Live Tech Games

Last updated: 17th November 2022 

We recommend that you read this Privacy Notice in full to ensure you are fully informed.  However, if you only want to access a particular section of this Privacy Notice, then you can click on the relevant link above to jump to that section.

Live Tech Games respects your right to privacy.  This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Notice only applies to personal information that we collect through our website at https://livetechgames.com/ (“Website”), our applications (“Apps“) and when you play one of our games (“Games“). Where we provide links to websites of other organisations, this Privacy Notice does not cover how that organisation processes personal information. We encourage you to read the privacy notices on the other websites you visit.

To understand the terms under which you use the services we provide to you in the United Kingdom, please read our Terms of Service.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details under the “How to contact us” heading below.

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1. What does Live Tech Games do?

Live Tech Games is a game developer and live gaming platform headquartered in the United Kingdom. We offer players mobile gaming experiences with live mobile tournaments via our bespoke games.

For more information about Live Tech Games, please see the “Our Mission” section of our Website.

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2. What personal information does Live Tech Games collect and why?

• Identity Data: includes name, username or other identifier. 
• Contact Data: includes address, email address, telephone number.
• Transaction Data: includes details about payments by you, order details and history, details of services you have purchased from us, details of in-App purchases by you.
• Technical Data: includes IP address, login data, browser type, time zone setting and location, browser plug-in types, operating system and platform, device ID, advertising ID.
• Usage Data: includes information about how you use our Website and Apps.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third party partners, and your communication preferences. 
• Profile Data: includes information about your interests, preferences, participation in prize draws and competitions, survey responses and feedback, your username and password, your avatar, purchases or orders made by you, information about any cash prizes you win.

3. How and why is my information collected?

The personal information that we may collect about you broadly falls into the following categories:

• Information that you provide 

Certain parts of our Website and Apps may ask you to provide personal information.   

Account creation

We may ask you to provide your contact details including your email, user name and password in order to register an account with us, to enable you to sign in to this account when you play our Games, and so you can subscribe to marketing communications from us, and/or submit enquiries to us. 

Where you are engaging with us in relation to our B2B services, we may store your business contact details and job title if they are used in order to register an account with us.

Profile picture

In some Games you can personalise your game avatar with your own profile picture. We may also store your picture, if you choose to personalise your game avatar with your own profile picture. 

Purchase of goods or services

If you make any in-App purchases for goods or services whilst playing our Games, or any other purchases of services from us, we will store a log of that purchase.

Prize fulfilment

Some of our Live tournament Games offer cash prizes. In the event that you win a cash prize, we will store a record of that win as well as information such as your name and email address in order to for us to fulfil your prize. Please note that we will not collect your payment information for this purpose. Fulfilment of any cash prizes you win will be via a third-party payments company – PayPal.

Customer services information

You may choose to provide us with additional information when you contact us about our services, contact us for technical or other support, or otherwise interact with us.  For example, you may complain about the performance of our Website and/or Apps and send us screenshots of errors that you have received when using our Website and/or Apps.  We will also collect information as to how you navigate our Website and/or Apps to contact customer services and the channel of communication that you use. 

Chat function information 

We will process and store any personal data that you provide in the chat. If you do not want us to collect this information, please do not use the chat functionality in our Apps. Please note that you should never submit any personal data related to anyone else in any such chat and must in particular not submit any data that is related to health, sexual orientation, race or ethnicity, political or religious beliefs or membership in any trade union.

User generated content 

You may choose to provide us with a contribution to our blog, published on our Website. If you choose to do so, we will process and store your personal data including your name and, depending on the content, your opinions on our Website. 

User settings

We collect information about the selections you have chosen on any in-App settings, privacy settings and details about when you provided any consent and for what purposes. These may include in-App notification preferences, marketing email preferences and music preferences.  

• Information that we collect automatically

When you visit our Website and use our Apps, we collect certain information automatically from your device.  In some countries, including countries in the European Economic Area and UK (together, “Europe“), this information may be considered personal data under applicable data protection laws.

Specifically, the information we collect automatically will include information such as your IP address, device type, unique device identification numbers, browser-type, operating system, App version, broad geographic location (e.g., country or city-level location), how you are connecting your device to the Internet, i.e., whether by WiFi or cellular data.  We also collect information about how your device has interacted with our Website and Apps, including the pages you accessed, links clicked, and the Games you played when you accessed our Apps.  When you play one of our Games we will save information about your general activities in the Game and for how long you played that Game.

Collecting this information enables us to better understand the visitors who come to our Website and Apps, where they come from, and what content on our Website and Apps is of interest to them.  We use this information for our internal analytics purposes and to improve the quality and relevance of our Website, our Apps and our Games. 

