Info on what goes on @AGN
Posted on:Monday, 29th October 2012
Latest updated: Tuesday, 11th September 2018 @ 13:59 BST
Viewed: 1872 times
Summary – Policy Overview
This Policy explains how we may Process your information. This Policy may be amended or updated from time to time, so please check it regularly for updates.
Eagle Networks Ltd, with its affiliates and its subsidiaries (collectively, “us”, “our” or “we”), owns, operates, or provides access to, several interactive websites, mobile and connected applications, and other online interactive features and services, including, but not limited to, emails, newsletters, forums, communities, sweepstakes and contests (collectively “Services”).
2.What Categories of Information We May Process
Summary – Categories of Information We May Process
We may Process: your personal details (e.g., your IP address); information about your interactions with our content or advertising; and any views or opinions you provide to us.
We may also Process information about you from your use of our Services (e.g., the type of device you are using, the internet service provider, etc.), including your interactions with content and advertising on the Services.
“Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable.
“Process”, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
We may Process the following categories of Personal Information about you:
- Personal details: your name; username or log in details; password; areas or topics of interest; and photograph (if you or another user posts a photo on the Service).
- Demographic information: gender; age/date of birth; nationality; salutation; job title, company information, education, work experience and other professional information; and language preferences.
- Contact details: postal address; telephone and/or mobile number; email address; and your public social media handles or profile(s).
- Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
- Location information: location data that describes the precise geographic location of your device (“Precise Location Data”).
- Views and opinions: any views and opinions that you or other users choose to send to us, or publicly post about us on social media platforms or in the Services, including on forums.
We also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this Policy, which may include but is not limited to:
- Information about your use of the Services, such as usage data and statistical information, which may be aggregated.
- Browsing history including the websites or other services you visited before and after interacting with the Services.
- Searches for and interactions with e-commerce opportunities, such as merchants and offers contained in the Services.
- Non-precise information about the approximate physical location (for example, at the city or zip code level) of a user’s computer or device derived from the IP address of such computer or device (“GeoIP Data”).
- Internet Protocol (“IP”) address, which is a unique string of numbers automatically assigned to your device whenever you access the Internet.
- your visits to, and interaction and engagement with, the Services, content and ads on third party websites, applications, platforms and other media channels (“Channels”), and
- your interaction with emails including the content and ads therein (collectively, “Online Data”).
- Device type, settings and software used.
- Log files, which may include IP addresses, browser type, ISP referring/exit pages, operating system, date/time stamps and/or clickstream data, including any clicks on customized links.
- Web Beacons, which are electronic files that allow a website to count users who have visited that page or to access certain cookies.
- Pixel Tags, also known as clear GIFs, beacons, spotlight tags or web bugs, which are a method for passing information from the user’s computer to a third party website.
- Local Shared Objects, such as Flash cookies, and Local Storage, such as HTML5.
- Mobile analytics to understand the functionality of our mobile applications and software on your phone.
Under certain circumstances and depending on applicable law, some of this Other Information may constitute Personal Information. Personal Information together with Other Information is hereinafter referred to as “User Information”.
3. Sensitive Personal Information
Summary – Sensitive Personal Information
We do not seek to collect or otherwise Process your Sensitive Personal Information. Where we need to Process your Sensitive Personal Information for a legitimate purpose, we do so in accordance with applicable law. The Services are not intended for use by children.
We do not collect or otherwise Process Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, or any other information that may be deemed to be sensitive under GDPR (collectively, “Sensitive Personal Information”) in the ordinary course of our business. Where it becomes necessary to Process Sensitive Personal Information under GDPR, we would rely on one of the following legal bases:
- Compliance with applicable law: We may Process your Sensitive Personal Information where the Processing is required or permitted by applicable law;
- Detection and prevention of crime: We may Process your Sensitive Personal Information where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);
- Establishment, exercise or defense of legal rights: We may Process your Sensitive Personal Information where the Processing is necessary for the establishment, exercise or defense of legal rights; or
- Consent: We may Process your Sensitive Personal Information where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Information.
