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Our Privacy Policy
Last updated 12 November 2024
This Privacy Policy is issued on behalf of Moonbug Entertainment Limited, company number 11197631 and data protection registration number ZA457059, with its registered office at 3
We take your privacy seriously and are committed to protecting personal data. This Privacy Policy sets out how we process your personal data when you access our App and subscribe to our gaming content.
1.Introduction
This Privacy Policy explains who we are, why and how we process personal data collected through your use of the App or otherwise through your interaction with us, what rights you have and how to get in touch with us. For ease of reference, we have divided this Privacy Policy into the following sections:
Introduction
Who do we collect personal information about?
How is your personal information collected?
How do we obtain your consent?
What information do we collect?
How and why do we use your personal information?
Why do we share your personal information and with whom?
How long do we keep your personal information for?
Security
International data transfers
Your rights
Processing Activities Schedule - Details of how we use your personal data, and why.
It is important that you read this Privacy Policy together with any other notices that we may provide on our App at or around the time that we collect or process personal data about you, including our App Terms and Conditions.
We will update this Privacy Policy from time to time to reflect changes to our business or changes in the law. When these changes involve our data collection practices, we will let you know by updating the notice. However, it is overall your responsibility to check this Privacy Policy regularly – for ease of reference, the top of this Privacy Policy indicates the date on which it was last updated.
2.Who do we collect personal information about?
App users
When you or your child interacts with our App, we will collect and process certain personal data from you. Using the App automatically generates some information, such as when and how you used the App. We may also collect data from third parties, for example from our third-party authentication platform, when you access the App via an account you have on another platform (e.g. Apple or Google) when you make a purchase within the App.
People who contact us
If you contact us with an enquiry, submit a complaint or provide any feedback (whether through the App or through another method), we will collect and process your personal data in connection with your interaction with us and our App.
3.Children
Our App is designed as a tool for parents and guardians, so you can go through the activities with your child or let them guide themselves. We collect data from parents and guardians in respect of their subscriptions.
We do not collect your child’s personal data. If we do collect your child’s personal data in the future, we will comply with all applicable laws and regulations. We will request the consent of a parent or guardian to process the personal data of your child in our App as
described in section 5.
As a parent or guardian, if you believe we have collected personal data about your child, you may contact us to review the data and request that we cease processing data about your child.
4.How is your personal information collected?
Direct interactions with you
When you use and interact with our App, you may provide us with certain personal data, such as when downloading the App, subscribing to gaming content, contacting us or reporting a problem with the App. When you do these things we may collect, store and use the personal data that you disclose to us, in accordance with this Privacy Policy.
Automated technologies or interactions
We collect certain Behavioural Data about you when you visit and interact with our App through the use of technologies such as SDKs (Software Development Kits).
Information we collect from other sources
From time to time we may also obtain personal data from other sources, for example:
third parties that provide technical services to us so that we can provide our App; and
third party platforms who fulfil your purchases of subscriptions on the App so that we can manage our subscription contract with you.
Where our use of your personal data requires consent, you can provide such consent at the time we collect the personal data, by selecting your preferred options based on the information presented.
6.What information do we collect?
What is personal data?
Where this Privacy Policy refers to ‘personal data’, it is referring to data about you from which you could be identified. The types of personal data we process from you may include:
Behavioural Data about your use of our App. This includes your interactions with our App, information about when your current or previous sessions started, information about links that you clicked and screens you viewed and interacted with on our App. We collect this information by using SDK technology. For more details about the third-party SDKs we use, please see our Cookies Policy.
Contact Data, such as your email address.
Account Data includes feedback you may provide on the App stores, and the content of any messaging you send us through our customer support team.
Purchase Data about your subscription. This includes the details of the transaction (e.g. what you purchased, the date of the transaction and the price). The exact data depends on the payment method you chose. Since our App’s subscription purchases are made via Apple and Google’s stores, we do not hold any details about your debit or credit card or other financial information.