Some of this information is collected using cookies and similar tracking technologies, as explained further under the heading “Cookies and similar tracking technologies” below. You can also find more information about our use of cookies in our separate cookie notice and when you manage your cookie preferences in our consent management platform. 

• Information that we obtain from third party sources

From time to time, we receive personal information about you from third party sources . But only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us. Third party sources from which we may collect information about you include:  

• Partners that engage in marketing and advertising activities on our behalf.
• Publicly available sources, including data in the public domain.
• Third-party service providers engaged for services such as e-commerce, payment and technical.

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4. Who does Live Tech Games share my information with?

We share your personal information with the following categories of recipients:

• Third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website and Apps), or who otherwise process personal information for purposes that are described in this Privacy Notice. We work with the following types of third-party service providers:
• Core Infrastructure including hosting services such as Microsoft Azure who process all of our hosted data;
• Payment service providers such as PayPal who process Contact Data and who assist us with fulfilment of cash prizes; 
• Customer relationship management services such as Help Shift and Braze who process Identity Data, Contact Data and Technical data who assist us with customer support;
• Marketing companies and advertising partners who process Technical Data such as your IP address and other advertising identifiers and who assist us with our marketing and advertising activities.
• Commercial partners such as ITV plc (“ITV“) for business, commercial and advertising reasons, who in certain contexts, independently decide how to process data. We may share information such as your email address with ITV, which may be used by ITV for their own data matching and analytics purposes (such as to see whether a user of our Apps is also a user of ITV products and services). We may also share information with ITV about your in-App activity including how many live tournaments you have entered playing our Games and other types of session data. Where we provide you with in-App advertising content (including in-App links) on behalf of our partners such as ITV, we may share information such as whether you have clicked on or otherwise interacted with any advertising content, banners or links. Please note that the results of any data matching and analytics carried out by ITV will only be shared by ITV with their commercial partners where relevant data protection contractual clauses are in place.
• Any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
• An actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice.
• Any other person with your consent to the disclosure.

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5. Legal basis for processing personal information?

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

We have set out a description of the ways we may use your personal data and which of the legal bases we rely on to do so, in the table below. 

In certain situations, we require your data to pursue our legitimate interests. We do this in a way which is reasonable for you to expect as part of the running our business and which does not materially affect your rights and freedoms.  We have identified below what our legitimate interests are.  

 

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To provide you with access to the Apps, their content and functionalities including to register you as a new user, set up your account, and provide you with access to your account.	(a) Identity (b) Contact	(a) Performance of a contract with you
To process and fulfil any in-App purchases or other purchases you make from us including: (a) Manage payments, fees and charges (b) Send you purchase confirmations and invoices (c) Collect and recover money owed to us	(a) Identity (b) Contact (c) Transaction (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c) Sending you technical notices, updates, security alerts, and support and administrative messages (d) Responding to your comments, questions, and requests and providing customer service	(a) Identity (b) Contact (c) Profile (d) Transaction (e) Usage (f) Marketing and Communications	(a) Performance of a contract with you  (b) Necessary for our legitimate interests (to keep our records updated and to ensure that our Website and Apps operate securely and effectively)
To understand feedback about our Website, our Apps and our services, and to help quickly and easily provide more information on the use of those services	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Necessary for our legitimate interests (to study how customers use our Website, our Apps and our services, to develop them and grow our business)
To enable you to partake in a  competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our Website, our Apps and our services, to develop them and grow our business)
To fulfil the payment of cash prizes where you win any of our competitions	(a) Identity (b) Contact (c) Profile	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to enable us to pay you where you have won a cash prize)
To administer and protect our business and our Website and Apps (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical (d) Usage	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To personalise your experience of our Website and/or Apps in accordance with your interests and preferences	(a) Identity (b) Contact (c) Profile (d) Usage (e) Technical	(a) Consent (where we collect personal data using cookies or similar technologies we will process your personal data on the basis of your consent) (b) Necessary for our legitimate interests (to provide a personalised and engaging user experience of our Website and/or Apps)
To deliver relevant advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	(a) Consent (where we collect personal data using cookies or similar technologies we will process your personal data on the basis of your consent) (b) Necessary for our legitimate interests (to deliver relevant and engaging content to our users, to grow our business and to inform our marketing strategy)
To monitor performance and overall usage of our Website and Apps and user retention rates, track how users are engaging with our services, identify how and how frequently features are utilised, identify problem areas and inform design development for future updates	(a) Technical (b) Usage	(a) Consent (where we collect personal data using cookies or similar technologies we will process your personal data on the basis of your consent)   (b) Necessary for our legitimate interests (to define types of users for our services, to keep our Website and Apps updated and relevant, to develop our business and to inform our marketing strategy)
To share your contribution to our blog (published on our Website)	(a) Identity (b) Profile	(a) Consent
To send you advertising or promotional materials, including information about new Games, products, contests, features and enhancements, special offers and other events of interest from Live Tech Games and our select partners (including ITV)	(a) Identity  (b) Contact  (c) Marketing and Communications	(a) If required by marketing laws, we seek consent before sending marketing materials to individuals and in such cases consent is our lawful basis for sending marketing to you. When we process your information based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before it is withdrawn.  To exercise your rights, see ‘Your data protection rights’ section of this Privacy Notice.
For collecting information through the device-based settings which you have enabled (e.g. access to your GPS location, camera or photos)	(a) Information from device settings	(a) Consent When we process your information based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before it is withdrawn.  To exercise your rights, see your device-based settings and ‘Your data protection rights’ section of this Privacy Notice.
To comply with and to assess compliance with applicable laws, rules and regulations, and internal policies and procedures	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to ensure our Website and our Apps operate effectively and compliantly)