Children. The Services are not intended for use by children, especially those under 13. No one under the age of 13 should provide any Personal Information or use our public discussion areas, forums or chats. Minors under the age of 18 are not permitted to make purchases through the Services or obtaining coupons or codes from the Services to purchase goods or services on third party websites. If, notwithstanding these prohibitions, your children disclose information about themselves in our public discussion areas, consequences may occur that are not intended for children (for example, they may receive unsolicited messages from other parties). If it is discovered that we have collected Personal Information from someone under 13, we will delete that information immediately.
4.How We Collect or Create Information
Summary – Collection and Creation of Information
We may collect or obtain User Information about you: directly from you (e.g., where you contact us); in the course of our relationship with you; when you make your Personal Information public (e.g., if you make a public post about us on social media); when you use any of our Services; when you visit our Services; when you register to use any part of the Services; or when you interact with any third party content or advertising on the Services. We may also receive User Information about you from third parties (e.g., social network sites). We may also create User Information about you, such as records of your interactions with us. Eagle Networks Ltd is not responsible for Personal Information you volunteer about yourself in public areas of the Services. This Policy does not cover the practices of third parties who may provide information about you to Eagle Networks Ltd.
Collection of User Information: We may collect User Information about you from the following sources:
- Data you provide: We may obtain your Personal Information when you provide it to us across our Services (e.g. where you sign up for emails, newsletters, bulletins; register for site membership or create a profile or account on any part of the Services; enter a sweepstakes, contest, competition or prize draw; participate in surveys; perform search queries through the Services; contact us via email, telephone or by any other means; purchase a subscription, software license or product; or when you provide us with your business card, etc.).
- Relationship data: We may collect or obtain your Personal Information in the ordinary course of our relationship with you (e.g. if you purchase a service from us).
- Data you make public: We may collect or obtain your Personal Information that you clearly choose to make public, including via social media (e.g., we may collect information from your social media profile(s) if you make a public post about us) or through our chats, forums or communities on the services.
- Service data: We may collect or obtain your Personal Information when you visit, download, use or register to use any part of our Service.
- Content and advertising information: If you choose to interact with any third party content or advertising on the Services or Channels, we may receive User Information about you from the relevant third party.
- Third party information: We may collect or obtain your Personal Information from third parties who provide it to us. This may include social network sites or services (e.g., Facebook, Twitter, LinkedIn, etc.). If you use a third party connection or log-in (e.g., Facebook Connect, Twitter, or Google+) to access the Services, create a membership or profile on any part of the Services, access our content or forward our content to another person, platform or service, we may also receive your username or email address for those third party services or other information available about you or collected from you on those services.
Please note that Eagle Networks Ltd is not responsible for the information you volunteer about yourself in the discussions in certain public areas of the Services, such as forums, blogs, wikis, chat rooms, private messages, message boards or other publicly accessible interaction, or information that you choose to make public in your member profile or other areas of the Services that allow users to upload or post content. We discourage users from posting such Personal Information in this fashion. You can change your publicly available information at any time via your profile page. To request removal of your Personal Information from these areas, please contact us using our DSAR Portal. In some cases, we may not be able to remove your Personal Information, in which case we will let you know we are unable to do so and why.
Creation of User Information. We may also create User Information about you, such as records of your interactions with us and details of your purchase history, for internal administrative purposes and analysis. We may also combine data you have provided to us with data obtained from third parties such as social networks and other data collection entities.
5. Purposes for Which We May Process Your Information
Summary – Purposes for Which We May Process Your Information
We may Process User Information for the following purposes: providing the Services to you; communicating with you; providing advertising to you on the Services and Channels; analyzing engagement with our audience; observing user engagement and purchase activity across the Service and Channels; managing our IT systems; conducting surveys; ensuring the security of our systems; conducting investigations where necessary; compliance with applicable law; and improving our Services.
The purposes, for which we may Process User Information, subject to applicable law, include:
- Provision of the Services to You: providing the Services to you from Eagle Networks Ltd or its partners including (i) offering of contests, as well as chat areas, forums and communities, (ii) posting of your personal testimonial alongside other endorsements, (iii) display of your personal reviews of products or services, (iv) allowing you to search for other website members using information you may already know about that member such as username, full name or gamer profile and identify users matching that criteria, (v) management of your account, and (vi) customer support and relationship management.
