SECTION 1: DATA PRIVACY LAW AND YOUR DIGITAL RIGHTS

What is this Policy all about?

Welcome to our Privacy Policy! It’s great that you’d like to know more about how we keep your information safe. This policy will give you information about how we look after your personal data when you visit or use our applications (apps). The Privacy Policy also tells you about your privacy rights and how the law protects you. Finally, this Privacy Policy covers our online data collection activities.

This is our overall Privacy Policy. For some jurisdictions, additional country/state specific provisions apply.

In other words, if you’re looking for more information on how we collect, store, use and share your personal data, this is the place for you!

Your privacy rights

As a data subject you have the following rights in respect of the personal data we hold on you:

Request access to your personal data. You have a right to access the personal data we are keeping about you. In many cases this information is already present to you in your online services from us. Your right to access may, however, be restricted by legislation, protection of other persons’ privacy and consideration for the Oranta Digital business practices, know-how, business secrets and internal assessments.

Request correction of incorrect or incomplete data. If the data we have pertaining to you are incorrect or incomplete, you are entitled to have the data corrected, with the restrictions that follow from legislation.

Request erasure You have the right to request deletion of your data when:

the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
you withdraw your consent to the processing and there is no other legitimate reason for processing;
you object to the processing and there is no justified reason for continuing the processing;
or the processing is unlawful.

SECTION 2: PERSONAL DATA

What personal data does the Oranta Digital collect?

Personal data is any information about a person from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes your username and password.
Purchaser Data includes purchases or orders made by you, your interests, preferences, and feedback or survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, participate in sweepstakes and other prize competitions and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data because this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We use Pseudonymized Data in order to minimize the privacy impact to you.

Pseudonymization is a method that replaces or removes information in the dataset that identifies an individual but permits a data controller or third party to reidentify the personal data with reasonable effort. It is important to be aware that unlike anonymization, pseudonymization does not remove all identifying information from the data but reduces the linkability of a dataset with the identity of an individual.

We do not proactively collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, or genetic information, biometric data for identification purposes, or information about criminal convictions and offences.

How does the Oranta Digital collect personal data from you?

We collect personal data from the following sources:

Websites includes any websites operated by or for the Oranta Digital, including sites that we operate under our own domains/URLs and mini-sites that we run on third party social networks such as Facebook.
Mobile games/apps includes mobile games or applications operated by or for the Oranta Digital, such as smartphone apps.
E-mail, text and other electronic messages includes electronic communications between you and the Oranta Digital.

How does the Oranta Digital use your personal data?

Oranta Digital app or online channel

What you do	What we collect	Why we collect it	Legal Basis
Use a Oranta Digital app or online channel	Technical data; Usage data; Additionally, data is collected using cookies* on our apps or websites (to the extent you have consented to the use of cookies). See Section 3 of this Policy or our Cookie Policy for more information about how cookies work and what types of data they collect. *If a child under the age of 16 accesses an online channel that is designed for children by using an age gate, we will obtain parental consent before collecting any personal information from the child (see Section 4 in this Policy for further information).	To optimize the user experience and the functionality of our apps; To deliver tailored marketing, including retargeting, if you have provided us with your consent (see our Cookie Declaration for more information); To improve and tailor your experience on our apps, websites, and services; To ensure that content from our apps and websites is optimized for you and for your computer or device; To be able to generate statistics and insights based on Aggregated Data to understand the health of our business and measuring the effectiveness of our advertising campaigns and promotions; To give you relevant marketing both when engaging with us in our own channels as well as via third party channels (e.g. social media, search sites, market places); To find recruit potential new customers that look like our current customers.	Your consent, art. 6(1)(a), GDPR, in connection with our use of cookies (to the extent such consent is provided); Legitimate interest, art. 6(1)(f), GDPR. Our legitimate interest is to be able to optimize and improve our apps and online channels, to be as relevant to our consumers as possible in our marketing efforts both in our own channels as well as in third party channels;, to ensure that our apps and websites are running smoothly for consumers, and to ensure that we process no personal data of a child under the age of 16 without parental consent.

