Last Revised - September 20, 2021
Our values and what this policy is for:
We collect personal information about you in a number of different ways. In this section, we explain the different ways we collect personal information about you and the ways in which that information will be used. For more detail on how we use your data, please see section 3 (What does Enjin do with this data and what is our legal basis for processing this data?) below.
We will usually collect and store the following data about you when you access and use our Services:
We will sometimes use third party advertising companies to help us collect this personal information. Further information is provided below in section 5 (Third party advertising companies) below.
The personal information you provide is collected, stored and used to enable us to provide you with the Services in the best way possible. This includes:
The above uses of your personal information are necessary in order for us to provide the Services, and for you and other users to be able to use them, in accordance with our Terms of Service.
Sometimes, our use of your personal information is for purposes which are ancillary to the provision of the Services, or which are desirable in order to make them operate more effectively. In those circumstances, we believe we have a legitimate interest in handling your data, and do not believe that this storage and use of your data will be of particular concern to you.
We use your personal information for our legitimate interests in the following ways:
If you have opted in for marketing communications, we will collect, store and use your email address, as well as data relating to your use of the Services, in order to provide marketing for Services that we believe may be of interest to you (see below for details of our marketing communications). We also use your data to offer you other Services which we think may be of interest to you, by email, where you have chosen to opt-in to such communications in your account settings.
You can opt-out at any point by clicking “Unsubscribe” in any email communication you receive, which means you will no longer receive these marketing messages. Additionally, the withdrawal of your consent may however result in certain consequences. For example, in certain cases, we may not be able to provide you with certain Services.
We will also collect anonymised details about visitors to and use of our Services for the purposes of creating aggregate statistics or reporting purposes. However, no single individual will be identifiable from the anonymised details we collect for these purposes. We may share this aggregated information about our user base with our partners and advertisers.
Enjin will share your personal information with various third parties (including our affiliate companies in other countries) as follows:
We will also disclose your personal information to third parties:
We may also disclose and use anonymised, aggregated reporting and statistics about users of our website or our goods and services for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us and we will stop doing so.
We want to make sure that our advertising and marketing is relevant and interesting to you and our other users.
These third party advertising companies collect, store and use data by integrating cookies and other tracking software on our Services. The relevant data collected by these third parties may include website activity (for example, how long you are accessing our website and which specific pages you have looked at), IP addresses, and geolocation information. Data which you provide to Enjin when using our Services may also be captured by these third parties.
In some cases these third parties will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients.
We engage the services of a cloud storage provider in providing our Services. This means that the personal information we collect from you might be used, stored and/or accessed by our staff, members of our group, or suppliers outside of Singapore, such as in the European Economic Area ("EEA"), the USA, Canada, Asia Pacific, and other locations where our provider has servers. Further details on to whom your personal information may be disclosed are set out in section 4 (What personal information is shared with or accessed by third parties?).
Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting our DPO, whose details are set out at section 14 (Further questions and how to make a complaint), at any time.
We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
If you create an account to use our Services, we will process your personal information for as long as you retain your account with us and this will be deleted within 30 days of you closing your account. We will retain your IP address information on the basis of our legitimate interest of ensuring the security of our websites, apps and Services.
If you wish to remove your personal information from the Services (except for your IP address), you can close your account at any time.
You have certain rights in relation to your personal information. If you are located in the European Union, please refer to section 8.2 for information relating to your rights. If you are located outside the European Union, please refer to section 8.3 for information relating to your rights.
If you would like further information in relation to these or would like to exercise any of them, please contact our DPO, whose details are set out at section 14 (Further questions and how to make a complaint), at any time.
We will consider all such requests and provide our response within a reasonable period (and in any event within one (1) month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that (i) we require proof of identity before responding to any requests to exercise your rights and (ii) certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
If an exception applies, we will tell you this when responding to your request. We may request that you provide us with information necessary to confirm your identity before responding to any request you make.
If you are located in the European Union, you have the following rights:
If you are not located in the European Union, you have the following rights:
We also collect and use your personal information for undertaking marketing by email. We may send you certain marketing communications (including electronic marketing communications) if you have chosen to opt-in.
We will always obtain your consent to send you direct marketing communications where we are required to do so by law and if we intend to disclose your personal information to any third party for such marketing.
If you wish to stop receiving marketing communications, you can choose to opt-out of receiving messages from us or our Services by following directions on the bottom of the email message you receive.
Enjin recognizes the importance of children’s safety and privacy on the Internet. For this reason, and in compliance with certain laws, we do not intentionally collect personal information from children, nor do we offer any content targeted to children. We do not collect information relating to the age of individuals using our Services and, therefore, we recommend parents and guardians of children using our Services regularly clear their browser cache and/or browsing history to clear cookies. Please see our Cookies Policy for more information.
For some Services it may be possible for those under the age of 13 to register an account and access Services and other content (with parental or guardian consent). Where children under 13 sign up and use certain aspects of the Services, we rely on the checks carried about by our third party suppliers (for example, PayPal) associated with those aspects of the Services, to ensure appropriate parent/guardian consent has been obtained.
If you would like to review or amend your child's information, ask to have it deleted, and/or refuse to allow any further collection or use of your child's information, then please send an email to email@example.com. Please be sure to include your email address and a telephone number where we can reach you. To protect your child's privacy and security, we will take reasonable steps to help verify your identity before granting you access to the information that we collect and maintain about your child.
The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.
For this reason, Enjin is committed to protecting your personal information from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures. We secure your personal information via TLS, and use a secure service to prevent unauthorized access to data. Data is protected by encryption and secured through access control lists, security keys / tokens, IP whitelisting and by the use of username / password access. Enjin also carries out access audits of its staff in order to detect any unauthorized access.
In the course of provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our website and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorized access to it.
Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We require that you do not share your passwords with anyone else.
Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.
If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact our DPO, Oscar Franklin Tan, at firstname.lastname@example.org. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.
If you are an EU citizen, you may also make a complaint to the relevant data protection regulator under the EU's General Data Protection Regulation.