Triumph Games
Privacy Policy
Last updated: 26th January 2024
These terms are made available by Triumph Games Limited (“Triumph” /
“we” / “us”). Our registered office is at DS House 306 High Street,
Croydon, Surrey, CR0 1NG. We are a company registered in England and
Wales, with company number 11767850.
This privacy policy (the “Privacy Policy”) applies and has effect in
respect of our website, including the online forums and communities (the
“Forums”) therein, if applicable, where we make this Privacy Policy
available (including, without limitation, the
website http://www.triumphgames.io/) (each a “Website”) and the email
mailing lists we may operate in connection therewith, if applicable (each
a “Mailing List”). Together, the Website, Mailing List and the Forums
are referred to as the “Online Services”.
If you have any questions or comments about this Privacy Policy, please
contact us at support@triumph-games.com.
You have the right to object to the processing of your personal
data in certain circumstances. Information in further detail about
your right to object, and your other rights, is set out below.
We are committed to protecting and respecting your privacy. The Privacy
Policy explains the basis on which personal information we collect from
you will be processed by us or on our behalf. Where we decide the
purpose or means for which personal data you supply through these
Online Services is processed, we are the “data controller.” We will
comply with all applicable data protection laws, including the General
Data Protection Regulation 2016/679 and the General Data Protection
Regulation as it forms part of the laws of England and Wales, Scotland
and Northern Ireland by virtue of section 3 of the European Union
(Withdrawal) Act 2018.
Please read this Privacy Policy carefully as it contains important
information about the following:
What information we may collect about you;
How we will use information we collect about you;
Whether we will disclose your details to anyone else; and
Your choices and rights regarding the personal information you
have provided to us.
This Privacy Policy forms a part of and should be read in conjunction with
our terms of use for the Online Service, where applicable.
The Online Services may contain hyperlinks to services owned and
operated by third parties. These third party services may have their own
privacy policies and we recommend that you review them. They will
govern the use of personal information that you submit or which is
collected by cookies and other tracking technologies whilst using these
services, and will also govern the services (such as, without limitation,
mailing lists) of those third parties that may be of interest to you. To the
maximum extent permissible by law, we do not accept any responsibility
or liability for the privacy practices of third party services.
We may make changes to this Privacy Policy in future, which will be
posted on this page. Please check this page from time to time to ensure
you are aware of any changes.
We may collect and process the following information which may include
your personal data (together, "Online Services Data”):
Information provided by you when using the Forums
(“Forum Information”)
In order to set up an account for you to use the Forums, where we make
Forums available, we may collect the following information from you:
first name and last name;
date of birth;
country;
console / platform preference;
username;
email address; and
password.
We may also generate a unique forum user ID for our use which identifies
your account (which would also be Forum Information).
Contact information provided by you when you contact us for
support
(“Contact Information”)
We may ask you for, or you may submit, certain contact information to us
whenever you contact us for support or assistance relating to the Online
Services or to submit a business-related enquiry to us. This may include,
without limitation:
your email address;
your company / employer; and
your name.
Information collected for the purposes of providing analytics
(“Analytics”)
We may collect technical information about your use of the Online
Services through the use of tracking technologies and analytics. Personal
data we may collect includes the following:
how many times you visit the Website;
which pages you go to;
traffic data;
IP and MAC address;
internet service provider;
your device operating system and version;
your device make and model;
the country of your device; and
identification of crashes and defects.
Contact information provided by you when you sign up to our
Mailing List
(“Mailing List Information”)
We may ask you for, or you may submit, certain contact information to us
when you sign up to our Mailing List. This may include:
your email address; and
your name.
Content created by our users which we host and display on the
Forums
(“User Content”)
When users submit their own User Content to the Forums, this content
may contain personal and non-personal information. This could include
information in or about the User Content, such as the location of a photo
or the date a file was created, or anything else a user decides to
communicate using these parts of our Online Services.