Digital Marketing communications (e.g email, SMS, push messages or similar direct marketing)

What you do	What we collect	Why we collect it	Legal Basis
Subscribe to one or more of our digital marketing communications where opt-in subscription is legally required; Have not opted out of receiving one or more of our digital marketing communications or our newsletters.	Marketing and Communications Data; Necessary Identity Data; Information about which type of marketing communication you open and how you engage with the content.	To be able to deliver our digital marketing communications to you; To run internal statistics and gain insights and to optimize and tailor both the content and delivery of our communications newsletter to those who want to receive it; To give you relevant marketing based on your interests and preferences both when engaging with us in our own branded channels as well as via third-party channels (e.g. social media, search sites, market places); To find/recruit potential new customers that look like our current customers (‘look alike’) or ensure that our current customers are not targeted with irrelevant marketing messages (‘suppression’).	Your consent, art. 6(1)(a), GDPR, which is provided upon your subscription to the marketing communication; Our legitimate interest, art. 6(1)(f), GDPR in understanding our marketing effectiveness outside our own channels (e.g. via social media, search engines or market places); Your consent, art. 6(1)(a), GDPR to allow us to target you with personalized marketing outside of our own branded channels (e.g. via social media, search engines or market places); Legitimate interest, art. 6(1)(f), GDPR. Our legitimate interest in providing you with relevant content of your marketing message based on aggregated insights from shoppers and users on our website; Legitimate interest, art. 6(1)(f), GDPR. Our legitimate interest is to get statistics for internal use to improve our products and services.

The Oranta Digital’ own social networks

What you do	What we collect	Why we collect it	Legal Basis
Interact with the Oranta Digital’ social networks	Information you have made available, which may include comments, reactions, sharing of our social media account posts or other user-generated content	To answer your questions; To report on and analyze user engagement on the platform; To give you the opportunity to influence which new products we launch.	Legitimate interest, art. 6(1)(f), GDPR, in connection with answering your questions and reporting and analyzing on user engagement; Performance of a contract, art. 6(1)(b), GDPR, which is our agreement with you about intellectual property rights assignment.

Third-party social networks

What you do	What we collect	Why we collect it	Legal Basis
Interact with third-party social networking features, such as ‘Like’ functions* *The social media platforms may use personal information collected from the Oranta Digital’ social network account on their platform for their own purposes as described in their own privacy policies.	Information you have made available, which may include demographic information about you and where you live, your comments, reactions, sharing of our social media account posts or other user-generated content; Analytical performance data for social media posts and digital ads.	To report on and analyze user engagement with the content posted on the platform(s); To give you the opportunity to influence which new products we launch.	Legitimate interest, art. 6(1)(f), GDPR, in connection with analyzing and reporting on user engagement and post-performance.

SECTION 3: COOKIES AND SIMILAR TECHNOLOGIES (‘COOKIES’)

Cookies are small data files that your browser places on your computer or device. A cookie itself does not contain or collect information. However, when it is read by a server via a web browser, it can help a website deliver a more user-friendly service – for example, remembering previous purchases or account details.

SECTION 4: INFORMATION FOR PARENTS

Keeping children safe online

We care deeply about making sure children are safe online and have extra privacy processes in place to make sure we’re keeping our younger fans safe when they’re using our online channels. In fact, some features have age gates to prevent children from inadvertently using such features. We also take all reasonable care to ensure that we don’t knowingly collect, store, use or process personal information from children who may use those features without proper parental consent.

We’ve joined a digital child safety program which audits our company on a yearly basis to make sure we follow the rules in the way we interact with children online.

When it comes to personal data, we consider anyone under the age of 16 years a child and seek parental consent.

When we do process personal information from children, we take extra steps to protect their privacy including:

• Making sure we tell parents what personal information we collect, store, use and process from their child and explaining whether we share the information;
• Meeting legal requirements by asking for parental consent to collect, use and process a child’s data and asking for consent to send their children information about our products and services;
• Limiting how we collect, store, use and process personal information from children so only data that is reasonably needed for them to take part in an online activity is collected;
• Giving parents access or the option to ask for access to personal information we’ve collected from their child – parents can also ask for their children’s personal information to be changed or deleted.

Collecting and using children’s information

While some of our websites, channels and apps are designed with families and users of all ages in mind, others are intended to be used mainly by children. Whenever we collect personal information from a child, we only keep the information for the time we need it to provide a service or for the time it’s legally required to be kept on record.

