DISOBEY PRIVACY NOTICE

Last Updated: July 2023

1. Introduction

Disobey.GG Limited is a company incorporated & registered in England under company number 12223682 with its offices at Amelia House, Crescent Road, Worthing, England, BN11 1QR (“Disobey”, “we”, “us”, “our”). 

Disobey is a games marketing agency specialising in social media, community management & influencer campaigns.

Together, these activities are our “Services”. We also operate a website: https://www.disobey.gg/ (the “Website”). 

As part of delivering our Services & operating our Website, we may, from time to time, process certain data which relates to individuals who are:

• producing content for digital channels (“Content Creators”);
• individuals working for or on behalf of our clients (“Client Personnel”); 
• visiting our Website (“Website Visitors”); 
• applying for jobs via our Website (“Job Applicants”); &
• interacting with our social media channels (“Social Media Users”), 

 “you” & “your” shall refer to all/any of the above.

Disobey is committed to protecting & respecting your privacy. This privacy notice (“Privacy Notice”) explains the basis on which personal data we collect from you will be processed by us or on our behalf. 

Where we decide the purpose or means for which your personal data is processed, we are the ‘controller’ of your personal data. 

We may make changes to this Privacy Notice in future, which will be posted on this page. Where appropriate, we will notify you of changes via email.  

If you have any questions or comments about this Privacy Notice, please contact us at: privacy@disobey.gg

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2. Information we may collect about you

We may collect & process the following information, which may include your personal data.

Service Information

Information processed about Client Personnel in relation to the provision of Services to our clients 

We process certain information about Client Personnel when clients sign up for our Services. This may include their full name, the name of their employer (i.e., our client’s company name) & their contact details (which includes email address). 

When we provide Services to our clients in relation to a certain project, clients or their Client Personnel may share certain information with us about their project to help us deliver our Services. In some cases, this information may relate to or identify Client Personnel. For example, clients or Client Personnel may send us project-related information within onboarding documentation or via email. This may include budget information, a brand overview including logo(s), studio name(s), current marketing strategies, future marketing plans, trailer links, assets such as screenshots, audio files, or information on game mechanics or lore. 

Clients (or Client Personnel on behalf of a client) may be required to provide Service Information under a contract between us. If a client fails to provide this information when required, we may be unable to work with, or deliver our Services to, the client. 

Source: We obtain the information listed above either from Client Personnel directly or from the client for which they work. We may also conduct our own research to obtain project-related information listed above, such as trailers or game details, from publicly accessible sources.

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Channel & Media Information

Information processed in relation to social media account(s), store pages, content channels &/or websites

If Social Media Users post or upload any content, including content in relation to our Services or Website, on social media channels (such as Facebook, Twitter or Instagram), content channels (such as Twitch or YouTube), store pages or websites, this will be processed under these platforms’ respective privacy policies which may be found on their websites. 

Where Social Media Users follow us or interact with our content or choose to send us links to their social media accounts or channels, we may process personal data from their social media profiles (depending on their social media privacy settings). 

When providing the Services to our clients, Client Personnel may also directly provide us with certain information from their client’s social media account(s), store pages &/or websites, such as log-in details. 

Channel & Media Information may include personal data such as a client’s (which may identify or relate to Client Personnel) or Social Media User’s name (&/or their social media unique username), email &/or postal address, location, telephone number(s), URLs, gender, age, date of birth, images (including profile pictures), correspondence with us through those channels, general interests & preferences (e.g., Likes, Shares & Posts), statistics (subscribers, followers, view counts etc.) & any other personal data available on these platforms, accounts or channels. 

Clients (or Client Personnel on behalf of the client) may be required to provide Channel & Media Information under a contract between us. If a client fails to provide this information when required, we may be unable to work with, or deliver our Services to, the client.

Source: We may collect Channel & Media Information from Social Media Users & Client Personnel directly or, in the case of Client Personnel, from the client for which they work. We may also collect Channel & Media Information from the relevant social media platform(s), content channel(s) or other web page(s), as referred to above – this information may be available publicly depending on your privacy settings & the structure of the relevant platform, channel or webpage.

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Enquiry Information

Information provided by Website Visitors when submitting an enquiry on our Website‍

If a Website Visitor submits a general enquiry via our Website, we may process the following information about them: name (first name & surname), email address, company name, position, budget, website URL, the category of service to which the enquiry relates, how they heard about us & any other information they choose to provide us in the message text. 

Source: We collect Enquiry Information from Website Visitors directly.

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Job Vacancy Information

Information provided when Job Applicants respond to job vacancies published on our Website

We may ask Job Applicants for, or they may submit to us, certain information when they respond to a job vacancy or apply for a job through our Website. This will normally include their first & last name, email address, how they heard about the position, information relating to the Job Applicant’s pronouns (which does not allow us to make certain inferences about, or reveal information relating to, the Job Applicant’s health, sex life or sexual orientation), cover letter, resume (CV) &/or portfolio of their work (which may contain information such as their postal address, telephone &/or mobile phone number, date of birth, qualifications, details of their previous work &/or employment & other information they include in their CV), & other information such as why they want to work at Disobey, & other role-specific questions to better gauge their experience within the industry.

Job Applicants may be required to provide Job Vacancy Information, so we can consider their application & potentially enter into a contract with them. If a Job Applicant fails to provide us with this information, we may be unable to consider them for the job vacancy.

Source: We collect Job Vacancy Information from Job Applicants directly

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Analytics Information

Information collected about Website Visitors when they use our Website

We process Website Visitors' hashed IP addresses, which we share with Webflow (our third-party service provider). We also process certain additional information using cookies - see Section 10 (Cookies) below for further information.

