Website Privacy Policy




Welcome to Hatch House Games Limited’s privacy policy.

Hatch House Games Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (except for visitors from the USA, to whom a separate policy applies) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.


1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Hatch House Games Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you:

  • purchase or download our products;
  • use our services;
  • create an account on our website;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 personal data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Hatch House Games Limited (referred to as we, us and our in this privacy policy) is the controller and responsible for your personal data. We are a company incorporated and registered in England and Wales under number 12625063.

Contact details

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights , please contact the data privacy manager using the details set out below.

  • Email address: privacy@mrswordsmith.com ;
  • Postal address: Hatch House Farm, West Woodhay, Newbury, Berkshire, RG20 0BH.

You have the right to make a complaint at any time to:

  • the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection issues (www.ico.org.uk);
  • a competent supervisory authority of an EU member state if you are located in the EU.
We would, however, appreciate the chance to deal with your concerns before you approach the ICO or another supervisory authority so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 23 July 2021

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.

Third party links

This website may include links to third party websites. Clicking on those links 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 policy of every website you visit.


2. The data 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 (i.e. anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Contact Data includes billing address, delivery address, email address and telephone number(s);
  • Identity Data includes first name and last name;
  • Marketing and Communications Data includes your preferences in receiving marketing from us.
  • Profile Data includes:
    • your email address and password;
    • purchases/orders placed by you or downloads from our website;
    • your interests, preferences, feedback, reviews and survey responses;
  • Technical Data includes:
    • internet protocol (‘IP’) address;
    • your login data;
    • your browser type and version;
    • your time zone setting and location;
    • your browser plug-in types and versions;
    • your operating system and platform; and
    • other technology on the devices you use to access our website;
    • unique user IDs that we ascribe to you;
  • Transaction Data includes details about:
    • payments to and from you;
    • deliveries to you and any returns;
    • details of products you have purchased/ordered or downloaded from us;
  • Usage Data includes information about how you:
    • use our website and products and services;
    • respond to direct marketing that we send to you.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

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 products/services). In this case, we may have to cancel the provision of the products/services but we will notify you if this is the case at the time.


3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • direct interactions.You may give us your Identity, Contact and Transaction Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • purchase or download our products;
    • create an account on our website;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us feedback or contact us.
  • automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details;
  • third parties. We will receive personal data about you from various third parties as set out below:
    • Technical Data from:
      • analytics providers;
      • advertising networks; and.
      • search information providers.
    • Transaction Data from payment processing and delivery service providers:
      • H. Charlesworth & Co Limited (where you are located in the United Kingdom);
      • PayPal (Europe) S.à r.l. et Cie, S.C.A.;
      • Shopify International Limited;
      • Stripe Payments Europe, Limited;
      • National Products Fulfilment Pty Limited (where you are located in Australia).

Cookies

For more information about the cookies we use, please see cookie policy.


4. How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

  • where we need to perform a 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.

Click ‘lawful basis’ to find out more about the types of lawful basis that we will rely on to process your personal data.

Purposes for which we will 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 personal 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.

Purpose / Activity Type(s) of Data Lawful Basis for Processing, Including Basis of Legitimate Interest
To register you with a customer account on our website.
  • Contact
  • Identity
  • Profile
Performance of a contract with you.
To process and (where applicable) deliver your orders, including managing payments, fees and charges. For delivery and returns, we will share your personal data with our delivery providers. For payments, we will share your personal data with one of our payment providers.
  • Contact
  • Identity
  • Transaction
Performance of a contract with you.
Recovering money owed to us.
  • Contact
  • Identity
  • Transaction
Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship with you, which will include:
  • notifying you about changes to our terms or privacy policy;
  • asking you to leave a review or take a survey.
  • Contact
  • Identity
  • Marketing and Communications
  • Profile
  • Usage
  • Performance of a contract with you.
  • Necessary to comply with a legal obligation.
  • Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To enable you to partake in a prize draw, competition or complete a survey.
  • Contact
  • Identity
  • Marketing and Communications
  • Profile
  • Usage
  • Performance of a contract with you.
  • Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
To administer and protect our business and our website, including:
  • troubleshooting;
  • data analysis;
  • testing;
  • system maintenance;
  • support;
  • reporting; and
  • hosting of data.
  • Contact
  • Identity
  • Technical
  • Usage
  • 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 reorganisation or group restructuring exercise).
  • Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and to measure and understand the effectiveness of the advertising we serve to you.
  • Contact
  • Identity
  • Marketing and Communications
  • Profile
  • Technical
  • Transaction
  • Usage
Necessary for our legitimate interests (to study how customers use our products and services, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our:
  • website;
  • products and services;
  • marketing;
  • customer relationships and experiences.
  • Technical
  • Usage
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 form a view on what products and services you may want, need or be of interest to you and to make suggestions and recommendations (via our website) to you about products and services that may be of interest to you.
  • Contact
  • Identity
  • Marketing and Communications
  • Profile
  • Technical
  • Usage
Necessary for our legitimate interests (to develop our products and services and to grow our business).
To send you suggestions and recommendations about products and services that may be of interest to you (i.e. marketing).
  • Contact
  • Identity
  • Marketing and Communications
Consent.
To create aggregate data.
  • Profile
  • Technical
  • Transaction
  • Usage
Necessary for our legitimate interests (to understand users of the website – e.g. which demographics purchase which products, where they are located etc.).

