Privacy Policy GDPR

Privacy Policy

Who we are

Our website address is: http://popcorngamer.com.

What personal data we collect and why we collect it

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Analytics

Who we share your data with

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments may be checked through an automated spam detection service.

GDPR Introduction

The EU General Data Protection Regulation (“GDPR”) came into force on 25 May 2018.

The new Regulation aims to standardise data protection laws and processing across the EU, giving people greater rights to access and control their personal information.

Our Commitment

PopcornGamer is committed to ensuring protection of all personal information that we hold, and to provide and to protect all such data. We recognise our obligations in updating and expanding this program to meet the requirements of GDPR.

PopcornGamer is dedicated to safeguarding the personal information under our control and in maintaining a system that meets our obligations under the new regulations. Our practice is summarised below.

How We Prepared for GDPR

PopcornGamer already has a consistent level of data protection and security across our organisation, but we have introduced new measures to ensure compliancy.

  • Information Audit — We carried out an audit of information previously held and ensured that it was compliant with the new regulations.
  • Policies and Procedures — we have revised data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:
    • Data Protection – our main policy and procedure document for data protection has been revised to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy and the rights of individuals.
    • Data Retention and Erasure – we have updated our retention policy and schedule to ensure that we meet the “data minimisation” and “storage limitation” principles and that personal information is stored, archived and destroyed in accordance with our obligations. We have procedures in place to meet the new “Right to Erasure” obligation.
    • Data Breaches – our procedures ensure that we have safeguards in place to identify, assess, investigate and report any personal data breach as early as possible. Our procedures have been explained all employees.
    • International Data Transfers and Third-Party Disclosures – where
      PopcornGamer stores or transfers personal information outside the EU, we have robust procedures in place to secure the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as binding rules, or standard data protection clauses for those countries without.
    • Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge
  • Privacy Notice/Policy – we have revised our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
  • Obtaining Consent – we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information
  • Direct Marketing – we have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
  • Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, we have developed stringent procedures for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
  • Processor Agreements – where we use any third-party to process personal information on our behalf (ie Payroll, Recruitment, Hosting, etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they meet and understand their/our GDPR obligations.

Data Subject Rights

We provide easy-to-access information via [our website, in the office, during induction, etc] of an individual’s right to access any personal information that PopcornGamer processes about them and to request information about:

  • what personal data we hold about them
  • the purposes of the processing
  • the categories of personal data concerned
  • the recipients to whom the personal data has/will be disclosed
  • how long we intend to store your personal data for
  • if we did not collect the data directly from them, information about the source
  • the right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
  • the right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
  • the right to lodge a complaint or seek judicial remedy and who to contact in such instances.

Information Security and Technical and Organisational Measures

PopcornGamer takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction.

GDPR Roles and Employees

PopcornGamer have designated [insert DPO/lead name] as our [Data Protection Officer (DPO)/Appointed Person] and have appointed a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. The team are responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR compliance, identifying any gap areas and implementing the new policies, procedures and measures.

PopcornGamer understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans.

If you have any questions about our GDPR compliance policies, please contact [Data Protection Officer (DPO)/Appointed Person].

Last reviewed 25 January 2019