For the purpose of the Data Protection Act 2018 and the General Data Protection Regulation 2016/679 (both “Data Protection Law”), the data controller is MP Entertainment Ltd (“Us”, “We”).
We are committed to protecting and respecting the privacy of all adult or guardian users (“You”) and the privacy and protection of any child (of any age; “Child”) who interacts with the services or is processed as part of them. This policy sets out the basis on which any of your or your family’s personal data that we have received, by any means, will be processed by Us, including through interaction with any representatives of Santa HQ, including “Santa”. Please ensure that you understand and agree to the content of this policy when using the Santa HQ application (“App”). Where you do not agree, please stop using the App immediately.
INFORMATION WE COLLECT ABOUT YOU
Personal Data provided by you
“Your Personal Data” may include but not be limited to the following for you: name, email address, residential address, address, telephone number, photograph, personal description, relationship to any child enrolled for the App experience etc.
The “Child’s Personal Data” may include the following in respect of any person who is under the age of 18, or 13, who will be using or participating with the App: name, photograph, information such as interests, hobbies, stories, activities, wish-list of presents, any information voluntarily disclosed by You or the Child as part of interaction with the App whether through the electronic interface or engagement with Santa directly etc.
“Personal Data” shall be considered as including Your Personal Data and the Child’s Personal Data.
In using the App, we may ask You:
- to provide some of Your Personal Data in order to sign up for our mailing list, marketing and promotional materials, set up an account, request a call-back, information or other mode of contact, administer our services to clients’ personnel.
- or the Child to provide some of the Child’s Personal Data in order to interact with the App, including disclosing information as part of activities (photos, stories, activities etc.) and request and participated in a call-back by Santa, including video calling.
We will never ask you to provide or ever use any sensitive personal data in relation to:
- Your Personal Data, such as your political opinions, medical information, sexual orientation, racial or ethnic origin etc.
- Child’s Personal Data, including medical information etc.
Personal and Other Data collected while using our App
We may use third party application analytics partners where needed to enhance the performance of the App, in which case such information shall be made available to You.
We reserve the right to record and monitor the Video Call for training and quality purposes.
USES MADE OF THE INFORMATION
We will only use Your Personal Data as strictly required for the following legitimate purposes in order for us to carry out our business, to:
- provide direct marketing where you have explicitly consented to receive such communications or are the personnel of our client or supplier;
- notify you of service information, including: upcoming and past activities, communications regarding scheduled times for video calls with Santa;
- share Your Personal Data as required by the section ‘Sharing Your Personal Data’ below;
- respond to correspondence or contact initiated or requested by You;
- improve the functionality, performance, efficiency or usability of the App, customer platforms, technology development or our marketing processes or functions;
- obtain information about our services in order to improve service delivery.
We will only use the Child’s Personal Data as strictly required for the following legitimate purposes in order for us to carry out our business, to:
- ensure that the services relating to the App operate as anticipated, such as technically hosting the Child’s Personal Data within the App during the Christmas period, tracking and reviewing the completed activities and carrying out scheduled video calls;
We will only use your Other Data as strictly required for the following legitimate purposes in order for us to carry out our business, to:
- administer the App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- improve the App to ensure that content is presented in the most effective manner for users and their computers;
- allow you to participate in interactive features of our service, when you choose to do so;
- part of our efforts to keep the App safe and secure;
- measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to You;
- make suggestions and recommendations to you and other users of the App about goods or services that may interest You.
We will not use Your or the Child’s Personal Data to make automated decisions about you which do not require human intervention.
We will retain Your Personal Data for a period of no longer than five years as needed to support the service bought by You under the App. This in no way limits your rights to request the deletion, correction or discontinued use of Your Personal Data at any time, per the ‘Your Rights’ section.
We will delete all of the Child’s Personal Data by 31st March 2021. However, You may request the deletion of the Child’s Personal Data at any date prior to this, per the ‘Your Rights’ section.
DISCLOSURE OF YOUR INFORMATION
You agree that we have the right to share Your, your Other or your Child’s Personal Data with:
- our third-party partners and suppliers who are required to provide the services under the App, for the below defined purposes, including:
- Made by Prism: application developers for the App;
- Ministry of Fun: personal-relations and events agency facilitating the services provided by means of the App; and
- a number of independent contractor actors performing their role as Santa;
- Digital Ocean; hosting provider for the App; and
You agree that we have the right to share Your, your Other or your Child’s Personal Data:
- where you explicitly consent;
- if we are under a duty to disclose or share such Personal Data in order to comply with any legal obligation (such as child protection).
- analytics and search engine providers that assist us in the improvement and optimisation of the App (however, in such case we would not provide information about any single identifiable individual, but provide high-level statistical information such as the number of men, women, age groups etc.);
- in the event that we sell or buy any business or assets, in which case we will disclose your Personal Data to the seller or buyer of such business or assets;
- if our company, or substantially all of its assets, are acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets;
- if we are under a duty to disclose or share Personal Data in order to comply with any legal obligation (such as fraud prevention), or in order to enforce or apply our terms and conditions.
TECHNICAL PROTECTION OF PERSONAL DATA
We use third-party hosting and platform providers to host the App. Therefore, the Personal Data may be transferred to and stored in and outside the European Economic Area (“EEA”); which may be the United Kingdom and United States of America. The primary location of data hosting is within London and Amsterdam, however technical support is provided by the third party specified above, within locations outside the EEA. We have undertaken a review of the nature of any Personal Data processed outside the EEA as to the risk of harm to You and the Child and consider that this is low, therefore use of Our partners and third parties is suitable, appropriate and proportionate.
By submitting Your and/ or submitting/ permitting the submission of the Child’s Personal Data, you agree to this transfer, storing or processing by way of internet transmissions of Personal Data. While Personal Data cannot be guaranteed to be safe and free from risk of accidental disclosure, loss or destruction, We take all reasonable steps in accordance with good industry practice and in accordance with the Data Protection Laws to protect Your Personal Data, and in particular the Child’s Personal Data.
As a user of the App and parent or guardian of the Child, you have the right to request:
- a copy of any/ all of Your Personal Data and the Child’s Personal Data, we hold about You or the Child;
- us to correct any inaccuracies or update out of date Personal Data and
- that we delete any of Your or the Child’s Personal Data at any time;
- transfer Your Personal Data to another service provider.
You can exercise these rights at any time by contacting us at the below email.
You are also entitled to request that we stop sending you marketing materials or contacting you for any direct marketing purposes. Please note that where we continue to provide you services or, we may still contact you with service-related information but these will not amount to marketing.