GINGER GM
PRIVACY POLICY
The purpose of the present document is to define how GingerGM collects, shares and uses your (i.e. User's) personal information via https://gingergm.com/ (the “Website”).
For the purposes of the data protection legislation,Ginger GM Limited, a company organized and existing under the laws of United Kingdom with its principal place of business located London Mindsports Centre 21-23 Darling Road, Hammersmith, London, United Kingdom, W6 0JD (“GINGER GM”, “we” or “us”) is the “data controller” (the company who is responsible for, and controls the processing of, your personal data).
If you are aged 16 or under, you must ensure that we have your parent/guardian's permission before you provide any personal information to us (including creating an account).
We consider the privacy and security of personal information of our customers and affiliates the issue of utmost importance and value, and therefore, will do everything in our capacity to safeguard it. The present policy shall be applicable to all customers applying for our products and services, as well as all mentors and other members accessing our website or using our mobile application.
INFORMATION WE COLLECT
Additionally, we will obtain information you provide to us:
- Payment information and transactions: to take payment for purchases and charge the correct amount of VAT (if applicable) we need to request and store your physical address information, after any purchase, we keep a record of the transaction.
- Shipping information: to ship physical products we need to request and store your physical address information.
- Communications with us: you may provide information when contacting us for support, speaking with us via social media or when you submit a review, and we may keep records of that communication.
We may monitor your use of GINGER GM through the use of cookies and similar tracking devices. For example, we may monitor how many times you visit, which pages you go to, traffic data and location data. This information helps us to build a profile of our users, which we use to help improve the way we deliver services to you. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. For further information on our use of cookies, please see our Use of Cookies section below.
HOW WE USE YOUR PERSONAL DATA
- facilitating subscriptions, and digital chess content purchases;
- billing you;
- to help us identify you and any accounts you hold with us;
- Administration;
- fraud prevention and detection;
- customising GINGER GM and its content to your particular preferences;
- to notify you of any changes to GINGER GM or to our services that may affect you;
- statistical analysis; and
- improving our services.
- research, and behavioural analysis;
- customer profiling and analysing your purchasing preferences;
- marketing—see Marketing and opting out, below;
- customising GINGER GM and its content to your particular preferences.
MARKETING AND OPTING OUT
If you have given permission, we may contact you by email about products we think may be of interest to you. If you prefer not to receive any direct marketing communications from us, you can opt out at any time. For more details see Your rights, below.
DISCLOSURE OF YOUR PERSONAL DATA - OUTSIDE GINGER GM
To achieve the purposes mentioned in this Privacy Policy and Notice and to the extent necessary, we may disclose your personal data to GINGER GM's agents and service providers, other companies within the Play Magnus' group, hereunder affiliates, as well as GINGER GM's agents and service providers (acting as processors and sub-processors) that provide us with support in the services that we offer you. These third parties may include, amongst others, financial institutions and payment service providers, technological and analytical service providers, advertising and marketing related partners and service providers.
For service efficiency purposes, some of these providers are located in territories outside the EU/EEA, and from time to time we may transfer your personal data to a third country not being approved by the European Commission as a safe country for such transfer (adequacy decision). Whenever applicable GINGER GM will use the Standard Contractual Clauses to ensure an equivalent level of protection as granted within the EU/EEA or other lawful grounds for carrying out said transfer.
KEEPING YOUR DATA SECURE
We will use appropriate technical and organizational measures to safeguard your personal data, for example:
- access to your account is controlled by a password and username that are unique to you; and
- we store your personal data on secure servers.
- Ensure nobody else will use GINGER GM while you are logged into your account (we advise our users to take extra care when using public computers/devices and to NOT leave themselves logged in; it is your responsibility to ensure this does not happen);
- Log out and exit your account on GINGER GM when you are not using it, on any private and/or public computer or device; and
- Keep your password and any account details or access details secret and to yourself.
PROFILING
We may use profiling techniques to propose to you certain content types or titles. We do this on the basis of your usage patterns of GINGER GM, including previous purchases.
USE OF COOKIES
A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our website. We use cookies on GINGER GM to:
- recognise you whenever you visit GINGER GM (this speeds up your access to the website as you do not have to log on each time);
- obtain information about your preferences;
- carry out research and statistical analysis to help improve our content, products and services and to help us better understand our visitor requirements and interests;
- make your online experience more efficient and enjoyable.
In most cases we will need your consent in order to use cookies on GINGER GM. This is done through a cookie banner included at the bottom of the GINGER GM's website landing page, where you will be asked to accept or decline cookies which are set for purposes related to marketing and personalisation. If you change your mind in the future about letting us use cookies, you can modify the settings on our webpage or in your browser to reject cookies or disable cookies completely.
