We know that you care about your personal data and how it is used, and we want you to trust that MiniChess uses your personal data carefully. This Privacy Notice will help you understand what personal data we collect, why we collect it and what we do with it. As you read our Notice, please keep in mind that it applies to all MiniChess Franchises and associated companies, MindCompany Franchise Holdings, MindCompany Unlimited, and The Entrust Foundation
Please take a moment to familiarise yourself with our privacy practices and let us know if you have any questions by sending us an email or submitting a request through the “Contact Us” form on our websites.
You have the right to object to certain uses of your personal data including the use of your personal data for direct marketing. Kindly email us should you have any questions.
WHO IS COLLECTING YOUR DATA
Any personal data provided to or collected by MiniChess is controlled by MiniChess Franchise Holdings, the data controller.
This Privacy Notice applies to personal data collected by MiniChess in connection with the services and products we offer. References to “MiniChess” in this Notice means MiniChess Franchise Holdings and any company directly or indirectly owned and/or controlled by MiniCHess Franchise Holdings that you are interacting with or have a business relationship with.
This Privacy Notice also applies to MiniChess’s marketing content, including offers and advertisements for MiniChess products and services, which we (or a service provider acting on our behalf) send to you on third-party websites, platforms and applications based on your site usage information. These third-party websites generally have their own Privacy Notice and Terms and Conditions. We encourage you to read them before using those websites.
WHAT PERSONAL DATA IS BEING COLLECTED?
Personal data means any information that can be used to identify directly or indirectly a specific individual. You are not required to provide MiniChess the personal data that we request, but if you choose not to do so, we may not be able to provide you with our products or services, or with a high quality of service or respond to any queries you may have.
We may collect personal data from a variety of sources. This includes:
Personal data you give us directly,
Personal data we collect automatically, and
Personal data we collect from other sources.
Personal data means any information that can be used to identify directly or indirectly a specific individual. This definition includes personal data collected offline through our Consumer Engagement Centres, direct marketing campaigns, sweepstakes and competitions, and online through our websites, applications, and branded pages on third-party platforms and applications accessed or used through third-party platforms.
You may be asked to provide your personal data when you are in contact with us. MiniChess may share your personal data with each other and other MiniChess associated companies and use it in a manner consistent with this Privacy Notice. We may also combine it with other information to improve our products, services, content, and advertising.
You are not required to provide MiniChess the personal data that we request, but if you choose not to do so, we may not be able to provide you with our products or services, or with a high quality of service or respond to any queries you may have.
WAYS IN WHICH WE COLLECT PERSONAL DATA
We may collect personal data from a variety of sources. This includes:
Personal data you give us directly. We collect data about how you use our services and products, such as the types of content you view or engage with, or the frequency and duration of your activities. We also collect personal data you provide us when you sign up for a marketing newsletter, complete a survey or register for an account to buy our products. In so doing, we may ask for personal data, such as your name, gender, date of birth, address, email address, telephone number or credit card details. Some MiniChess brands may collect “special categories of personal data” about you with your explicit consent. For more information on the special categories of data we collect and how we use it, please refer to the relevant section below.
Personal data we collect from other sources. We collect personal data from other sources including our trusted partnerships with third parties and where we operate MiniChess accounts on third-party platforms: For example, when you use the “like” functionality on Facebook or the +1 functionality on Google+. Additionally, we receive information about you and other visitors’ interactions with our advertising to measure whether our advertising is relevant and successful. We also collect information about you and your activities from a third party when we jointly offer services or products, or from third-party data enrichment providers who may deliver insights to MiniChess about the personal data we hold.
HOW DO WE PROTECT CHILDREN’S PRIVACY?
We understand the importance of taking extra precautions to protect the privacy and safety of children using MiniChess products and services.
Most of MiniChess’s websites are designed and intended for use by adults. Where one of our websites is intended for use by a younger audience, we will obtain consent from the person with parental responsibility before we collect personal data where it is required by applicable laws and regulations (the age at which consent is necessary varies from Country to Country).
