- This Privacy Notice sets out how we, Eliora Educational Games Limited of 2601 Universal Trade Centre, 3 – 5A Arbuthnot Road Central, Hong Kong (collectively “Eliora”, “we”, “us”, “our”) process the personal data of individuals (each a “customer”, “user”, “you”, “your”) who contact us, who use our website, social media sites, services and related content or who purchase our goods or services (collectively, the “Services”).
- Additional information for users located in the European Economic Area (“EEA”), Switzerland and the UK about their rights and other information can be found in the Annex to this Privacy Notice.
- This notice, together with our Cookies Notice, Website Terms and Refund and Return Policy and any other documents referred to in these documents, set out our views and practices regarding your personal data and how we will treat it. Please read these documents carefully. By visiting our website, you acknowledge the processing described in this notice, our Website Terms and related documents.
- We will let you know, by posting on our website or otherwise, if we make any changes to this notice from time to time. Your continued use of the Services after notifying such changes will amount to your acknowledgement of the amended notice.
- This notice has been last updated on 26 September 2019.
What personal data do we process about you?
- For those individuals who are subject to the European General Data Protection Regulation, “personal data” means any information relating to an identified or identifiable natural person, known as a ‘data subject’. We may process the following personal data about you:
a. Information provided by you. For example, we will receive your name and the nature of your enquiry when you contact us, your delivery and payment details when you order a product, your purchase history if you are a returning customer, your email when you subscribe to our communications, your username, submissions, reviews and ratings if you interact with our pages and posts on social media sites and your education and employment history when you make a job application. We may be unable to assist unless you provide the relevant information, and some information will be mandatory for our compliance with the law.
b. Information about your device. For example, when you visit our website we may collect technical information about your device such as IP address, operating system, browser, time zone setting, clickstream data, page interaction information (such as scrolling, clicks, and mouse-overs), your preferences, and methods used to browse away from the page. You do not have to provide this information, however, it will be useful for our statistical and business administration purposes.
c. Information from third party sources. For example, if you purchase our goods our payments vendor will inform us if your payment was successful and our deliveries partner will inform us when you received our goods. Such information is required in order to fulfil your orders. We may also receive your profile information if you interact with our pages and posts on social media sites, where such information is made available to us by the social network in accordance with their privacy notice.
- You should not provide to us information about others unless you have their permission to do so.
- We will rely on the information provided by you as accurate, complete and up to date, and we shall be grateful if you would let us know as soon as there are any changes to it.
How & why we use the data we collect
- Generally, we will use your information (i) to operate and improve our Services; (ii) to fulfil your orders and requests; and (iii) send marketing and show advertising to our users.
- In particular, we will use your information when:
(a) responding to your communications;
(b) providing the Services, including our website and its features, social media posts and sites, goods ordering facility, content and other services;
(c) notifying you of changes to our Services;
(d) sending you notices, invoices and collecting payments;
(e) engaging vendors to fulfil functions in relation to our Services, including webhosting, payment facility, logistics, data storage, information security, debt recovery, and other functions;
(f) sending you marketing requested by you;
(g) serving personalised advertising to your devices, in accordance with our Cookie Statement below;
(h) ensuring the security of our business and preventing and detecting fraud or illegal conduct;
(i) administering our business, including complaints resolution, troubleshooting, data analysis, quality control, staff training, testing of new features, research, statistical and survey purposes;
(j) developing and improving our Services;
(l) complying with applicable law, including in response to a lawful request from a court or regulatory body.
- The legal basis for our processing of personal data for the purposes described above will typically include:
- processing necessary to fulfil a contract that we have in place with you or other data subjects, such as processing for the purposes set out in paragraphs (a), (b), (c) and (d);
- your consent, such as processing for the purposes set out in paragraphs (e), (f) and (j);
- processing necessary for our or a third party’s legitimate interests, such as processing for the purposes set out in paragraphs (a), (b), (c), (g), (h), (i) and (j), which is carried out on the basis of our legitimate interests to ensure that Services are provided properly, efficiently and, as far as possible, in a way that is relevant to you, ensure the security of our business and our users’ information and ensure the proper administration of our business;
- processing necessary for compliance with a legal obligation to which we are subject, such as processing for the purposes set out in paragraph (k);
- and any other applicable legal ground from time to time.
