Privacy Policy

SIDEQUEST META LTD

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Introduction

Welcome to SideQuest’s Privacy Policy.

SideQuest respects your privacy and is committed to protecting your personal information (sometimes referred to as personal data) in accordance with applicable data protection laws. This Privacy Policy informs you how we collect, use, share and look after your personal data and tells you about your privacy rights and how the law protects you.

This Privacy Policy applies to personal information collected through our [Gamers Hub], website and online services. The games and the features, functions, information, software and services offered through our [Gamers Hub], website and other online services are referred to in this Policy as our “Service”.

If you are an employee, job candidate or consultant working for SideQuest, please refer to our Staff Privacy Policy (available from our HR department) for details of how your personal data is held and used by SideQuest.

SIDEQUEST META LTD is the controller of the personal information collected through our Service. Our contact details are set out later in this Privacy Policy.

We reserve the right to change the provisions of this Policy from time to time. We encourage you to periodically review this document for the latest information on our privacy practices.

IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how SideQuest collects and processes your personal data through your use of our Service, including any data you may provide through this website when you log in to our gaming platform, sign up to our newsletter or other marketing emails, use our website or take part in a survey or competition.

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 data. This Privacy Policy is in addition to other notices and privacy policies and is not intended to override them.

What is personal data?

The term “personal data” means information that specifically identifies an individual (such as a name, address, telephone number, mobile number, email address, or other account number), and also information about that individual’s location or activities, such as information about their use of the Service, login preferences, IP addresses or mobile device identifiers, from which an individual can be identified.

Personal information does not include “aggregated” or “de-identified” or “anonymised” information, which is data we collect about the use of the Service or about a group or category of products, services or users, or other data from which individual identities or other personal information has been removed so that the individual concerned cannot be identified directly or indirectly. Such data helps us understand trends and our users’ needs so that we can better consider new features or otherwise tailor our Service. This policy in no way restricts or limits our collection and use of such information.

Data Privacy Manager

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.

Contact details

Full name of legal entity: SIDEQUEST META LTD

Postal address: Suite 9.05, Tower 1, 1 Harbour Exchange Square, London E14 9GE

Telephone number/email: support@sidequestmeta.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Your duty to inform us of changes

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

While using our Service you may be presented with 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 or practices. We encourage you to read the privacy policy of every website you visit so you are fully aware how your personal data is being used.

How do we protect children?

Children under the age of [13] are not eligible to use our Service. The Service is not directed to children under such minimum age. If we discover that we have inadvertently collected information from children under such minimum age, we will delete the children’s information from our systems in accordance with applicable law. If you become aware that personal information about a person under such minimum age has been provided to us, please immediately contact us using the details set out above.

If you are under [16] years of age, do not provide any personal information unless you have first obtained your parent’s or guardian’s permission. Depending on the applicable laws, verified consent from your parent or guardian may be required.

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THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. As explained above, it does not include data where the identity has been removed (anonymous data).

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

Information you provide to us voluntarily:

You may provide us with the following types of information about you, for example when you (or, if you are a child, your parent) complete a membership application form and register for an account through www.SideQuest.co.uk/members or if you provide us with information about you via email, through a form on our website or mobile app or by telephone, for example if you sign up for marketing emails or contact our customer services.

If you are a customer: Name, telephone number, dates of birth, ID number (brp/passport number/Chinese ID), email address, gender, emergency contact details, game preferences and marketing preferences, information preference, in game chat logs and messages communicated through use of our Service.
The payment information shown by merchants (such as MasterCard) on receipts on our POS payment machines. We do not process payments ourselves and do not collect or store credit card details or similar bank account details. You should review the payment service providers’ privacy notices for information about how they use your payment data.

Information we collect automatically:

Internet Protocol (IP) address
Broad geographic location (e.g. country or city-level location) based on your IP address
Log data (time and period) in-store and online
In-game items and behaviours
Achievements you have completed in the game
Device information and identifiers, analytics and advertising IDs (through cookies and technical identifiers which are stored on your device) - see our Cookie Policy for further details
CCTV – we use CCTV in our studios [for security purposes]. [We notify you by means of a notice in each studio that CCTV pictures are being collected.]
We do not record games but may do in future. We will update this Privacy Notice if that occurs and you will be made aware if you are being recorded when you are playing a game.
Photos to promote events and tournaments

Information we obtain from third party sources

We sometimes purchase marketing lists from third party PR and marketing companies. We use this personal data only in accordance with data protection law and we use only reputable suppliers.
SideQuest access and use publicly available data from Steam or similar game platforms, or information shared eg by Sony PlayStation data (eg friends list, block list)
If you log in to our Service using social network accounts, such as Facebook, Google, WeChat or Instagram, we may collect personal information you authorised those networks to share with us to pre-populate our sign up form. Exactly what information we receive from your social media will depend on your social media privacy settings, but it would typically include your basic public profile information such as:
- your username
- profile picture
- gender (with your option)
- your friends playing the same game
- other information from the networks that you have permitted the networks to share with us
- any information you have made public on the networks.