While children can choose whether to share their information with us, there are features of our websites that won’t function if they haven’t given us their information. Where personal information is needed for features to function, we’ll only ask for information that is reasonably required to take part in the activity.

Here are some examples of times when we collect children’s data:

When we collect location information. Some of our websites, channels and apps are designed for children. We request consent from a parent or guardian by email before collecting information on a child’s street name, address or coordinates. We do that because such information will effectively make us able to identify a specific child. On the other hand, we don’t require parental consent to collect information on a child’s city, country or region as long as it isn’t linked directly to the specific child. The reason for this is that such generic information will not make us able to identify a specific child. If you would like us to stop collecting this type of location information, you can adjust the settings on the device your child is using at any time. Alternatively, please contact our Customer Service team.

When we collect ‘persistent identifiers’. In order to give visitors to our online channels more relevant and personalized online experiences, we collect some types on information (e.g. information on IP addresses, mobile device identifier, browsers, internet service providers, referring pages, exit pages, visitor frequency, operating systems, date stamps, time stamps and clickstream data). We collect this information using technologies such as cookies, pixels, flash cookies, web beacons and other unique identifiers (which we define under the Cookie section of this Privacy Policy). We may collect this information ourselves or ask a third party to process the data on our behalf. We use this data to give children access to online features and activities, to customize content, to improve our online channels, to analyze the performance of our online channels and to create anonymous reports. If we ever want to collect children’s personal data for any reason, we would contact the child’s parent or guardian for consent in advance. A list of third-party operators who collect ‘persistent identifiers’ on our sites and apps can be found in our Cookie Policy and Cookie Declaration.

Parental choices and controls

At any time, parents or guardians can refuse to allow us to use and collect further personal information from their child. Parents or guardians can ask us to delete the personal information we have collected in connection with their child’s account from our records. As personal information is required for some services, deleting a child’s records may result in an account, membership or service being unavailable to the child in the future.

SECTION 5: INFORMATION FOR KIDS

This Privacy Policy tells you how we use your personal data, so you know what happens with it when you give it to us.

Sometimes there are links to other pages. You might want an adult to help with these because they can sometimes be confusing.

Personal data? What’s that?

Anything that can be used to identify you is your personal data. You might already know this could be things like your name or a photo of you, but it is also things like your email address or online username.

If you want to know more, please ask an adult to help you read the entire Privacy Policy.

Personal data? What’s that?

The main reason we need to use your personal data is to know who you are.

If you are logged in to one of our apps or games, we use your personal data to keep track of your game progress, to help you stay connected with your friends in the app or game.

If we don’t have your personal data, it means we might not be able to do certain things for you. We might not be able to remember how far you made it in a certain game, or let you upload photos to share with friends.

If you want to know more about what we are doing with your personal data, you can ask an adult to read the full Privacy Policy with you to help you understand the details.

So, can you just use my personal data for anything?

Nope! We can only use your personal data for certain reasons.

We provide a lot of online services, and there are some rules that say we need to use your personal data to do our work and deliver the service to you, and we can do this without asking you first.

Other times, we need to get consent from your parents. If you or your parents (or guardians) say no then we won’t (and can’t) use your personal data.

Can anyone else see my personal data?

Sometimes we need to share your personal data to do our work. We’re very careful about how we do this, which means there are even more rules.

We might need to share your data with your family if they are helping you. Also, we might need to share your data with other people. Please ask an adult to help you read our full Privacy Policy and Cookie Policy and Cookie Declaration.

Do you keep my personal data forever?

We are only allowed to keep your personal data for as long as we need it. Depending on the circumstances, this period can vary.

Do I have a say in what happens to my personal data?

Yes you do. You have what we call ‘rights’ when we use your data. One of these is the right to know what we do with it. That’s what this page is for.

You can ask us to tell you what personal data we have about you, or you can tell us to stop using it or delete it. If your personal data is wrong or incorrect, you can tell us and we will fix it.

The rights you have depend on what we use your data for, and there is a lot more information in this Privacy Policy. Please ask an adult to help you read it.

About our website

Like lots of websites, our website downloads tiny files called ‘cookies’ onto your computer. These help our website to work properly for you.