Last update: 7th August 2021
Game Change LSS ltd. Or Game Change takes privacy and data protection seriously and seeks to comply with all applicable data protection requirements, including the European Union’s General Data Protection Regulation (GDPR)
We are committed to safeguarding the privacy of our website visitors and service users.
This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
In this policy, “websites” refers to all content available under the domain name “game-change.com” or any domain name alias to the same content and any other online and mobile services that we provide.
In this policy, “we”, “us” and “our” refer to Game Change LSS Ltd.
- How we use your personal data
- Providing your personal data to others
- International transfers of your personal data
- Retaining and deleting personal data
- Amendments
- Your rights
- Cookies
- Our details
In this section we have set out:
- the general categories of personal data that we may process
- the purposes for which we may process personal data
- the legal bases of the processing
We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
We may process your account data (“account data“). The account data may include your name, email address, employer, mailing address and telephone number/s. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our websites, providing our products and services, ensuring the security of our websites and related services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include your name, email address, employer, mailing address and telephone number/s. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent and/or our legitimate interests, namely the proper administration of our website and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website, (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our websites and business
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters and related marketing content (“subscription data“). The subscription data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
Providing your personal data to others
We share your information with a number of organisations for the purpose of providing our products and services to you as when there is a legal or regulatory requirement.
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
We may share your personal data with our agents, consultants, suppliers or service providers insofar as reasonably necessary for the proper administration of our business and in order to deliver any agreed contracts. These organisations include:
- Customer Relationship management data – based in United States of America
- Marketing database and email automation platform provider – based in the United States of America
- Email and communications service provider – based in the European Economic Area (EEA)
- Website service provider – based in United States of America
- Learning management platform service provider – based in United States of America
Financial transactions relating to our website and services are handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
International transfers of your personal data
In this section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA)
As part of delivering our services to you, we may transfer your personal data to The United States of America. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, agreed with each of our service providers
Retaining and deleting personal data
This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data as follows:
- Name, email address, employer name, mailing address, telephone number/s will be retained for as long as necessary following initial enquiry to ensure proper administration of our business and in order to deliver any agreed contracts.
We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
We may update this policy from time to time by publishing a new version on our website. In doing so we will change the updated date at the top of this page.
You should check the updated date on this page when you use our services to ensure you are happy with any changes to this policy. If you are not happy with the changes then you should cease using our services
In some cases, we may provide you with additional notice of changes to this privacy policy, such as via email. We will always provide you with such additional notice well in advance of the changes taking effect where we consider the changes to be material.
You may instruct us to provide you with any personal information we hold about you
We may withhold personal information that you request to the extent permitted by law.
You may instruct us at any time not to process your personal information for marketing purposes.
You may instruct us to change or remove your personal data if you think it is inaccurate
You may ask us to delete your personal information. Generally, this is the case when:
- there is a legal requirement to do so
- your personal information is no longer needed for the original collection reason
- you are removing your consent for us to use your personal data
- there is no legal reason for the use of your personal data
In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt-out of the use of your personal information for marketing purposes.
You may request your data to be transferred to another party in a commonly used format. We will only be able to comply with such a request where decisions were made by a computer rather than a person and it does not adversely affect the rights of others.
About cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
We use cookies for the following purposes:
- authentication – we use cookies to identify you when you visit our websites and as you navigate our websites
- status – we use cookies to help us to determine if you are logged into our websites
- personalisation – we use cookies to store information about your preferences and to personalise the website for you
- security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally
- advertising – we use cookies [to help us to display advertisements that will be relevant to you
- analysis – we use cookies to help us to analyse the use and performance of our website and services
- cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally
Cookies used by our service providers
Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
Google Analytics
We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy
Details of Cookies:
| Cookie Name | Expiration Time | Description |
| _ga | 2 years | Used to distinguish users. |
| _gid | 24 hours | Used to distinguish users. |
| _gat | 1 minute | Used to throttle request rate. |
| AMP_TOKEN | 30 seconds to 1 year | Contains a token that can be used to retrieve a Client ID from the AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service. |
| _gac_<property-id> | 90 days | Contains campaign related information for the user. If you have linked your Google Analytics and AdWords accounts, AdWords website conversion tags will read this cookie unless you opt-out. |
MailChimp
We use MailChimp to provide email and marketing automation. This service uses cookies for tracking usage of our. You can view the privacy policy of this service provider at https://mailchimp.com/legal/privacy/
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- https://support.google.com/chrome/answer/95647?hl=en (Chrome);
- https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
- http://www.opera.com/help/tutorials/security/cookies/ (Opera);
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- https://support.apple.com/kb/PH21411 (Safari); and
- https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
Blocking all cookies will have a negative impact on the usability of many websites.
If you block cookies, you will not be able to use all the features on our websites.
Game Change LSS Ltd is registered in England and Wales under registration number 13166953 and our registered office and principal place of business is at 9-11 Peckover St, Little Germany, Bradford, United Kingdom BD1 5BD
Your privacy is very important to us. If you have any questions or comments about this policy you can contact us:
- by post, to the postal address given above
- using our website contact form
- by telephone, on +44 (0)1274 452 107
- by email, using [email protected]