- Offering and Improving the Services: operating and managing the Services for you; providing personalized content to you; communicating and interacting with you via the Services; identifying issues with the Services and planning improvements to or creating new Services; and notifying you of changes to any of our Services.
- Surveys: engaging with you for the purposes of obtaining your views on our Services.
- Communications: communicating with you via any means (including via email, social media, post or in person) regarding news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required.
- Advertising: providing advertising based on your interests and interactions with the Services and Channels, including using User Information to serve you advertisements on the Services and Channels, as well as licensing segments of User Information to third parties. For further information, please see Section 6 below.
- Audience Engagement: identification and development of audience engagement, advertising and promotional strategies on various platforms and channels, both within the Service and on Channels.
- User Engagement and Purchases: tracking purchase traffic and activity across the Service and on Channels, including review of your browsing history (if available); provision of analytics and measurement of cost of traffic against money being made.
- IT Administration: administration of Eagle Networks Ltds’ information technology systems; network and device administration; network and device security; implementing data security and information systems policies; compliance audits in relation to internal policies; identification and mitigation of fraudulent activity; and compliance with legal equirements.
- Security: electronic security measures (including monitoring of login records and access details) to help mitigate the risk of and provide the ability to identify and rectify a security incident.
- Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
- Legal Proceedings: establishing, exercising and defending legal rights.
6. Cookies, Similar Technologies and Online Behavioral Advertising
Summary – Cookies, Similar Technologies and Online Behavioral Advertising
Eagle Networks Ltd and/or certain third parties may collect information about you for online behavioral advertising purposes in order for you to receive relevant interest-based advertising on the Services and on other websites, platforms and media channels. We use Online Data as well as other User Information to send you online behavioral ads. Online Data is aggregated with the Other Information and data we collect and/or similar data collected by partners to create groups of users and certain general-interest categories or segments that we have inferred. We use this information to get a more accurate picture of audience interests in order to serve ads we believe are more relevant to your interests.
Tracking technologies on the Services may be deployed by Eagle Networks Ltd and/or by our service providers or partners. Certain tracking technologies enable us to assign a unique identifier to you, and relate information about your use of the Services to other information about you, including your User Information. We may match information collected from you through different means or at different times and use such information along with offline and online information obtained from other sources (including from third parties), including, but not limited to, demographic information and updated contact information, for the purposes of learning more about you so we can provide you with relevant content and advertising.
We and our partners (including but not limited to e-commerce partners, affiliates, and analytics providers) also may use technologies such as pixel tags, e-tags, IP addresses, Local Shared Objects, Local Storage, Flash cookies and HTML5 to analyze trends; administer the Services; collect and store information such as user settings, anonymous browser identifiers and video viewing history; supplement our server logs and other methods of traffic and response measurement; track users’ location and movements around the Services; gather demographic information about our user base; and to improve our understanding of traffic on the Services, visitor behavior, and responses to promotional campaigns. Various browsers may offer their own management tools for removing Local Storage. To manage Flash Local Shared Objects please click here
Eagle Networks Ltd and/or certain third parties may collect information about you for online behavioral advertising (“OBA”) purposes in order for you to receive relevant interest-based advertising on the Services and on other websites, platforms and media channels. OBA is also referred to as interest-based advertising.
The specific providers we use for OBA are subject to change. For information about how to opt out of tracking methods for these entities and others, click here.
7. What is the Lawful Basis for Processing Personal Information
Summary – Lawful Basis for Processing User Information
We may Process your User Information where: you have given your consent; the Processing is necessary for a contract between you and us; the Processing is required by applicable law; the Processing is necessary to protect the vital interests of any individual; or where we have a valid legitimate interest in the Processing.
In Processing your User Information in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:
- Consent:: We may Process your User Information where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);
- Contractual necessity: We may Process your User Information where the Processing is necessary in connection with any contract that you may enter into with us;
- Compliance with applicable law: We may Process your User Information where the Processing is required by applicable law;
- Vital interests: We may Process your User Information where the Processing is necessary to protect the vital interests of any individual; or
- Legitimate interests: We may Process your User Information where we have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.
8. What Information We Disclose to Third Parties
Summary – Disclosure of User Information to Third Parties
We may disclose your User Information to: legal and regulatory authorities; our external advisors; parties who Process User Information on our behalf (“Processors”); any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on the Services.