Disclosure of your personal data
- There are circumstances where we may wish to disclose or are compelled to disclose your personal data to third parties. These scenarios include disclosure to:
- our affiliates or associated offices;
- our vendors to facilitate the provision of the Services;
- subject to appropriate legal basis such as consent, our advertising and marketing partners who enable us, for example, to deliver personalised ads to your devices or who may contact you by post, email, telephone, SMS or by other means;
- successor or partner legal entities, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event relating to our business. In the case of a merger or sale, your personal data will be permanently transferred to a successor company;
- public authorities or other third parties where we are required by law to do so; and
- other third parties where you have provided your consent.
International transfer of your personal data
- We will host your personal data in the United Kingdom and in Israel which are countries deemed to provide adequate safeguards for your data. For further information about what this means, please see the website of the Information Commissioner’s Office. Our office in Hong Kong does not carry out processing of your personal data.
- We may also transfer your personal data to our vendors located outside of your country. Where this is the case, we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means. In particular, we will ensure that appropriate transfer mechanisms, such as standard contractual clauses, are in place to ensure an adequate level of data protection. You may contact us for a copy of such safeguards in these circumstances.
Retention of personal data
- We retain personal data for as long as is necessary for the purposes listed above or longer as may be required by the law. Please contact us for further details of applicable retention periods.
- We may keep an anonymized form of your personal data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate interest in doing so.
Security of personal data
- We will use appropriate technical and organisational information security measures to try to prevent unauthorised access to your personal data. However, please be aware that the transmission of information via the internet is never completely secure. Whilst we can do our best to keep our own systems secure, we cannot control the whole of the internet and we cannot therefore guarantee the security of your information as it is transmitted to and from our website.
- Where you have created or received a password or authentication code which enables you to access certain parts of our website, you are responsible for keeping this password or authentication code confidential. We ask you not to share your password or authentication code with anyone.
Your right to opt-out
- If you would like us to stop sending you marketing communications you may use the opt-out link here, the unsubscribe link in our marketing communications or by amending the settings in our Services. You may also contact us here.
Data subject rights
- Data subjects, but also other individuals depending on applicable law, have numerous rights in relation to their personal data. For further information about your data protection rights please visit the website of your local data protection authority.
- Right to information. We hope to satisfy your right to information by providing this notice.
- Right to make an access request. Data subjects may request in writing copies of their personal data. However, compliance with such requests is subject to certain limitations and exemptions and the rights of other individuals. Each request should make clear that an access request is being made. You will be required to submit a proof of your identity.
- Right to rectification. Data subjects may request that we rectify any inaccurate or incomplete personal data.
- Right to withdraw consent. Data subjects may at any time withdraw their consent to the processing of their personal data carried out by us on the basis of their previous consent. Such withdrawal will not affect the lawfulness of processing based on such previous consent.
- Right to object to processing including automated processing and profiling. We do not make automated decisions about data subjects. Profiling may be carried out for business administration purposes, such as monitoring trends in user visits to our website and in order to deliver relevant ads to users’ devices. We will comply with valid objection requests unless we have a compelling overriding legitimate ground for the continuation of our processing or we have another lawful reason to refuse such request. We will of course comply with each valid opt-out request in relation to marketing communications.
- Right to erasure. Data subjects may request that we erase their personal data. We will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping the personal data, such as, our business record retention obligations.
- Restriction. Data subjects may request that we restrict our processing of their personal data in various circumstances. We will comply, unless there is a lawful reason for not doing so, such as, a legal obligation to continue processing your personal data in a certain way.
- Right to data portability. In certain circumstances, data subjects may request the controller to provide a copy of their personal data in a structured, commonly used and machine-readable format and have it transferred to another provider of the same or similar services. We do not consider that this right applies to our Services. However, to the extent it does, we will comply with such transfer request. Please note that a transfer to another provider does not imply erasure of the data subject’s personal data which may still be retained for legitimate and lawful purposes.
- Right to lodge a complaint with the supervisory authority. We suggest that data subjects contact us about any questions or complaints in relation to how we process their personal data. However, each data subject has the right to contact the relevant supervisory authority directly. A list of the European supervisory authorities is available here.
Parents and guardians
- Our Services are not directly intended for children and should not be used by them unless supervised by a parent or guardian.
- Questions, comments and requests regarding this notice are welcomed and should be addressed to firstname.lastname@example.org.