Privacy Policy
COMMONWEALTH FOUNDATION LTD.
(“we” and “us”) is committed to protecting your privacy.
1. Why do we have this Privacy
Policy?
This Privacy Policy explains how
we process the information we collect about you, how you can instruct us if you
prefer to limit the use of that information and procedures that we have in
place to safeguard your privacy. We have included a glossary section
to help you understand the meaning of some of the terms used in this
privacy policy.
It is important that you read this Privacy Policy together with any other
privacy notice or fair processing notice we may provide on specific occasions
when we are collecting or processing personal data about you so that you are
fully aware of how and why we are using your data. This Privacy Policy
supplements the other notices and is not intended to override them.
Controller and Contact Details
We are the data controller and are responsible for
your personal data. If you have any queries about this Privacy Policy,
including any requests to exercise your legal rights, please contact us using
the details below:
COMMONWEALTH FOUNDATION LTD.
2 Venture Drive #11-31 Vision
Exchange Singapore (608526)
Legal department e-mail address:
legal@cryptocommonwealth.io
Third Party Links
Our website may include links to third-party websites,
plug-ins and applications. Clicking on those links or enabling those
connections may allow third parties to collect or share data about you. We do
not control these third-party websites and are not responsible for their privacy
statements. When you leave our website, we encourage you to read the privacy
notice of every website you visit.
2. What personal data do we
collect, how we collect it and how do we use it? What personal data do we
collect?
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 collect, use, store and transfer the following
kinds of information about you:
- Identity Data includes first name, last name,
username or similar identifier.
- Contact Data includes billing address, delivery
address, email address and telephone numbers.
- Financial Data includes bank account and payment
card details.
- 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 also collect, use and share
Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data may be derived from your personal data but is not considered
personal data in law as this data does not directly or indirectly reveal your identity.
For example, we may aggregate your Usage Data to calculate the percentage of
users accessing a specific website feature. However, if we combine or connect
Aggregated Data with your personal data so that it can directly or indirectly
identify you, we treat the combined data as personal data which will be used in
accordance with this privacy notice.
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.
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.
How do we collect personal data?
We use different methods to collect personal data
including through:
- Direct interactions
You may give us personal data by filling in forms or
by corresponding with us. This includes personal data you provide when you:
- Become a member
- Create an account on our website;
- Subscribe to our newsletter;
- Identify yourself as a media with an interest in
games and related topics;
- Request marketing to be sent to you;
- Enter a competition, promotion or survey; or
- Give us some feedback.
- Automated technologies or
interactions.
As you interact with our website, we may automatically
collect Technical Data about your equipment, browsing actions and patterns. We
collect this personal data by using cookies and other similar technologies. We
may also receive Technical Data about you if you visit other websites employing
our cookies.
- Third parties or publicly
available sources
We may receive personal data about you from various
third parties and public sources as set out below.
- Technical Data from the following parties:
- Analytics providers such as Google;
- Contact, Financial and Transaction Data from
providers of technical, payment and delivery services such as PayPal.
- Identity and Contact Data
from publicly available sources such as Companies House and the Electoral
Register.
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:
|
Purpose/Activity |
Type of data |
Lawful basis for processing
including basis of legitimate interest |
|
To deal with your enquiries and
requests |
a) Identity |
(a) Performance of a contract
with you |
|
To: |
(a) Identity |
(a) Performance of a contract
with you |
|
To manage our relationship with
you which will include: |
(a) Identity |
(a) Performance of a contract
with you |
|
To enable you to partake in a
prize draw, competition or complete a survey |
(a) Identity |
(a) Performance of a contract
with you |
|
To administer and protect our
business and this website (including troubleshooting, data analysis, testing,
system maintenance, support, reporting and hosting of data) |
(a) Identity |
a) Necessary for our legitimate
interests (for running our business, provision of administration and IT
services, network security, to prevent fraud and in the context of a business
reorganization or group restructuring exercise) |
|
To deliver relevant website
content and advertisements to you and measure or understand the effectiveness
of the advertising we serve to you |
(a) Technical |
Necessary for our legitimate
interests (to study how customers use our products/services, to develop them,
to grow our business and to inform our marketing strategy) |
|
To use data analytics to
improve our website, products/services, marketing, customer relationships and
experiences |
(a) Identity |
Necessary for our legitimate
interests (to define types of customers for our products and services, to
keep our website updated and relevant, to develop our business and to inform
our marketing strategy) |
|
To make suggestions and
recommendations to you about goods or services that may be of interest to you
including issuing press releases and storage of your personal data on a CRM
system |
(a) Identity |
Necessary for our legitimate
interests (to develop our services and to carry out our business functions) |
|
To process messages you post in
our forum or other message areas |
(a) Necessary to comply with a
legal obligation |
- 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 or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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 contact us.