DESCRIPTION OF COOKIES
The table below is designed to provide more information about the cookies:
| Cookie | Owner | Purpose |
|---|---|---|
| _gid | Google analytics | Track page views |
| _ga | Google analytics | Calculate visitor, session and campaign data for the sites analytics reports |
| _gat | Google analytics | Throttle request rate |
| __stripe_mid | stripe | Fraud prevention |
| __stripe_sid | stripe | Fraud prevention |
| fcsid | foxycart | Payment processing |
| m | strip | Fraud prevention |
| __Secure-next-auth.callback-url | GingerGM | authentication |
| __Host-next-auth.csrf-token | GingerGM | authentication |
| _drip_client | Drip | Marketing emails (opt-in only) page views |
| PayPal | PayPal | Payment processing |
| fetchapp | FetchApp | Order details |
HOW TO TURN OFF COOKIES
To opt out of Google Analytics, visit this webpage -https://tools.google.com/dlpage/gaoptout.
The third-party vendors, including Google, whose services we use
- will place cookies on web browsers in order to serve ads based on past visits to our website.
- Third party vendors, including Google, use cookies to serve ads based on a user's prior visits to your website. This allows us to make special offers and continue to market our services to those who have shown interest in our service.
INFORMATION ABOUT OTHER INDIVIDUALS
- give consent on his/her behalf to the processing of his/her personal data; and
- receive on his/her behalf any data protection notices.
DO NOT USE GINGER GM FOR PRIVATE AND SENSITIVE DATA
GINGER GM is a tool to help you improve your chess learning. We do not wish for GINGER GM to be used for the processing of any sensitive data. Do not use GINGER GM (including its messaging function) to share with any user any personal contact information like your phone number or street address. Do not use GINGER GM to send or store any item revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
LINKS TO OTHER SITES
GINGER GM does and may contain links to other websites. This Policy applies only to our website,https://gingergm.com/, so when you visit other websites please read their privacy policies, as we cannot accept any responsibility for breaches or issues you may have in relation to privacy once you leave our website.
WHAT IS THE LEGAL BASIS FOR OUR PROCESSING YOUR PERSONAL DATA
In some cases, the legal basis for the processing of your personal data is your consent. This is the case, for example, if you agree to us emailing you with marketing information. Any consent you provide may be withdrawn at any time by emailingdpo@playmagnus.com.
In other cases, the processing will be necessary for the purposes of our providing you with the Services as referred to in our Terms of Service.
Also, we may process personal data in accordance with our legitimate interest in engaging, providing and developing our services to you and other users – provided that those interests are not outweighed by your rights and interests. If you think that your rights and interests do outweigh our legitimate interests in providing our services, please let us know by emailing us atdpo@playmagnus.com.
We may also process your data where:
This is necessary to allow us to comply with our legal obligations; or
If you have previously given consent to our processing your data (for example, in relation to our sending you marketing information by email) you can freely withdraw such consent at any time. You can do this by emailing us atdpo@playmagnus.com. If you do withdraw your consent, and if we do not have another legal basis for processing your information, then we will stop processing your personal data. If we do have another legal basis for processing your information, then we may continue to do so subject to your legal rights. More details about your data protection rights are set out in the Your Rights section below.
YOUR RIGHTS
You have the right to access information we hold about you, together with an explanation of the categories of data being processed, the purposes of such processing, and the categories of third parties to whom the data may be disclosed.
If you wish to exercise this right, please send a request todpo@playmagnus.com.
You also have the following rights:
- The right to require us to rectify any inaccurate personal data concerning you.
- The right to be "forgotten" by us and have us erase any personal data we hold about you, if it is no longer necessary for us to hold the data for purposes of your use of the Service.
- The right to object to us using your data for the purposes of profiling you or making automated decisions about you. We may use your data to determine whether we should let you know information about the Service which might be relevant to you. Otherwise, the only circumstances in which we will do this is to provide you with the GINGER GM service.
- The right to ask us to port your data to another service (if technically feasible) or to provide you with a copy of data we hold about you in a structured, commonly used machine-readable format so that you can provide it to them. We will do so to the extent that we are required to under applicable laws, but not to the extent that this involves disclosing data about any other individual.
- You can also exercise these rights at any time by contacting us atdpo@playmagnus.com. To the extent that it does not involve disproportionate effort on our part, if you exercise any of the above rights we will tell any third parties to whom we have passed your data.
HOW LONG WE KEEP YOUR DATA
We will retain personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
OTHER IMPORTANT PROVISIONS
If we change our Privacy Policy, we will notify you on the changes. You should check this page occasionally to ensure you are happy with any changes to this policy.
OUR CONTACT DETAILS
We welcome your feedback and questions. If you wish to contact us please do it by using the message feature available on the Website or by clicking on “Support” on the homepage. If you wish to contact us regarding any privacy concerns, please send an email todpo@playmagnus.com or you can write to us at Tordenskiolds gate 2, 0160 Oslo, Norway.
Last update of this Privacy Policy: November, 2022.
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