We also collect, use and share Aggregated Data such as statistical or demographic data, solely for the purpose of improving our App’s services and functionalities. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data is anonymised and 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 App feature or functionality. 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 processed 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.
7.How and why do we use your personal information?
We use your personal data for the purposes set out in this section. If we wish to make any changes to these purposes, we will update this Privacy Policy.
We will only use your personal data for the purposes set out in this Privacy Policy and will comply with our obligations under applicable laws. Most commonly we will use personal data in the following circumstances:
where you have asked us to do so, or consented to us doing so;
where we need to do so in order to perform a contract we have entered into with you, such as providing you access with additional gaming content available via a subscription;
where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and
where we need to comply with a legal or regulatory obligation.
We use your personal data for the following purposes:
to personalise your experience (for example, by recording your child’s progress on the App);
to give you access to our gaming content and to enable you to purchase our subscriptions;
to answer any questions you may submit to us about our App or content, including responding to your feedback;
to carry out insight and analysis;
to comply with our legal obligations or in connection with the administration of our business.
For more information about our processing activities, including the personal data that is processed in connection with those activities, please see our Processing Activities Schedule.
8.Why do we share your personal information and with whom?
Depending on how and why you provide us with your personal data, we may need to share it with third parties, as set out in the list below. This list is non-exhaustive, and there may be circumstances where we need to share personal data with other third parties. We may share your personal data:
with any company within the Moonbug group of companies, for the purposes of managing and administering our business;
with selected third parties who we subcontract to provide various services and/or aspects of our App’s functionality and services. Their services to us may include processing operations, such as data hosting and maintenance, customer care, analytics, finance and accounting, legal support, payment processing, service improvement, data security and fighting against spam, abuse, fraud and other wrongdoings;
auditors, lawyers, and other professional advisers, who advise and assist us in relation to the lawful and effective management of our organisation, and in relation to any disputes we may become involved in;
law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation;
if we were to sell, transfer, buy or merge any parts of our business or assets, then personal data held by us about you may be one of the transferred assets and the new owners may use your personal data in the same way as set out in this Privacy Policy;
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in a criminal or legal investigation; and
in order to enforce or apply any of our App’s Terms and Conditions; or to protect the rights, property, or safety of our business, our customers, our staff or others. This includes exchanging information with other companies and organisations for the purposes of online safety, fraud protection and the protection of our intellectual property where appropriate.
Service Providers
Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide our service providers with the minimum amount of personal data they need to fulfil the services we request, and we endeavour to ensure that they protect this data and do not use it for any other purpose. We take these relationships seriously and aim to ensure that all of our service providers who process personal data on our behalf act on our written instructions, setting out their commitment to comply with applicable data protection laws and to assist us with our duties in respect of your exercise of your applicable data subject rights.
9.How long do we keep your personal information for?
We will hold your personal information on our systems only for as long as required to fulfil the purposes we collected it for, including to provide you with the services you have requested and 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. In some circumstances you can ask us to delete your personal data: see ‘Your rights’ below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you for research, demographic, analytical or statistical purposes), in which case we may use this information indefinitely without further notice to you.
10.Security
Moonbug takes the protection of personal data seriously. We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including use of secure servers.
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 in accordance with our instructions and they are subject to a duty of confidentiality.
Despite these precautions, and although we will do our best to protect your personal data, Moonbug cannot guarantee the security of information transmitted over the internet or that unauthorised persons will not obtain access to personal data. In the event of an actual or suspected data breach, we have put in place procedures to deal with this and will notify you and any applicable regulator of a breach where required to do so.
11.International data transfers
Please note that as your personal data is shared within the Moonbug group of companies, this will involve transferring it outside of the United Kingdom (UK) or European Economic Area (EEA), including exchanging data between the UK, EEA, the USA and other countries. Some of our external service providers may be also based outside of the UK or EEA. These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfilment of your request for information, customer support and the provision of services.
Where we transfer your data to a service provider that is outside of the UK or EEA (as relevant), we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld. Transfers of personal data are made:
to a country recognised by the appropriate body as providing an adequate level of protection; or
if to a country which does not offer adequate protection, these transfers have been governed by approved standard data protection clauses or by implementing other appropriate safeguards to provide adequate protection.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside of the UK or EEA.
