Viker may change this Policy at any time in which case we shall notify you of any changes to this Policy. The changes will apply to your use of the Website and/or App and/or participation in any prize promotion (as applicable) after we have given notice. If you do not wish to accept the new Policy you should not continue to use the Website and/or App and/or participate in any prize promotion (as applicable). If you continue to use the Website and/or App and/or participate in any prize promotion (as applicable) after the date on which the change comes into effect, your use of the Website and/or App and/or participation in any prize promotion (as applicable) indicates your agreement to be bound by the new Policy.
For the purposes of data protection legislation, Viker is the controller for the processing of your personal data. Viker has notified the Information Commissioner’s Office (“ICO”) of its processing of personal data. Viker’s registration number is ZA493856.
This Policy was last changed on 10 May 2019.
SECTION A – Your use of the Website and participation in any prize promotions
1. Information which is collected when you use the Website: Viker may collect the following information from you via the Website if you choose to contact us via the Website, namely your name, phone number, e-mail address and details of your particular query.
2. Information which is collected when you participate in any prize promotion: Viker may collect the following information from you if you choose to participate in any prize promotion, namely any and all personal data made available via the applicable social media site that you have signed up to and via which you enter the applicable prize promotion, the contents of which will be determined by you but are likely to include your name, e-mail address and other information about you, together with any other information that we ask you to submit in order to enter the prize promotion and, if you are a winner, claim your prize.
3. Processing ground: Viker relies on the contractual necessity processing ground to collect the items of information listed in paragraphs 1 and 2 above, as this information is required in order for Viker to answer your particular query and/or for you to enter the prize promotion, including, if you are a winner, to claim the prize in question.
4. How the information about you on the Website and when entering any prize promotion is used: The information about you described in paragraphs 1 and 2 is used by Viker:
a. to provide technical support in relation to your use of the Website and its Apps, troubleshooting/answer your particular query and, if applicable, to enter you into the prize promotion and, if you are a winner, deliver the prize in question to you;
b. to use such information in anonymised form for its own research and marketing purposes; and
c. to share with third parties as described in paragraph 8 below.
SECTION B - Your use of any Viker App
5. Information which is collected by the App: Viker may collect the following information when you use one or more of Viker’s Apps:
a. for the Scratch Day and Spin Day Apps (the “RF Apps”), your name and e-mail address (collected via Facebook log-in, required for you to download and use the App) and (if applicable) any alternative e-mail address(es) (if provided to us when redeeming any Cashout, Reward and/or Prize);
b. for all its other Apps, Viker only collects personally identifiable information if you consent for the purposes of serving you more targeted adverts (see paragraph 7(b) below).
6. Processing ground: Viker relies on thecontractual necessity processing ground to collect the items of information listed in 4(a), as this information is required in order for Viker to provide additional services via the applicable RF App e.g., to allow you to collect virtual tokens and remember you the next time you log-in, as well as to provide you with the applicable Cashout, Reward and/or Prize. You are, however, able to access many of Viker’s Apps without providing such data. In addition, for each RF App, in order to serve personalised adverts, Viker relies on the consent processing ground as you have the opportunity to consent or withdraw your consent to your personal information being used in this way when first logging-in to the applicable RF App and at any time thereafter via the Menu settings in the applicable RF App.
7. How the information about you on the App is used: The information about you described in paragraph 5 may be used by Viker as follows:
a. to enable Viker to undertake administration tasks in relation to the management of the App and to provide the services that Viker provides via the App to you, namely to permit you to access and play mobile games via the App including, in the case of any RF App, to allow you to collect virtual tokens and remember you the next time you log-in as well as redeem any Cashout, Prize and/or Reward;
b. to (if you consent), serve you adverts that are more personalised to you;
c. to tweak, tune and facilitate the improvement of the App;
d. to provide technical support in relation to your use of the App and troubleshooting;
e. to prevent fraud or illegal activities;
f. to use such information in anonymised form for its own research and marketing purposes; and
g. to share with third parties as described in paragraph 8 below.
SECTION C - GENERAL
8. Sharing information with third parties: Viker shall not pass your information to any third party (other than as described in this paragraph). Your information may, subject to Viker’s obligations to comply with applicable data protection legislation, be shared with the following third parties:
a. your e-mail address with prize providers/gift card partners in relation to its RF Apps in order for Viker to be able to provide such prize/gift card to you;
b. if you consent when using any RF App, we will share certain personal information with our advertising partners in connection with the placing of personalised adds. You can remove your consent to this at any time via the Menu within the applicable RF App;
c. Amazon Web Services, which Viker uses to host the information collected;
d. having taken precautions to maintain the security of such information, Viker may share this information with its regulator;
e. in anonymised form, Viker may share the information with:
i. any third party, in relation to the sale of some or all of Viker’s business, or its assets, or as part of any business restructuring or reorganisation. Viker will take steps with the aim of ensuring that your rights continue to be protected if your personal data is transferred in accordance with this paragraph;
ii. data aggregators and app providers as part of an analysis of user metrics or sales performance (as per paragraph 5(b) above); or
iii. law enforcement agencies in compliance with law enforcement.
9. Links to third party websites and third party adverts:Viker is not responsible for the privacy policies and practices of other sites even if you access them using links from the Website or App. You should check the policy of each site you visit and contact its owner or operator if you have any concerns or questions. In addition, if you link to the Website or App from a third party site or via a social network (e.g. Twitter), Viker is not responsible for the privacy policies and practices of the owners or operators of that third party site and recommends that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
10.Security: Viker has implemented technology and policies to safeguard your privacy from unauthorised access and improper use.
11.Storage and Data Retention:We store your information in the EEA and, for the RF Apps and our Website, we retain your personal data for as long as you wish to make use of the Website and/or applicable RF App (as applicable) and for a maximum of 1 year after you stop using the applicable RF App and/or contact us via the Website. For entry into any prize promotion we will retain your personal data for the duration of the prize promotion and for up to 6 months thereafter. You can ask for your information in relation to any RF App and/or our Website to be removed at any time by e-mailing us at email@example.com or firstname.lastname@example.org.
SECTION D - Contact with Viker
12.Information Viker collects and uses if you contact us or make complaints: When Viker receives complaints by email it files any relevant document and may retain details of the complainant and other individuals identified in the complaint. Viker will only use this information to process the complaint. Viker shall retain information in relation to a complaint for 6 years after its closure, in a secure environment and access to it will be restricted on a ‘need to know’ basis.
SECTION E – Contact and Your rights
13.Viker Details:If at any time you would like to contact Viker you can do so by sending an e-mail to us at email@example.com or write to us at “Data Protection Query, Viker Limited, Puzzle London, 200 Union Street, London, SE1 0LX”. This is Viker’s registered address and we are a company incorporated in England and Wales with company number 06290437.
14.Your Rights:You can contact us using the details set out in the paragraph above if you wish to: (i) access a copy of the personal data that we hold about you; (ii) correct any items of personal data that we hold about you; and/or (iii) have any items of personal data that we hold about you erased or object to our processing of such items of personal data. You may also contact the ICO at any time.