Please take care before posting content on the Forums and do not
post information you do not wish to be publicly accessible.
To provide the Online Services to you
We will process information about you (including the Forum Information
and User Content) for the purpose of delivering our Online Services to
you under the terms of use agreed between us (such as for our Website
and Forum). The processing of information in this way is necessary for us
to provide you with the Online Services – such as content posting
functionality / user account functionality in Forums, and to generally
ensure the Online Services deliver the features promised and work
properly. For this purpose, we rely upon the legal basis of performance of
a contract (being performance of the terms of use agreed between us
(either our express terms, or our implied terms if not expressly
provided)) and our legitimate interests (being our commercial interests in
providing enhanced services and functionality to you).
To help us improve the Online Services and fix any problems
We may process information about you (including the Forum Information,
Analytics and User Content) so that we can analyse and improve our
Online Services and fix problems. For this purpose, we rely upon the
legal basis of performance of a contract (being our terms of use (either
our express terms, or our implied terms if not expressly provided)).
This processing is also necessary for us to pursue our legitimate interests
of: (i) ensuring that our Online Services function properly so that you and
other users have the best experience when using our Online Services; (ii)
improving the quality of our Online Services and providing a better
experience to our users; and (iii) identifying and correcting any bugs in
the Online Services.
To respond to your enquiries and requests for support and to
enable you to use the Forums and Website
We may process certain of your information, including without limitation
your Contact Information, so that we are able to properly respond to your
enquiries and support requests in accordance with the terms of use
(either our express terms, or our implied terms if not expressly provided)
agreed between us. For this purpose, we rely upon the legal basis of
performance of a contract and also our legitimate interests, being our
commercial interests to respond to your queries and requests for
support.
To acquire new users and engage our current customers and users
Consent-based mailing lists
We may process Mailing List Information to make suggestions and
recommendations to you and other users of our Online Services about: (i)
news and updates relating to us, our partners, products, services,
content and games; (ii) games, content, goods and services that may
interest you; and (iii) other promotional activity and events we think may
be of interest for you.
To the extent required by law, we rely upon your consent in order for us
to undertake this data processing activity. You can revoke your consent at
any time by letting us know, including by emailing us.
‘Soft opt-in’ mailing lists
In some instances (such as with some of our existing customers) the law
may permit us to process your personal information in order to send
information to you by email that we think is of interest for you on the
basis of our legitimate interests, being our legitimate business interests
in marketing our activities and promoting the success of our business
and our games, products and services. We may process your Online
Services Data for this purpose, including without limitation your Mailing
List Information. If the information is not of interest for you, you can opt-
out at any time by letting us know, including by emailing us.
To prevent fraud and illegal activity
We may process personal data (being any portion of the Online Services
Data) for our legitimate interests of ensuring that use of the Online
Services is lawful and non-fraudulent, does not disrupt the operation of
our services, and does not harass our staff or other individuals, and also
for us to enforce our legal rights and to comply with our legal
obligations.
Where we reasonably believe that you are or may be in breach of any
applicable laws or our terms of use (either our express terms, or our
implied terms if not expressly provided), we may process your personal
information to inform relevant third parties such as law enforcement
agencies about the content.
To the extent permitted by law, we may disclose your identity and/or
contact information to third parties where your activities (such as your
forum posts) may infringe their rights including without limitation
intellectual property rights or privacy rights.
A cookie is a text file placed onto your device when you access our
Website. We may use cookies and other online tracking devices such as
web beacons, and flash object storage to deliver, improve and monitor
our Website, including in the following ways:
Authentication
To log you into our Forums and keep you logged in (where we provide
Forums).
Analytics
To help us understand how you use our Website, and how often, so we
can improve them to deliver a better experience for our users. To carry
out research and statistical analysis to help improve our content,
products and services.
The information we obtain from our use of cookies will not usually
contain your personal data. Although we may obtain information about
your device such as your IP address, your browser and/or other internet
log information, this will not usually identify you personally.