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.

Marketing

You will only receive marketing messages from us if you have requested these from us.

You can ask us to stop sending you marketing messages by:

  • following the opt-out links on any marketing message sent to you; or
  • contacting us at any time.

However, where you opt out of receiving these marketing messages, we may still continue to process your personal data for other purposes.

We will not share your personal data with third parties for marketing purposes.


5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • External Third Parties as set out in the Glossary;
  • Third parties to whom we 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 policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers (where they are acting as our processors) to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


6. International transfers

Whenever we transfer your personal data out of the UK (including where the source of that data is the USA), we must have a lawful basis on which to do so. For those third parties outside the UK to whom we transfer your personal data (listed in the External Third Parties), we ensure a similar degree of protection is afforded to it by:

  • transferring to countries that have been deemed to provide an adequate level of protection for personal data (an ‘adequacy decision’); or
  • where there has been no adequacy decision, using a standard contract that has been approved for use in the UK and which ensures personal data has the same protection as it has in the UK.
Please contact us if you want further information (including a copy of the standard contract, where applicable) on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used/accessed in an unauthorised 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.


8. Data retention

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. Otherwise, we will erase your personal data promptly once it has been (so far as we are able to establish) over 12 months since you last visited our website.


9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

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 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.


10. Glossary

LAWFUL BASIS

  • Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want.
  • Legitimate interest means processing your personal data to pursue a particular legitimate interest (whether ours or those of third parties). 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 personal 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.
  • Complying 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

  • Payment processing providers (acting as controllers):
    • Amazon Payments UK Limited (incorporated and registered in England and Wales with company number 11049457 and whose registered office is at 1 Principal Place, Worship Street, London, EC2A 2FA);
    • PayPal (Europe) S.à r.l. et Cie, S.C.A. (incorporated and registered in Luxembourg with company number B118349 and whose registered office is at 22-24, Boulevard Royal, L – 2449);
    • Shopify International Limited (incorporated and registered in the Republic of Ireland with company number 560279 and whose registered office is at 2nd Floor, 1-2 Victoria Buildings, Haddington Road, Dublin 4, DO4 XN32);
    • Stripe Payments Europe, Limited (incorporated and registered in the Republic of Ireland with company number 513174 and whose registered office is at c/o A & L Goodbody, IFSC, North Wall Quay, Dublin 1, Dublin).
  • Delivery service providers (acting as controllers):
    • H. Charlesworth & Co Limited (incorporated and registered in England and Wales with company number 01143652 and whose registered office is at Flanshaw Way, Flanshaw Lane, Wakefield, West Yorkshire, WF2 9LP);
    • National Products Fulfilment Pty Limited (incorporated and registered in Australia with company number 100 588 289 and whose registered office is at 6 Ross Place, Wetherill Park, NSW 2164).
  • Service providers (acting as processors):
    • Adore Digital Media Limited (incorporated and registered in England and Wales with company number 09639541 and whose registered office is at Unit 3f, Aston Business Park, Shrewsbury Avenue, Peterborough, Cambridgeshire, PE2 7EY), a provider of search engine optimisation services;
    • Amazon Web Services EMEA SARL (incorporated and registered in Luxembourg with company number B186284 and whose registered office is at 38, Avenue John F. Kennedy, L - 1855), a provider of cloud computing and storage services;
    • Appsflyer UK Ltd (incorporated and registered in England and Wales with company number 10246990 and whose registered office is at 5th Floor Merck House, Seldown Lane, Poole, BH15 1TW), a provider of data analytics services;
    • Google UK Limited (incorporated and registered in England and Wales with company number 03977902 and whose registered office is at Belgrave House, 76 Buckingham Palace Road, London, SW1W 9TQ), a provider of data analytics services.

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 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 personal 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;

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