If you are a child under the age where parental consent is required in your Country, you should review the terms of this Privacy Notice with your parent or guardian to make sure you understand and accept them. If we discover that we have collected personal data from a child without consent from a parent or guardian where such consent should have been obtained, we will delete that personal data as soon as practical. Access to certain parts of the MiniChess’s websites and/or eligibility to receive prizes, samples or other rewards are generally limited to users over a certain age.
We sometimes use your personal data to carry out age verification checks and enforce any such age restrictions.
WHAT PURPOSE DO WE USE YOUR DATA FOR?
We collect, process, and disclose your personal data only for specific and limited purposes. For example, to process your payments, to assess and handle any complaints, to develop and improve our products, services, communication methods and the functionality of our websites, to provide personalised products, communications, and targeted advertising as well as product recommendations to you.
We also create profiles by analysing the information about your online surfing, searching, and buying behavior and your interactions with our brand communications by building segments (creating groups that have certain common characteristics) and by placing your personal data in one or more segments.
Additionally, MiniChess processes your personal data also using automated means. An automated decision is a decision that is made solely by automatic means, where no humans are involved in the decision-making process related to your personal data.
We collect, process, and disclose your personal data for the following purposes:
To process your payments, if you purchase our products, to provide you with your order status, deal with your inquiries and requests, and assess and handle any complaints;
To process and answer your inquiries or to contact you to answer your questions and/or requests;
To develop and improve our products, services, communication methods, and the functionality of our websites;
For the purposes of competitions or promotions that you have entered;
To communicate information to you and to manage your registration and/or subscription to our newsletter or other communications;
To manage our everyday business needs regarding your participation in our contests, sweepstakes, or promotional activities or request;
To authenticate the identity of individuals contacting us by telephone, electronic means, or otherwise;
For internal training and quality assurance purposes;
To understand and assess the interests wants, and changing needs of consumers, to improve our website, our current products, and services, and/or developing new products and services; and
To provide personalised products, communications, and targeted advertising as well as product recommendations to you.
When we collect and use your personal data for purposes mentioned above or for other purposes, we will inform you before or at the time of collection.
Where appropriate, we will ask for your consent to process the personal data. Where you have given consent for processing activities, you have the right to withdraw your consent at any time.
In some cases, we rely on legitimate interest for processing your personal data. A legitimate interest could exist for example, when you sign up for a loyalty scheme with one of our brands and we use the personal data collected to conduct data analytics to improve our products or services. This ground will only be used where it is necessary to achieve a legitimate interest, for example, to assist in the performance of a contract, or to optimise service, and does not outweigh your rights as an individual. This legal basis will only be relied upon where there is no less intrusive way to process your personal data. We can assure you that if legitimate interest is used as a ground for processing your personal data, we will keep a record of this and you have the right to ask for this information.
We process your personal data to perform a contract to which you are or will be a party. For example, we need to process your personal data to deliver a product or a service you bought, to allow you to take part in one of our competitions, or to send you samples that you have requested.
We also process your personal data when we have a legal obligation (e.g., tax or social security obligations) to perform such processing. For example, a court order or a subpoena may require us to process personal data for a particular purpose, or we may be compelled to process personal data to report suspicious transactions under the local anti-money laundering rules.
MiniChess uses your personal data to build profiles. We create profiles by analysing the information about your online surfing, searching, and buying behavior and your interactions with our brand communications by building segments (creating groups that have certain common characteristics) and by placing your personal data in one or more segments. These segments are used by MiniChess to personalise the website and our communications to you (such as showing relevant content to you when you visit our site or in a newsletter to you), and to display relevant offers and advertisements from the MiniChess brands on the MiniChess sites, and via third-party websites. The segments can also be used for third-party campaigns on the MiniChess sites. MiniChess profiles your data where you have provided consent for us to do so; for example, accepting the setting of cookies on your browser online or signing up for email newsletters from one of our brands.
You can withdraw your consent to prevent your personal data from being used this way at any time by unsubscribing to the use of your email address if you have logged into one of our websites or signed up for any marketing newsletters.