Purposes for which we use your
personal data
We have set out below, in a table format, a
description of all the ways we plan to use your personal data, and which of the
legal bases we rely on to do so. We have also identified what our legitimate
interests are where appropriate.
Note that we may process your personal data for more
than one lawful ground depending on the specific purpose for which we are using
your data. Please contact us if you need details about the specific legal
ground we are relying on to process your personal data where more than one
ground has been set out in the table below.
Change of purpose
We will only use your personal data 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
you wish to get an explanation as to how the processing for the new purpose is
compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated
purpose, we will notify you and we will explain the legal basis which allows us
to do so.
Please note that we may process your personal data
without your knowledge or consent, in compliance with the above rules, where
this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the
parties set out below for the purposes set out in the table above:
- Our employees
- Service providers acting as processors based in
Ireland and the USA who provide IT and system administration services.
- Professional advisers acting as processors or joint
controllers including lawyers, bankers, auditors and insurers based in the
United Kingdom who provide consultancy, banking, legal, insurance and
accounting services.
- HM Revenue & Customs, regulators and other
authorities acting as processors or joint controllers based in the United
Kingdom who require reporting of processing activities in certain
circumstances.
- Third parties to whom we may choose to sell,
transfer, or merge parts of our business or our assets. Alternatively, we
may seek to acquire other businesses or merge with them. If a change
happens to our business, then the new owners may use your personal data in
the same way as set out in this privacy notice.
- Some of our external third parties are based outside
the European Economic Area (EEA) so their processing of your personal data
will involve a transfer of data outside the EEA. Whenever we transfer your
personal data out of the EEA, we ensure a similar degree of protection is
afforded to it by ensuring at least one of the following safeguards is
implemented:
- We will only transfer your personal data to countries
that have been deemed to provide an adequate level of protection for
personal data by the European Commission. For further details, see
European Commission: Adequacy of the protection of personal data in non-EU
countries.
- Where we use certain service providers, we may use
specific contracts approved by the European Commission which give personal
data the same protection it has in Europe. For further details, see
European Commission: Model contracts for the transfer of personal data to
third countries.
- Where we use providers based in the US, we may
transfer data to them if they are part of the Privacy Shield which
requires them to provide similar protection to personal data shared
between the Europe and the US. For further details, see European Commission:
EU-US Privacy Shield.
- Please contact us if
you want further information on the specific mechanism used by us when
transferring your personal data out of the EEA.
3. Information Security
We have put in place appropriate security measures to
prevent your personal data from being accidentally lost, used or accessed in an
unauthorized way, altered or disclosed. In addition, 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.
4. Data retention
How long will you use my personal
data for?
We will only retain your personal data for as long as
necessary to fulfill 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 data, we consider the amount, nature, and sensitivity of the personal
data, the potential risk of harm from unauthorized 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
requirements.
Details of retention periods for different aspects of
your personal data are available in our retention policy which you can request
from us by contacting us.
In some circumstances you can ask us to delete your
data: please refer to your legal rights below for further information.
In some circumstances we may anonymize 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:
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: (a) if you want us to establish the data’s accuracy; (b) where our
use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.
If you wish to exercise any of the rights set out
above, 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 may 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 may 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.
5. Cookies
Pieces of information transferred to your computer’s
hard disk from a website are known as cookies. They allow our Website to store
information about your browsing patterns, making our website more useful to
you. Many major sites use cookies: in fact, they are commonly used throughout
the Internet to offer personalized services. Most browsers are automatically
set to accept cookies. Each time you use our Website, the cookie is accessed.
This way, we can track the features you use and the pages and content that you
view on our website to help personalize your experience.
You may disable cookie support on your browser but be
aware that by doing so, you will lose certain features that require a cookie to
work properly. We may use the information collected by the cookie to provide us
with various statistics without identifying any individual.
Please contact us at technical@cryptocommonwealth.io
if you require information about disabling any cookies on our website.
Glossary
LAWFUL BASIS
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 contact 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 or regulatory
obligation
Means processing your personal data where it is
necessary for compliance with a legal or regulatory obligation that we are
subject to.