';
• Our auditors, insurers, lawyers and other professional advisers; 
• Credit reference agencies; 
• Law enforcement agencies, other governmental agencies or third parties if we are required by law to do so;
• Other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity. 

6 Social Features 

6.1 Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted. 

6.2 Our games and Services may include features from our partners, such as social media interaction tools. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices. 

7 Transferring your information outside Europe and the UK 

7.1 Our service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data. This means that when we transfer your personal information outside the UK (either directly or through a processor) we will only do so where (i) there are binding corporate rules in place; or (ii) the country where we are making the transfer to is a country deemed by the UK Information Commissioner’s Office to have an adequate level of protection in place for your personal information; or (iii) if there is no adequacy decision, where we have a lawful contractual arrangement with the service provider containing protections for your personal information (i.e. an international data transfer agreement). Please contact us if you want further information on the mechanisms used by us when transferring your personal information out of the UK.

8 Your rights 

8.1 Under EU data protection laws you have a number of rights in relation to your personal data. We respect and honour these rights and will help you to exercise them insofar as we are able. 

8.2 You have the right:

• To request access to or a copy of any personal data which we hold about you;
• To rectification of your personal data, if you consider that the information we are holding is inaccurate; 
• To ask us to delete your personal data, if you consider that we do not have the right to hold it; 
• To withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent); 
• To ask us to stop or start sending you marketing messages as described below in the marketing section; 
• To restrict processing of your personal data; 
• To data portability (moving some of your personal data elsewhere) in certain circumstances; 
• To object to your personal data being processed in certain circumstances; and
• To not be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data; and 
• To make a complaint about the processing of your personal data.

8.3 If you would like to exercise any of these rights, please contact us using our contact details set out below.

8.4 You will not have to pay a fee to access your 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.

8.5 Please note that these rights are not absolute – in some cases they will not apply to you, or to the particular use that we are making of your data, and there are exceptions (for example if we have to process the data to comply with our own legal obligations) but if that is the case we will let you know if you make a request that we believe we cannot comply with. 

8.6 Any request from you for access to or a copy of your personal data must be in writing and we will endeavour to respond 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.

8.7 We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change at the following email address: support@liquid.city.

8.8 If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact your local data protection authority. 

9 Marketing 

9.1 If you are one of our customers/players or have otherwise agreed to be contacted for marketing purposes we may use your personal information to send you information about us and our Services. We have a legitimate interest in processing your personal information for promotional purposes (see above). This means we do not usually need your consent to send you promotional communications. You can unsubscribe from receiving direct marketing at any time and details of how to unsubscribe will be included in any marketing communications we send you. You also have the option of "unsubscribing" from our mailing list at any time thereby disabling any further such e-mail or other communication from being sent to you by emailing support@liquid.city.

9.2 You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting "limit ad tracking" (Apple iOS) or "opt-out of interest based ads" (Android). 

9.3 For personalised in-game offers opt-out, you can use the options provided in the game settings. 

9.4 We will action any opt out request from you as soon as we can. 

10 How long will we keep your information? 

10.1 We will only keep the information we collect about you for as long as required for the purposes set out in this notice or as required to comply with any legal obligations to which we are subject. This will involve us periodically reviewing our files to check that information is accurate, up-to-date and still required. 

10.2 By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six (6) tax years plus the current tax year after they cease being customers for tax purposes. 

10.3 In some circumstances you can ask us to delete your data: see "Your rights" for further information. 

10.4 When it is no longer necessary to retain your personal information we will securely destroy your personal information in accordance with applicable laws and regulations. Sometimes we may 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.

10.5 If you opt out from marketing, we will retain your information to enable us to respect your wishes to not be contacted for marketing purposes. 

11 Security 

11.1 We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. Such measures will be appropriate to the nature of the data concerned and the level of risk. If you have been provided with a password to access any of our Services you should not share that password with anyone else. 

12 Links to Other Sites 

12.1 Our websites may contain links to other sites, including via our social media buttons. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites and a link does not constitute an endorsement of that website. Once you link to another website from our website you are subject to the terms and conditions of that website, including, but not limited to, its internet privacy policy and practices. Please check these policies before you submit any data to these websites. 

13 Complaints 

13.1 Questions, comments and requests regarding this Policy are welcomed and should be addressed to support@liquid.city. 

13.2 If you have any concerns about our use of your information, you also have the right (if you are a UK resident) to make a complaint to the Information Commissioner's Office, which regulates and supervises the use of personal data in the UK, via their helpline on 0303 123 1113. 

14 How we use cookies 

14.1 A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. 

14.2 A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. 

14.3 You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the relevant website. 

15 Changes to this Policy 

15.1 Any changes we make to our Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Policy.