You should always review, and if necessary, adjust your privacy settings on the networks before linking or connecting them to our Service (See also paragraph 1.6 above).

We 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 to provide our Service, 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 our Service). In this case, we may have to cancel a Service you have with us but we will notify you if this is the case at the time.

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:

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.
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; “legitimate interest” means the interest of our business in conducting and managing our business to enable us to 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 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.
Where we need to comply with a legal obligation to which we are subject.
Where we have your consent (although generally we do not rely on your consent except in relation to marketing (See Marketing section in paragraph 3.3 below)).

Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways we may 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:

Personal Information	Purpose	Legal basis according to GDPR
Registration information: - Name - user name - email address - phone number (if applicable) - date of birth - ID (passport etc) number - gender - social media info (Facebook/WeChat etc)	Create membership account, log in, eligibility check, manage relationship, notify changes, ask reviews/surveys	Necessary for contract performance Legitimate interests (debt collection, identity check) Compliance with legal obligation (age/ID verification)
Supplier info, financial records	Keep payment records, manage fees/charges
Chat logs and messages	Deliver Service chat function	Necessary for contract performance
Support team submissions	Technical support, customer service	Necessary for contract performance
Game progress: log data, items, behaviours, achievements	Account record, improve Service, analytics	Legitimate interests
Photos	Marketing, event promotion	With your consent
Technical data: IP, location, device info, identifiers, Advertising ID	Improve Service, compatibility, analytics	Legitimate interests
Gameplay screenshots, cheat-related data, CCTV	Prevent fraud/hacking, venue security	Legitimate interests Legal obligation compliance
Advertising partner info	Track ad source, pay advertisers	Legitimate interests
Survey/contest voluntary info	Research, feedback, improve Service	With your consent

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Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us: We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need. You will receive marketing communications if you have requested info or purchased services and not opted out.
Third-party marketing: We will get your express opt-in consent before sharing data with third parties for marketing.
Opting out: You can opt out at any time by contacting us or clicking unsubscribe links.

Cookies

You can set your browser to refuse all or some browser cookies, or alert you when websites set or access cookies. If you disable or refuse cookies, some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see https://sidequesthub.com/cookies.

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 we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out above. We do NOT sell any personal information to third parties. We may share aggregated or de-identified information without consent.

Vendors, consultants and service providers (analytics, cloud, Tencent China, etc.)
Professional advisers (lawyers, bankers, auditors, insurers) in UK and China
HM Revenue & Customs, regulators and authorities in the UK
Third parties in case of merger, acquisition or asset sale

We require all third parties to respect data security and process only for specified purposes as per our instructions.

We reserve the right to disclose information to comply with law, legal process, or public/governmental authorities, to protect rights, property, safety of SideQuest, users, employees or public.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from accidental loss, unauthorised access, alteration or disclosure. Access is limited to those with business need, who process only on our instructions and are subject to confidentiality.

We have procedures for suspected data breaches and will notify you and regulators where legally required.

DATA RETENTION

We retain personal data only as long as reasonably necessary to fulfil the purposes, including legal, regulatory, tax, accounting requirements. We may retain longer in case of complaint or prospective litigation.

We consider data amount, sensitivity, risk, processing purposes, and legal requirements to set retention periods.

Some data (log, chat, in-game activity) may be stored only minutes/days; other data may be retained to maximum permitted by law.

We may anonymise data for research/statistics and use indefinitely.

YOUR LEGAL RIGHTS

Under data protection laws, you have the right to:

Request access to your personal data
Request correction of inaccurate/incomplete data
Request erasure of your personal data
Object to processing based on legitimate interest or direct marketing
Request restriction of processing
Request data transfer in structured, machine-readable format
Withdraw consent at any time

No fee is usually required for these requests. We may charge for unfounded/repetitive/excessive requests or refuse compliance.

We may verify your identity to protect data security. We aim to respond within one month; complex requests may take longer with notice.

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CHANGES TO THIS POLICY

We may revise this Policy periodically. Please check the effective date each time you use the Service.

This version was last updated on 13/04/2022. Historic versions can be obtained by contacting us.

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