Our Website displays a notice alerting you to our use of cookies and other
similar technologies and linking to this Privacy Policy. By using our
Website and selecting the relevant affirmative notice option you agree to
our placement of cookies and similar technologies on your device, and
our use of cookies or similar technologies for the purposes described in
this Privacy Policy.
Please note that if you choose to disable cookies, or similar technologies,
on your device you may be unable to make full use of our Website (e.g.
regarding authentication cookies, where applicable for Forums - if
provided with a Website).
We may work with third parties who may also set cookies on our
Websites. For example, we apply the Google Analytics cookie on our
Websites in order to better understand usage of our Websites.
Google Analytics cookies via our Website will not usually be retained on
your device for longer than thirty (30) days.
If you want to learn about how to opt out of Google’s use of cookies,
please visit https://tools.google.com/dlpage/gaoptout/ for information
about Google’s opting-out browser tool. For further information please
visit the website of the relevant third party (e.g. Google). The Google
Analytics terms of service can be accessed
here: www.google.co.uk/analytics/terms/us.html. Google’s Privacy Policy
is available here: https://policies.google.com/privacy?hl=en-US
We will share your information with third parties only in the ways
that are described in this Privacy Policy
Group members, personnel, suppliers or subcontractors: We keep your
information confidential, but may disclose it to any member of our group
(which means our subsidiaries, our ultimate holding company and its
subsidiaries, as defined in section 1159 of the Companies Act 2006), our
personnel, licensors, suppliers and subcontractors insofar as it is
reasonably necessary for the purposes set out in this Privacy Policy.
However, this is on the basis that they do not make independent use of
the information, and have agreed to safeguard it.
Merger or acquisition: If we are involved in a merger, acquisition, or sale
of all or a portion of its assets, you will be notified via, account message
and/or a prominent notice on our website of any change in ownership or
uses of this information, as well as any choices you may have regarding
this information. Your information may become available to, or be
managed by, the relevant new party.
Required by law: In addition, we may disclose your information to the
extent that we are required to do so by law (which may include to
government bodies and law enforcement agencies); in connection with
any legal proceedings or prospective legal proceedings; and in order to
establish, exercise or defend our legal rights (including providing
information to others for the purposes of fraud prevention).
Enforcement: We may also disclose your personal information to third
parties in order to enforce or apply the terms of agreements, to
investigate potential breaches, or to protect the rights, property or safety
of Triumph, our customers, or others.
Analytics: We may disclose personal data for the purposes of analytics for
improving and optimising our Online Services and delivering a better
user experience.
In the event we wish to process your personal data for marketing
purposes and where not otherwise detailed in this Privacy Policy, we will
obtain your prior consent to process your personal data before doing that
where we are required to do so by law. In each relevant instance, if you
prefer that we do not process your personal data in that way, you can let
us know by simply using the relevant consent options, buttons or similar
choices we provide to you at the relevant time.
If you do not wish to receive promotional or other marketing material
from us or third parties then you can contact us
via support@Triumphgames.com and let us know that you no longer wish
to receive promotional or other marketing material.
We may use automated decision-making methods which do not involve
human involvement to process your information, but we shall do so only
in the ways that are described in this Privacy Policy.
8. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE
PROCESS RELATING TO YOU
You have the following rights over the way we process personal data
relating to you, as set out in the table below. We aim to comply with
requests without undue delay, and within one (1) month at the latest.
To make a request, please let us know by sending an email
to support@triumph-games.com.
Ask for a copy of personal data we are processing about you and
have inaccuracies corrected or request erasure
You have the right to request a copy of the personal data we hold about
you and to have any inaccuracies corrected. You can request a copy by
emailing support@triumph-games.com.
We will use reasonable efforts, to the extent required by law, to comply
with requests to supply, correct or delete personal data held about you on
our files (and request that any third parties to whom it has been
disclosed to do the same).