 

To obtain further information about how we balance our legitimate interests against your rights and freedoms where applicable, please contact us using the contact details provided under the “How to contact us” heading below.

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6. Cookies and similar tracking technology

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you, including to serve interest-based advertising.  For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice and consent management platform . 

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7. How does Live Tech Games keep my personal information secure?

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include encrypting passwords in transit and at rest. 

Where you have created an account and unique password to enable you to access our Website and/or Apps it is your responsibility to keep this password secure and confidential.

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8. International data transfers

In some cases your personal information is transferred to, and processed in, countries other than the country you live in. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, our Website and App servers are located in the UK, Western Europe and the US, and our third party service providers and partners operate around the world.  This means that when we collect your personal information we will process it in any of these countries.

Where we transfer your personal information to countries and territories outside of the European Economic Area and the UK, which have been formally recognised as providing an adequate level of protection for personal information, we rely on the relevant “adequacy decisions” from the European Commission and “adequacy regulations” from the Secretary of State in the UK. 

Where the transfer is not subject to an adequacy decision or regulations, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. The safeguards we use are normally the forms of standard contract authorised for the purpose by the UK Information Commissioner’s Office. 

Our standard contracts used for this purpose can be provided on request.   

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9. Data retention

We retain the personal information we collect from you where we have an ongoing legitimate business need to do so. We will store and use your personal data for as long you have an account with us and for as long we consider it to be required to fulfil the purposes set out in this Privacy Notice. This means that we will use different categories of data for different periods. We will for example use contact and sign in details, gaming history and data related to your device for as long you use our Apps and play our Games, and as long as we need to provide you with your account. 

In certain circumstance, we will need to keep your information for legal reasons after your account has been deleted. The specific retention periods depend on the nature of the information and why it is collected and processed and the nature of the legal requirement. We keep your information when we have a legal obligation to do so (for example bookkeeping and financial reporting); to deal with and resolve requests and complaints (for example, if there was an ongoing complaint with respect to a service provided to you but you had deleted your account), to protect individuals’ rights (for example we will retain information about a data subject access request for one year after the request in case there is a subsequent complaint and the information is needed to demonstrate how the request was handled); and for litigation or regulatory matters (for example we would retain your information if there was an ongoing legal claim and the information was relevant to the claim. This information would be retained until the matter had been concluded.). 

When we have no ongoing legitimate business need or legal reason to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. 

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10. Your data protection rights

Depending on your location, you may have the following data protection rights.  To exercise any of them see specific instructions below or contact us using the contact details provided under the “How to contact us” heading below.

• You may access, correct, update or request deletion of your personal information.  
• You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. 
• You have the right to opt-out of marketing communications we send you at any time.  You can exercise this right by clicking on the “unsubscribe” link in the marketing e-mails we send you, or by turning off marketing emails in your in-App settings.
• If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a supervisory authority about our collection and use of your personal information.  In the United Kingdom, the supervisory authority is the ICO https://ico.org.uk/global/contact-us/.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

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11. Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, regulatory, technical or business developments.  When we make a material update to our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if, and where, required by applicable data protection laws. 

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.  

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12. How to contact us

If you have any questions or concerns about our use of your personal information, please contact us using the following details: hello@livetechgames.com  

The data controller of your personal information is Live Tech Games Ltd, which is registered with the Information Commissioner’s Office with registration number ZA926936