Under data protection laws, we are required toprovide you with certain information about who we are, how we process yourpersonal data and for what purposes, and your rights in relation to yourpersonal data. This information is provided in [LINK TO POLICY] and it isimportant that you read that information.
Before installation of this App, please indicateyour consent to our processing of your personal data (including your name,contact details, financial and device information) as described in the policy[LINK TO PDF OF POLICY].
YES I consent to the installation of the App for thepurposes of [PURPOSE OF APP].
NO I do not consent to the installation of the App.
How you can withdraw consent
Once you provide consent by selecting"YES", you may change your mind and withdraw consent at any time bycontacting us [CONTACT DETAILS] but that will not affect the lawfulness of anyprocessing carried out before you withdraw your consent.
[Consent to processing Location Data
YES I consent to processing of my Location Data([including details of my current location disclosed by [GPS technology OR [OTHER TECHNOLOGY]] so thatlocation-enabled Services are activated [to [PURPOSE OF LOCATION-ENABLEDSERVICES]]).
NO I do not consent to processing of my Location Dataand location-enabled Services are disabled in my settings.]
Livingart London LTD (we) are committed to protecting your personal data andrespecting your privacy.
This policy (together with our end-user licence agreement as set out at [WEB ADDRESS OF EULA] (EULA) and any additional terms of useincorporated by reference into the EULA, together our Termsof Use) applies to your use of:
· Metalove app (which was last updated on [DATE]) mobile application software (App) [available on our site] OR hosted on metalovegame.one (App Site), once you have downloaded or streamed a copy of the App onto your mobiletelephone or handheld device (Device).
· Any of the services accessiblethrough the App (Services) that are available on theApp Site or other sites of ours (Services Sites) [,unless the EULA states that a separate privacy policy applies to a particularService, in which case that privacy policy only applies]. This policy sets outthe basis on which any personal data we collect from you, or that you provideto us, will be processed by us. This App is not intended for children and we donot knowingly collect data relating to children. Please read the followingcarefully to understand our practices regarding your personal data and how wewill treat it.
This policy isprovided in a layered format so you can click through to the specific areas setout below. [Alternatively, you can download a pdf version of the policy here:[LINK].]
[IMPORTANT INFORMATION AND WHO WE ARE]
[THE DATA WE COLLECT ABOUT YOU]
[HOW IS YOUR PERSONAL DATA COLLECTED?]
[HOW WE USE YOUR PERSONAL DATA]
[DISCLOSURES OF YOUR PERSONAL DATA]
[INTERNATIONAL TRANSFERS]
[DATA SECURITY]
[DATA RETENTION]
[YOUR LEGAL RIGHTS]
[GLOSSARY]
[DESCRIPTION OF CATEGORIES OF PERSONAL DATA]
[IF ONLY ONEENTITY:] [LEGAL ENTITY NAME] is the controller and is responsible for yourpersonal data (collectively referred to as ["Company"],"we", "us" or "our" in this policy).
[IF SEVERALENTITIES PART OF A GROUP:] [COMPANY NAME] is made up of different legalentities, details of which can be found here [LINK]. When we mention"[COMPANY NAME]", we are referring to the relevant company in the[COMPANY NAME] Group responsible for processing your data which will be clearto you when you use our App. [LEGAL ENTITY NAME] is the controller responsiblefor this App.
[We have appointeda [data protection officer (DPO) OR data privacy manager]. If you haveany questions about this privacy policy, please contact them using the detailsset out below.]
Contact details
Our full detailsare:
· Full name of legal entity:[DETAILS]
· Name or title of [DPO OR data privacy manager]: [DETAILS]
· Email address: [DETAILS]
· Postal address: [DETAILS]
· [Telephone number: [DETAILS]]
You have the rightto make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues.
Changes to the privacy policy and your duty to informus of changes
We keep ourprivacy policy under regular review.
This version waslast updated on [DATE]. It may change and if it does, these changes will beposted on this page and, where appropriate, notified to you [by SMS OR by email OR when you next start the App or log onto one of the ServicesSites]. The new policy may be displayed on-screen and you may be required toread and accept the changes to continue your use of the App or the Services.
It is importantthat the personal data we hold about you is accurate and current. Please keepus informed if your personal data changes during our relationship with you.
Third party links
Our Sites may,from time to time, contain links to and from the websites of our partnernetworks, advertisers and affiliates. Please note that these websites and anyservices that may be accessible through them have their own privacy policiesand that we do not accept any responsibility or liability for these policies orfor any personal data that may be collected through these websites or services,such as Contact and Location Data. Please check these policies beforeyou submit any personal data to these websites or use these services.
We may collect,use, store and transfer different kinds of personal data about you as follows:
· Identity Data.
· Contact Data.
· Financial Data.