By way of example –
- MiniChess collects data, with your consent, from:
- Our websites are about what you view and the way you interact with our content;
- The digital display advertising that we serve to you on social platforms and other publisher’s websites; and
- Forms you fill in online and send to us about what your interests are.
- We also track the products you buy when you click on one of our display adverts and go on to purchase something from a selection of our retail partners.
- If you have asked to receive emails or SMS communications from us, we track whether you open, read or click on the content to see what you are interested in so that we can give you more content that we think you are more likely to enjoy.
- We use this data to profile your likes and dislikes.
- Based on this profile information, we may also give you advertising that we think you will like and want to see as you view content from us or from our network of publishers that we advertise with. Sometimes, with your consent, we may use your current location to serve advertising to you that is to do with promotions or events that are happening nearby that we think you might be interested in.
- We may also use information you have provided to selected third parties and consented to be shared, like your age, gender, life stage, lifestyle, and wider interests to identify people who we think will have similar interests to you and who we believe will be interested in similar advertising.
In some instances, MiniChess processes your personal data using automated means. An automated decision is a decision that is made solely by automatic means, where no humans are involved in the decision-making process related to your personal data. For example:
MiniChess uses game simulations of science-based behavioral assessments and data science techniques to assess prospective employees. Candidates are required to play a set of games and the behavioral patterns exhibited during gameplay are assessed by a MiniChess customised algorithm to predict the candidate’s potential for a specific role. This algorithm is regularly tested to ensure it remains fair, effective, and unbiased.
We will not make decisions based solely on automated decision-making that have a significant impact on you. If we do so we notify you and provide you with clear information about our decision to rely on automated processing to make our decision and our lawful basis for doing so. For example, MiniChess processes your personal data using automated means only if it is necessary for the entering into or the performance of a contract with you, or when you have given your explicit consent.
You have the right not to be subject to a decision that is based solely on automated processing and which produces legal or other significant effects on you. In particular, you have the right:
to obtain human intervention;
to express your point of view;
to obtain an explanation of the decision reached after an assessment; and
to challenge such a decision.
WHO WILL IT BE SHARED WITH
As part of the MiniChess Group, we may share your personal data within the MiniChess Group and with selected third parties in the following circumstances:
- Third-party service providers. In order to carry out your requests, respond to your inquiries, fulfill your orders, honor coupons, provide you with samples, enable you to participate in sweepstakes, or make various other features, services, and materials available to you through our websites we share your personal data with third-party service providers that perform functions on our behalf, such as companies that: host or operate MiniChess’s websites, process payments, analyse data, provide customer service, postal or delivery services, and sponsors or other third-parties that participate in or administer our promotions. They have access to personal data needed to perform their functions but may not use it for other purposes. Further, they must process this personal data in accordance with this Privacy Notice and as permitted by applicable data protection laws and regulations.
- Other third-parties. Your personal data will also be used by us or shared with our sponsors, advertisers, advertising networks, advertising servers, social media networks, and analytics companies or other third parties in connection with marketing, promotional, data enrichment, and other offers, as well as product information.
- Business transfers. Your personal data will be used by us or shared with the MiniChess Group, primarily for business and operational purposes. As the MiniChess Group continues to develop the business, it may sell or purchase assets, subsidiaries, or business units. In such transactions, your personal data generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, you consent otherwise). If another entity acquires us, our businesses, or substantially all or part of our assets, or assets related to MiniChess’s websites, your personal data will be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such personal data will be considered an asset of ours, and as such it is possible they will be sold or transferred to third-parties.
- Legal disclosure. We may transfer and disclose your personal data to third-parties:
- To comply with a legal obligation;
- When we believe in good faith that applicable law requires it;
- At the request of governmental authorities conducting an investigation;
- To detect and protect against fraud, or any technical or security vulnerabilities;
- To respond to an emergency, or otherwise
- To protect the rights, property, safety, or security of third parties, visitors to MiniChess’s websites, MiniChess or the public.