Object to us processing personal data about you
You can ask us to restrict, stop processing or delete your personal data if:
you consented to our processing the personal data and have
withdrawn that consent;
we no longer need to process that personal data for the reason it
was collected;
we are processing that personal data because it is in the public
interest or it is in order to pursue a legitimate interest of Triumph
or a third party, you don’t agree with that processing and there is
no overriding legitimate interest for us to continue processing it;
the personal data was unlawfully processed;
you need the personal data to be deleted in order to comply with
legal obligations; and/or
the personal data is processed in relation to the offer of a service to
a child.
You can request account deletion by sending an email
to support@triumph-games.com.
Obtain a machine-readable copy of your personal data, which you
can use with another service provider
If (i) we are processing personal data in order to perform our
obligations to you or because you consented and (ii) that
processing is carried out by automated means, we will help you to
move, copy or transfer your personal data to other IT systems.
If you request, we will supply you with the relevant personal data in
CSV format. Where it is technically feasible, you can ask us to send
this information directly to another IT system provider if you prefer.
Make a complaint to a Supervisory Authority
If you are unhappy with the way we are processing your personal
data, please let us know by contacting us via the support services.
If you do not agree with the way we have processed your data or
responded to your concerns, an alternative is to submit a complaint
to a Data Protection Supervisory Authority. Contact information for
the Information Commissioner’s Office, the UK’s independent
authority setup to uphold information rights, is available
here: https://ico.org.uk/.
We will hold your personal information on our systems for as long as is
necessary for the relevant service, or as otherwise described in this
Privacy Policy.
If you would like us to delete your Forum account or any User Content
that you have posted, please let us know by sending an email
to support@triumph-games.com. Please note that deletion of User
Content from a forum does not necessarily remove it permanently from
the public internet; please take care before making public posts as they
may be further disseminated or recorded by third parties over the public
internet.
We do not use our Online Services to knowingly solicit information from
or market to children under the age of 13. In the event that we learn that
we have collected personal information from a child under 13 years of
age we will delete that information as quickly as possible. If you believe
that we might have any information from or about a child under 13 years
of age please contact us at support@triumph-games.com.
We take commercially reasonable, appropriate technical and
organisational measures to ensure a level of security appropriate to the
risk that could be encountered via the use of our Online Services, taking
into account the likelihood and severity those risks might pose to your
rights and freedoms.
In particular, we will take precautions to protect against the accidental or
unlawful destruction, loss or alteration, and unauthorised disclosure of or
access to the personal data transmitted, stored or otherwise processed
by us. For example, our databases are limited to essential employees
only.
Please be aware that, while we make the security of our Service a high
priority, no security system can prevent all security breaches.
Unfortunately, the transmission of information via the internet is not
completely secure. We do our best to protect your personal data, but we
cannot always guarantee the complete security of your data transmitted
through our Service; subject to applicable law, the sharing of your
personal data with us and any transmission of the data is at your own
risk.
The data we collect from you may be transferred to, and stored at, a
destination outside the United Kingdom (“UK”). It may also be processed
by staff that operate outside the UK and work for us or our suppliers.
These staff may be engaged in the fulfilment of your orders, the
processing of your payment details, the maintenance of the Service, and
the provision of support services. We will take all steps reasonably
necessary to ensure that your data is treated securely and in accordance
with this Privacy Policy.
Where your personal data is transferred outside of the United Kingdom
to a territory not subject to an adequacy decision by the UK Government,
we have agreements in place with the relevant parties which include
either (i) standard data protection clauses adopted by the relevant data
protection regulator and approved by the UK Government or (ii) standard
data protection clauses adopted by the UK Government, to ensure that
appropriate safeguards are used to protect your personal data.
Alternatively, we may put in place other appropriate safeguards. If you
require more information about these safeguards, you can contact us
at support@triumph-games.com.
All questions, comments or enquiries should be directed to Triumph
at support@triumph-games.com. We will endeavour to respond to any
query or questions within three business days.
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