12.Your rights
As a data subject, you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them. These rights can be exercised at any time by contacting us – see the “Contact us” section below.
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:
(i) if your request is clearly unfounded, repetitive or excessive; or
(ii) if your request requires us to deliver any data under a ‘non-standard’ format for which we may charge any third-party costs we incur as a result of fulfilling your request. 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 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.
Your right to request access
If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). You may have heard of this right being described as a "subject access request". If you require additional copies, we may charge a reasonable fee for producing those additional copies.
Please note that this right entitles you to receive a copy of the personal data that we hold about you. It is not a right to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
Your right to rectification and erasure
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).
Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is correct. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to the request.
Your right to restrict processing
Where we process your personal data on the basis of a legitimate interest, you are entitled to ask us to stop processing it if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.
You may also ask us to stop processing your personal data: (a) if you dispute the accuracy of that personal data and want us to verify that data's accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; and/or (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.
Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will explain that reason, either at the time we first respond to the request or after we have had the opportunity to consider and investigate it.
Your right to portability
Under certain circumstances, where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party, you may write to us and ask us to provide it to you in a 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.
Your right to object to processing
You may object to processing of your personal data where we rely on legitimate interest (or those of a third party) for processing that personal data 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. We will comply with your request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.
Your right to withdraw consent
Where our processing of your data is on the basis of your consent, you can withdraw this consent at any time. This would not affect the lawfulness of the processing based on consent prior to the withdrawal. If you withdraw your consent, we may not be able to provide certain content or services to you. We will advise you if this is the case at the time you withdraw your consent.
Your rights in relation to automated decision-making and profiling
You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
Your right to lodge a complaint to the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the “Contact Us” section below. You can also report any issues or concerns to a regulatory or supervisory authority in the state of your residence or the place of the alleged infringement.
As we are incorporated in the United Kingdom, our regulatory authority is the Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website here.
You can find a list of contact details for all EU supervisory authorities here.
Right to Opt Out of Sale of Personal Data (California users)
A consumer (as defined in the California Consumer Privacy Act 2018 (or “CCPA”)) has the right to request disclosure of personal data about them sold by the party that sold it and the right to opt out of the sale of that consumer’s personal data by contacting the party that sold or intended to sell it.
Shine the Light (California users)
California law provides that you have the right to submit a request to us at our designated email address set out in the “Contact Us” section below and receive the following information: (i) the categories of information disclosed to third parties for the third parties' direct marketing purposes during the immediately preceding calendar year; and (ii) the names and addresses of third parties that received such information or, if the nature of their business cannot reasonably be determined from the name, then examples of the products or services marketed. Please put “Shine the Light Request” in the subject line of your email.
Exercising your rights
When you write to us making a request to exercise your rights, we may ask for copies of relevant ID documents to help us to verify your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
It will help us to process your request if you clearly state which right you wish to exercise, what personal data it is that is of particular concern to you and, where relevant, why it is that you are exercising it. The clearer and more specific the request, the faster and more efficiently we can deal with that request. If insufficient information is provided, then there may be a delay in actioning the request until additional information is provided (and we will tell you where this is the case).
Please note that all the rights mentioned in this section are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply. For example, we may refuse to comply with a request if it is manifestly unfounded or excessive.
We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this Privacy Policy. If you have any queries regarding this Privacy Policy and/or if you wish to exercise any of your rights as set out above, please contact us by emailing privacy@moonbug.com and marking it for the attention of our Data Protection Officer. Our postal address is 3
Whilst we would prefer that you direct any complaints or queries you have to us first, you may also lodge a complaint to the supervisory authority applicable in your country about the way we process your personal data. In the UK, this is the Information Commissioner's Office (“ICO”). The ICO is our designated data controller.
Details of how we use your personal data, and why
1.Using the Moonbug App
Our lawful basis
We process your personal data in this way in order to perform our contract with you. It is also in our legitimate interest to use personal data in these ways, to ensure that you have the best possible experience on our App.