INTERNATIONAL DATA TRANSFERS
MiniChess shares personal data within the MiniChess Group or with third parties for purposes described in this Privacy Notice.
MiniChess will only send personal data collected within a restricted legal framework, such as e.g. the European Economic Area (EEA) or Asian Pacific Economic Cooperation (APEC), to countries that do not have data protection laws that are considered to provide appropriate levels of protection in the restricted legal framework in circumstances such as:
To follow your instructions;
To comply with a legal duty; or
To work with our agents and advisers who we use to help run our business and services.
If we do transfer personal data outside of the restricted legal framework, MiniChess will make sure that it is protected in the same way as if it was being used in that restricted legal framework. We’ll use one of the following safeguards:
Transfer to another Country whose privacy legislation ensures an adequate level of protection of personal data similar or equivalent to the country it was collected in;
Put in place a contract with the third party that means they must protect personal data to the same standards as in the country the data was collected in.
HOW DO WE PROTECT YOUR PERSONAL DATA
MiniChess takes the security of your personal data very seriously. We take every effort to protect your personal data from misuse, interference, loss, unauthorised access, modification, or disclosure.
Our measures include implementing appropriate access controls, investing in the latest Information Security Capabilities to protect the IT environments we leverage, and ensuring we encrypt, pseudonymise and anonymise personal data wherever possible.
Access to your personal data is only permitted among our employees and agents on a need-to-know basis and subject to strict contractual confidentiality obligations when processed by third parties.
HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
We will keep your personal data for as long as we need it for the purpose it is being processed for. For example, where you make a purchase online with us we will keep the data related to your purchase, so we can perform the specific contract you have entered and after that, we will keep the personal data for a period that enables us to handle or respond to any complaints, queries or concerns relating to the purchase.
Your data may also be retained so that we can continue to improve your experience with us and to ensure that you receive any loyalty rewards which are due to you.
We retain the identifiable data we collect directly for targeting purposes for as little time as possible, after which we employ measures to permanently delete it.
We will actively review the personal data we hold and delete it securely, or in some cases anonymise it when there is no longer a legal, business, or consumer need for it to be retained.
WHAT ARE YOUR RIGHTS?
Your rights in relation to your personal data how it is processed. You can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can exercise your rights by sending an email to email@example.com or submitting a request through the “Contact Us” form on our websites.
Where we process your personal data, you have a number of rights over how the data is processed and can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can exercise your rights by sending an email to firstname.lastname@example.org or submitting a request through the “Contact Us” form on our websites.
- The right to be informed. You have the right to be provided with clear, transparent, and easily understandable information about how we use your personal data and your rights. Therefore, we’re providing you with the information in this Notice.
- The right to access and rectification. You have the right to access, correct, or update your personal data at any time. We understand the importance of this and should you want to exercise your rights, please contact us.
- The right to data portability. The personal data you have provided us with may be portable. This means it can be moved, copied, or transmitted electronically under certain circumstances.
- The right to be forgotten. Under certain circumstances, you have the right to request that we delete your data. If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with legal requirements. If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete, destroy, or permanently de-identify it.
- The right to restrict processing. Under certain circumstances, you have the right to restrict the processing of your personal data.
- The right to object. Under certain circumstances, you have the right to object to certain types of processing, including processing for direct marketing (i.e., receiving emails from us notifying you or being contacted with varying potential opportunities).
- The right to lodge a complaint with a Supervisory Authority. You have the right to lodge a complaint directly with any local Supervisory Authority about how we process your personal data.
- The right to withdraw consent. If you have given your consent to anything we do with your personal data (i.e., we rely on consent as a legal basis for processing your personal data), you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). You can withdraw your consent to the processing of your personal data at any time by contacting us with the details provided below.
- Rights related to automated decision-making. You have the right not to be subject to a decision that is based solely on automated processing and which produces legal or other significant effects on you. In particular, you have the right:
- to obtain human intervention;
- to express your point of view;
- to obtain an explanation of the decision reached after an assessment; and
- to challenge such a decision.
Further information and advice about your rights can be obtained from the data protection Regulator in your Country.