· Transaction Data.
· Device Data.
· Content Data.
· Profile Data.
· Usage Data.
· Marketing and CommunicationsData.
· Location Data
We explain thesecategories of data here [LINK TO DESCRIPTION OF CATEGORIES OF PERSONAL DATABELOW].
[We also collect,use and share Aggregated Data such as statistical or demographic data for anypurpose. Aggregated Data could be derived from your personal data but is notconsidered personal data in law as this data will not directly or indirectlyreveal your identity. For example, we may aggregate your Usage Data tocalculate the percentage of users accessing a specific App feature. However, ifwe combine or connect Aggregated Data with your personal data so that it candirectly or indirectly identify you, we treat the combined data as personaldata which will be used in accordance with this privacy policy.]
We do not collectany Special Categories of Personal Data about you (this includes details aboutyour race or ethnicity, religious or philosophical beliefs, sex life, sexualorientation, political opinions, trade union membership, information about yourhealth, and genetic and biometric data). Nor do we collect any informationabout criminal convictions and offences.
We will collectand process the following data about you:
· Information you give us. This isinformation (including Identity, Contact, Financial, and Marketing andCommunications Data) you consent to giving us about you by filling in forms onthe App Site and the Services Sites (together Our Sites),or by corresponding with us (for example, by email or chat). It includesinformation you provide when you register to use the App Site, download orregister an App, subscribe to any of our Services, search for an App orService, [make an in-App purchase,] [share data via an App's social media functions,][enter a competition, promotion or survey,] [or] [OTHER ACTIVITIES COMMONLYCARRIED OUT IN CONNECTION WITH AN APP] and when you report a problem with anApp, our Services, or any of Our Sites. If you contact us, we will keep arecord of that correspondence.
· Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we willautomatically collect personal data including Device, Content and Usage Data.We collect this data using cookies and other similar technologies. Please seeour cookie policy [LINK] for further details.
· [Location Data. We also use [GPStechnology OR [OTHER TECHNOLOGY]] todetermine your current location. Some of our location-enabled Services requireyour personal data for the feature to work. If you wish to use the particularfeature, you will be asked to consent to your data being used for this purpose.You can withdraw your consent at any time by [disabling Location Data in yoursettings OR [OTHER WAY IN WHICHCONSENT CAN BE WITHDRAWN]].]
· Information we receive from other sources including third partiesand publicly available sources. We will receivepersonal data about you from various third parties [and public sources] as setout below [DELETE OR ADD TO THIS LIST AS APPROPRIATE]:
· Device Data from the followingparties:
analytics providers [such as Googlebased outside the UK];
advertising networks [such as[NAME] based [inside OR outside] theUK]; and
search information providers [suchas [NAME] based [inside OR outside]the UK].
· Contact, Financial andTransaction Data from providers of technical, payment and delivery services[such as [NAME] based [inside ORoutside] the UK];
· Identity and Contact Data fromdata brokers or aggregators [such as [NAME] based [inside OR outside] the UK];
· Identity and Contact Data frompublicly available sources [such as Companies House and the electoral registerbased inside the UK]; and
· [ANY OTHER WAYS YOU COLLECTPERSONAL DATA].
· [Unique application numbers. When you want to install or uninstall aService containing a unique application number or when such a Service searchesfor automatic updates, that number and information about your installation, forexample, the type of operating system, may be sent to us.]
We use cookies[and/or other tracking technologies] to distinguish you from other users of theApp, App Site, the distribution platform (Appstore) or Services Sites and toremember your preferences. This helps us to provide you with a good experiencewhen you use the App or browse any of Our Sites and also allows us to improvethe App and Our Sites. For detailed information on the cookies we use, thepurposes for which we use them and how you can exercise your choices regardingour use of your cookies, see our cookie policy [LINK].
We will only useyour personal data when the law allows us to do so. Most commonly we will useyour personal data in the following circumstances:
· Where you have consented beforethe processing.
· Where we need to perform acontract we are about to enter or have entered with you.
· Where it is necessary for ourlegitimate interests (or those of a third party) and your interests andfundamental rights do not override those interests.
· Where we need to comply with alegal or regulatory obligation.
Click here [LINK TO GLOSSARY: LAWFUL BASIS] to findout more about the types of lawful basis that we will rely on to process yourpersonal data.
We will only sendyou direct marketing communications by email or text if we have your consent.You have the right to withdraw that consent at any time by contacting us.
[We will get yourexpress opt-in consent before we share your personal data with any third partyfor marketing purposes.]