We may disclose your User Information to other entities within the Company group, for legitimate business purposes (including operating the Services, and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to:
- legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
- outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality;
- third party Processors (such as analytic providers; data centers; etc.), located anywhere in the world, subject to the requirements noted below in this Section 9;
- any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;
- any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;
- any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation);
- any relevant third party provider, where our Services use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, information about your activities on the Services and Channels to provide you targeted advertising based upon your interests may be shared with the relevant third party provider. If you click or tap on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria;
For some of our Services, we may make some information, such as the name of our users, email address to third party providers of goods and services.
When you use a co-branded service (a service operated with a partner of Eagle Networks Ltd), or register or otherwise provide information on a co-branded site, you grant us permission to pass the collected information back to that partner, which may include third party service providers whose services are embedded into and/or appear within the Services;
With respect to surveys, in the event that responses are publicly disclosed, users will be notified at the time they take the survey. Otherwise we will disclose only aggregate information regarding its users’ responses in surveys to other participants in the survey. Where surveys allow users to submit written comments, and where Eagle Networks Ltd advises users of the possibility of such disclosure at the time they take the survey, Eagle Networks Ltd reserves the right to disclose any information provided by users, provided that no User Information identifying a specific user is disclosed.
Eagle Networks Ltd and some of our advertisers may use third party advertising service companies to serve advertisements, for OBA or otherwise, and perform related services when you interact with the Services. Often, these third party advertising companies employ cookies and other technologies to measure the effectiveness of website, app and email advertisements and to create a record of interaction with our content that they use in conjunction with their advertising which appears on other sites or applications, or for reporting website traffic, app use, statistics, advertisement data and/or other activities on the Services.
We may engage third party providers to assist with the collection, storage and segmentation of Online Data and the providers are required to maintain the confidentiality of this information. These third party providers may collect User Information from our Services for their own purposes, including but not limited to monitoring fraud around the web.
We may also engage third parties for the purpose of recognizing our users and delivering interest-based content and advertisements to them. We may share your User Information with our partners such as your name, email, or other identifier. Our partners may also: collect information directly from your device, such as your IP address, device ID, advertising ID, and information about your browser or operating system; and may place or recognize a unique cookie on your browser.
If we engage a third-party Processor to Process your User Information, the Processor will be subject to binding contractual obligations to:
- only Process the User Information in accordance with our prior written instructions;
- use measures to protect the confidentiality and security of the User Information; together with any additional requirements under applicable law.
9.International Transfers of Information
Summary – International Transfers of Information
Eagle Networks Ltd is a legal entity registered in the United Kingdom, and utilises data centers located in the United Kingdom.
If we transfer User Information from the European Economic Area (“EEA”) to a recipient outside the EEA that is not in an adequate jurisdiction, we do so on the basis of standard contractual clauses.
In certain situations, Eagle Networks Ltd may be required to disclose Personal Information in response to lawful requests by public authorities, including meeting national security or law enforcement requirements. If you are a European individual with a privacy related complaint, concern or question about Eagle Networks Ltds’ privacy practices, please contact us through our DSAR Portal.
Please note that we may use data collected by a third party operator/licensee of localized versions or editions of Services.
10. Data Security
Summary – Data Security
We implement appropriate technical and organizational security measures to protect your User Information. Please ensure that any Personal Information that you send to us is sent securely.
We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances we may use Secure Sockets Layer encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.
11. Data Accuracy
Summary – Data Accuracy
We take every reasonable step to ensure that your User Information is kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.
We take every reasonable step to ensure that your User Information that we Process is accurate and, where necessary, kept up to date, and any of your User Information that we Process that you inform us is inaccurate (having regard to the purposes for which they are Processed) is erased or rectified.
12. Data Minimization
Summary – Data Minimization
We take every reasonable step to limit the volume of your User Information that we Process to what is necessary.
We take every reasonable step to ensure that your User Information that we Process is limited to the User Information reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or access to the Services.
13. Data Retention
Summary – Data Retention
We take every reasonable step to ensure that your User Information is only retained for as long as they are needed.
We take every reasonable step to ensure that your User Information is only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will keep your User Information are as follows: we will retain copies of your User Information in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfil a legitimate business need.