If you purchase a subscription
What personal data do we collect?
Behaviour Data, Contact Data, Account Data, and Purchase Data.
How and why do we use the personal data?
Although you can use some parts of the App for free you will need a subscription to get full access to all of the games and activities in the App.
If you purchase a subscription, we use this data to enable you to access the benefit of the subscriptions that you can purchase via Apple and Google, including managing your access to subscribed in-App games across devices (so that you can enjoy the app across devices, provided you are logged in under the same Google or Apple ID credentials used to purchase the initial subscription).
Our lawful basis
It is necessary for us to use your personal data in order to perform our obligations in accordance with the contract we have with you for your subscription, and it is in our legitimate interests to use the personal data to ensure that we make the additional features (which are available to those holding a subscription) available to you in an effective and efficient way.
2.Customer service enquiries and feedback
If you need help with any issue concerning our App or our content.
What personal data we collect
Contact Data and, if applicable, Account Data and Purchase Data, as well as any other personal data you volunteer that is relevant to your enquiry.
How and why do we use the personal data?
When you contact us, you provide us with information that may be necessary to help address your enquiry or respond to your review.
If you have a complaint or technical issue concerning our App, we may collect and process a range of personal data to help us diagnose any technical or other account issues you are experiencing and to help us resolve them in an efficient way. We use this information to manage and respond to your enquiry.
Our lawful basis
We will process the personal data submitted to our customer support team for the purpose of performing any contract we may have with you. It is also in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry, provide a good standard of service and improve our customer services and App.
Where we permit a third party to use your personal data contained within content that you submit, we will do so without your permission if we are satisfied that it is within our or the third party’s legitimate interest to use your personal data. If it is not within our legitimate interest, we will contact you to ask your permission, in which case our processing of such personal data will be based on your consent.
If you have a general enquiry or provide feedback on your experience of our App and/or content.
What personal data we collect
Contact Data and, if applicable, Account Data, as well as any other personal data you choose to volunteer in your survey response or other feedback.
How and why do we use the personal data?
From time to time, we will invite you to provide feedback about us, our App and our content in the form of online surveys.
We will also collect and process your personal data to help us to monitor and improve our App and our content, to assist with the selection of future product and content lines, and to train our personnel.
If you submit any feedback to us, including via our App, such as quotes or testimonials, we may process any personal data contained within that content for the purposes of making available particular content and services via our App and promoting our App and our content.
We may also allow third parties to use the content that you contribute, or the content that you provide. If the use of such content would involve the use of your personal data, we may use your Contact Data to ask your permission to use the relevant content, unless we are satisfied that we have a lawful right to use the content without your permission.
Our lawful basis
It is in our legitimate interest to use the personal data provided by you so that we can improve our App and our content and provide them in an effective way.
3.Insight and Analysis.
When we analyse your use of and interaction with our App.
What personal data we collect
Behavioural Data and Cookies.
How and why do we use the personal data?
We and our third-party partners use this data to analyse how you use and interact with our App, and the effectiveness of our App, including:
to gain general insights about our App visitors and audience, including to measure the effectiveness of our App, and counting users who have visited our App or purchased a subscription;
to learn what parts of our App are most popular and what kind of features and functionalities our users like to see;
to help us with the development of future content; and
to provide a personalised experience to our App visitors and audience.
Our lawful basis
Where your data is collected through the use of non-essential cookies, we rely on consent to collect your personal data and for the onward processing purpose. Please see our Cookie Policy for further details.
4.Business administration and legal compliance
If we need to use your personal data to comply with our legal obligations or in connection with the administration of our business.
What personal data we collect
Contact Data, Account Data as well as any other personal data you may volunteer or we may request from you in the circumstances.
How and why do we use the personal data?
We may use your personal data: (i) to comply with our legal obligations; (ii) to enforce our legal rights; (iii) to protect the rights of third parties; and (iv) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.
Our lawful basis
Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us, such as a court order.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.