Purpose/activity
Type of data
Lawful basis for processing
To install the App and register you as a new App user
Identity
Contact
Financial
Device
Your consent
To process in-App purchases and deliver Services including managing payments and collecting money owed to us
Identity
Contact
Financial
Transaction
Device
Marketing and Communications
Location
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you including notifying you of changes to the App or any Services
Identity
Contact
Financial
Profile
Marketing and Communications
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition or complete a survey
Identity
Contact
Device
Profile
Marketing and Communications
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)
To administer and protect our business and this App including troubleshooting, data analysis and system testing
Identity
Contact
Device
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you
To make recommendations to you about goods or services which may interest you
To measure and analyse the effectiveness of the advertising we serve you
To monitor trends so we can improve the App
Identity
Contact
Device
Content
Profile
Usage
Marketing and Communications
Location
Consent
Necessary for our legitimate interests (to develop our products/Services and grow our business)
When you consentto providing us with your personal data, we will also ask you for your consentto share your personal data with the third parties set out below for thepurposes set out in the table [Purposesfor which we will use your personal data]:
· Internal Third Parties as setout in the [Glossary].
· External Third Parties as setout in the [Glossary].
· [Specific third parties [listedin the table [Purposes for which we willuse your personal data] above ORsuch as [SPECIFIC THIRD PARTIES]].]
· Third parties to whom we maychoose 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 achange happens to our business, then the new owners may use your personal datain the same way as set out in this privacy policy.
· [DETAILS OF ANY OTHER THIRDPARTY DISCLOSURES.]
[IF NO TRANSFERSOUT OF UK OCCUR:] [We do not transfer your personal data outside the UK.
OR
[IF BINDINGCORPORATE RULES ARE USED:] We ensure your personal data is protected byrequiring all our group companies to follow the same rules when processing yourpersonal data. These rules are called "binding corporate rules". Forfurther details, see [LINK TO APP OWNER'S BINDING CORPORATE RULES].
[Many of ourexternal third parties are based outside the UK so their processing of yourpersonal data will involve a transfer of data outside the UK.]
Whenever wetransfer your personal data out of the UK, we ensure a similar degree ofprotection is afforded to it by ensuring at least one of the followingsafeguards is implemented:
· [We will only transfer yourpersonal data to countries that have been deemed to provide an adequate levelof protection for personal data. For further details, see [ ].]
· [Where we use certain serviceproviders, we may use specific contracts approved by the UK which give personaldata the same protection it has in the UK. For further details, see [ ].]
Please contact usif you want further information on the specific mechanism used by us whentransferring your personal data out of the UK.]
All informationyou provide to us is stored on our secure servers. Any payment transactions[carried out by us or our chosen third-party provider of payment processingservices] will be encrypted using [Secured Sockets Layer technology OR [ALTERNATIVE ENCRYPTIONTECHNOLOGY]]. Where we have given you (or where you have chosen) a passwordthat enables you to access certain parts of Our Sites, you are responsible forkeeping this password confidential. We ask you not to share a password withanyone.
Once we havereceived your information, we will use strict procedures and security featuresto try to prevent your personal data from being accidentally lost, used oraccessed in an unauthorised way. [DETAILS OF PROCEDURES AND FEATURES.]
[We will collectand store personal data on your Device using [application data caches andbrowser web storage (including HTML5) OR[ALTERNATIVE MECHANISMS]] and other technology.]
[Certain Servicesinclude social networking, chat room or forum features. Ensure when using thesefeatures that you do not submit any personal data that you do not want to beseen, collected or used by other users.]
We have put inplace procedures to deal with any suspected personal data breach and willnotify you and any applicable regulator when we are legally required to do so.
[Details ofretention periods for different aspects of your personal data are [available inour retention policy which you can request by contacting us].]
[By law we have tokeep basic information about our customers (including Contact, Identity,Financial and Transaction Data) for [six] years after they cease beingcustomers for [tax] purposes.]
In somecircumstances you can ask us to delete your data: see [Your legal rights] below for further information.
In somecircumstances we will anonymise your personal data (so that it can no longer beassociated with you) for research or statistical purposes, in which case we mayuse this information indefinitely without further notice to you.
In the event thatyou do not use the App for a period of [TIME PERIOD] then we will treat theaccount as expired and your personal data may be deleted.
Under certaincircumstances you have the following rights under data protection laws inrelation to your personal data.
Please click onthe links below to find out more about these rights:
· [Request access to your personal data.]
· [Request correction of your personal data.]
· [Request erasure of your personal data.]
· [Object to processing of your personal data.]
· [Request restriction of processing your personal data.]
· [Request transfer or your personal data.]
· [Right to withdraw consent.]
You also have theright to ask us not to continue to process your personal data for marketingpurposes.
You can exerciseany of these rights at any time by contacting us at [[ADDRESS] OR [EMAIL ADDRESS]].
Consent means processing yourpersonal data where you have signified your agreement by a statement or clearopt-in to processing for a specific purpose. Consent will only be valid if itis a freely given, specific, informed and unambiguous indication of what youwant. You can withdraw your consent at any time by contacting us.
Legitimate Interest means theinterest of our business in conducting and managing our business to enable usto give you the best service/product and the best and most secure experience.We make sure we consider and balance any potential impact on you (both positiveand negative) and your rights before we process your personal data for ourlegitimate interests. We do not use your personal data for activities where ourinterests are overridden by the impact on you (unless we have your consent orare otherwise required or permitted to by law). You can obtain furtherinformation about how we assess our legitimate interests against any potentialimpact on you in respect of specific activities by contacting us.
Performance of Contract meansprocessing your data where it is necessary for the performance of a contract towhich you are a party or to take steps at your request before entering intosuch a contract.
Comply with a legal obligation meansprocessing your personal data where it is necessary for compliance with a legalobligation that we are subject to.
Othercompanies in the [COMPANY] Group [acting as joint controllers or processors]and who are based in [SPECIFIC COUNTRIES] and provide [IT and systemadministration services and undertake leadership reporting].
Serviceproviders [acting as processors] based in [SPECIFIC COUNTRIES] who provide [ITand system administration services].
Professionaladvisers [acting as processors or joint controllers] including lawyers,bankers, auditors and insurers based in [SPECIFIC COUNTRIES] who provide[consultancy, banking, legal, insurance and accounting services].
HM Revenue andCustoms, regulators and other authorities [acting as processors or jointcontrollers] based [in the UK] [who require reporting of processing activitiesin certain circumstances].
[DETAILS OFANY OTHER THIRD PARTIES, FOR EXAMPLE, MARKET RESEARCHERS, FRAUD PREVENTIONAGENCIES, PRICE COMPARISON SITES AND SO ON.]
You have theright to:
· Request access to your personal data(commonly known as a "data subject access request"). This enables youto receive a copy of the personal data we hold about you and to check that weare lawfully processing it.
· Request correction of the personal datathat we hold about you. This enables you to have any incomplete or inaccuratedata we hold about you corrected, though we may need to verify the accuracy ofthe 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 nogood reason for us continuing to process it. You also have the right to ask usto delete or remove your personal data where you have successfully exercisedyour right to object to processing (see below), where we may have processedyour information unlawfully or where we are required to erase your personaldata to comply with local law. Note, however, that we may not always be able tocomply with your request of erasure for specific legal reasons which will benotified to you, if applicable, at the time of your request.
· Object to processing of your personaldata 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 toobject to processing on this ground as you feel it impacts on your fundamentalrights and freedoms. You also have the right to object where we are processingyour personal data for direct marketing purposes. In some cases, we maydemonstrate that we have compelling legitimate grounds to process yourinformation which override your rights and freedoms.
· Request restriction of processing ofyour personal data. This enables you to ask us to suspend the processing ofyour 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 toerase it;
· Request the transfer of your personaldata to you or to a third party. We will provide to you, or a third party youhave chosen, your personal data in a structured, commonly used,machine-readable format. Note that this right only applies to automatedinformation which you initially provided consent for us to use or where we usedthe information to perform a contract with you.
· Withdraw consent at any time where weare relying on consent to process your personal data. However, this will notaffect the lawfulness of any processing carried out before you withdraw yourconsent. If you withdraw your consent, we may not be able to provide certainproducts or services to you. We will advise you if this is the case at the timeyou withdraw your consent.
Description of categories of personal data
· Identity Data: [first name, last name,maiden name, username or similar identifier, marital status, title, date ofbirth, gender].
· Contact Data: [billing address, deliveryaddress, email address and telephone numbers].
· Financial Data: [bank account andpayment card details].
· Transaction Data: includes [detailsabout payments to and from you and details of in-App purchases].
· Device Data: includes [the type ofmobile device you use,] [a unique device identifier [(for example, yourDevice's IMEI number, the MAC address of the Device's wireless networkinterface, or the mobile phone number used by the Device)],] [mobile networkinformation,] [your mobile operating system,] [the type of mobile browser youuse,] [time zone setting,] [OTHER INFORMATION].
· Content Data: includes informationstored on your Device, including [friends' lists,] [login information,][photos, videos or other digital content,] [check-ins,] [OTHER INFORMATION].
· Profile Data: includes [your usernameand password, in-App purchase history, your interests, preferences, feedbackand survey responses].
· Usage Data: includes details of your useof any of our Apps or your visits to any of Our Sites including, but notlimited to, [traffic data [and other communication data],] whether this isrequired for our own billing purposes or otherwise [and the resources that youaccess].
· Marketing and Communications Data:includes [your preferences in receiving marketing from us and our third partiesand your communication preferences].
· Location Data: includes [your currentlocation disclosed by [GPS technology OR[OTHER TECHNOLOGY]].