Source: We collect Analytics Information either from Website Visitors directly or via the use of our third-party cookies - see Section 10 (Cookies) below for further information.

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Marketing Information

Information about Content Creators’ marketing preferences‍

We offer certain subscription services for Content Creators to sign-up to via an online form on our Website (to obtain games keys, sponsored opportunities & updates from us, for example), & may separately offer to inform Content Creators about the projects we are currently working on (if relevant to the Content Creators) & potential partnerships that may be of interest to Content Creators.  

When providing this type of service, we may process the following information about Content Creators: their name (first name), online alias, email address, URL links to their social media accounts (including Facebook, Instagram, Twitter & TikTok), content channels (such as Twitch & YouTube) or other websites or accounts, account & channel usernames, total follower count, top three game genres & any other information Content Creators provide about themselves (for example, hobbies, favourite shows, sports, fashion etc.), any other Media & Channel Information & the fact that they have provided, or declined to provide, consent to receive marketing from us. 

Source: We collect Marketing Information either from Content Creators directly or from the relevant social media platform(s), content channel(s) or other web page(s), as referred to above – this information may be available publicly depending on your privacy settings & the structure of the relevant platform, channel or webpage

Please note that we do not make any decisions based solely on automated processing, including profiling, that have legal or similarly significant effects on you.

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3. Why we collect information about you

To provide Services to our clients

We may use Service Information, Channel & Media Information & Enquiry Information to deliver Services to our clients as per the terms agreed between us. The processing of information in this way is necessary for us to understand how best we can support clients via the provision of our Services, communicate with clients & deliver our Services to clients.

This processing is also necessary for us to pursue our legitimate interests of: (i) improving the quality of our Services; & (ii) promoting Disobey’s commercial interests.  

Lawful basis under UK GDPR: performance of contract & legitimate interests (listed above).

To manage our relationship with our clients (& Client Personnel), Content Creators & Website Visitors 

We may process Service Information, Channel & Media Information & Enquiry Information so that we are able to properly respond to questions, enquiries, complaints & support requests from Client Personnel, Content Creators & Website Visitors. 

This processing is also necessary for us to pursue our legitimate interests of: (i) ensuring that we address any concerns or queries regarding our Services or Website; (ii) correcting any issues experienced in relation to our Services or Website; & (iii) improving the quality of our Services.  

Lawful basis under UK GDPR: legitimate interests (listed above).

To fill any job vacancies

We may process Job Vacancy Information so that we are able to take steps prior to entering into a contract with Job Applicants, including assessing their skills, qualifications & suitability for the role &/or communicating with Job Applicants about the recruitment process. We may also need to process this information to enter into a contract with Job Applicants. 

This processing is also necessary for us to pursue our legitimate interests of: (i) allowing us to manage the recruitment process more efficiently; & (ii) assessing & confirming a candidate’s suitability for employment & deciding to whom to offer a job.  

Lawful basis under UK GDPR: taking steps prior to entry into contract, &/or legitimate interests (listed above).

To maintain & improve our Website

We may process Enquiry Information & Analytics Information so that we can analyse Website Visitors’ use of our Website, & understand & resolve any issues relating to our Website. 

This may include sending information relating to any crashes or similar issues experienced by Website Visitors to a third party for further investigation. This processing is necessary for us to pursue our legitimate interests of: (i) ensuring that our Website functions properly so that Website Visitors & other users have the best experience when using it; (ii) improving the quality of our Website, & the experience of Website Visitors; & (iii) identifying & correcting any bugs on our Website.   

Lawful basis under UK GDPR: legitimate interests (listed above).

To inform Content Creators about products & services that may be of interest to them

Where Content Creators have consented, we may use Marketing Data to send Content Creators emails or contact Content Creators via social media to keep them informed about our news, updates, latest projects, sponsored opportunities & partnerships which may interest them. Where we rely upon their consent to do this, Content Creators can withdraw their consent at any time by sending an email to privacy@disobey.gg.

Lawful basis under UK GDPR: consent.

‍To conduct marketing campaigns

When we are either collaborating with a Content Creator, or exploring potential collaboration opportunities with a Content Creator, we may process their Content Creator Information in order to run marketing campaigns when providing our Services. 

The processing of this information in this way is necessary for us to provide our Services to our clients & collaborate effectively with Content Creators. We may use this information to carry out research on Content Creators to identify who may be the best fit for our clients’ game, product or campaign. If a Content Creator submits information on our website (such as username & social channels), we may use that to do additional research about their channels through third-party websites & review their engagement on social media.

This processing is also necessary for us to pursue our legitimate interests of: (i) improving the quality of our Services to our clients; (ii) improving the effectiveness of our & our clients’ relationships with Content Creators, & (iii) promoting Disobey’s commercial interests.  

Lawful basis under UK GDPR: performance of contract & legitimate interests (listed above).‍

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4. SPECIAL CATEGORY DATA

“Special Category Data” means information (a) revealing an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, (b) genetic data, (c) biometric data (when used for identification purposes), &/or (d) data concerning an individual’s health, sex life or sexual orientation. 

We will only process Special Category Data if it is appropriate given the nature of the circumstances & where we are legally able to do so. Under applicable law, we need to have further justification for collecting, storing & using Special Category Data. 

The table below summarises: (a) the Special Category Data which we may process in relation to Content Creators; (b) our purposes for processing this information; & (c) the legal grounds we rely on to do so. 

5. Data Sharing

Information will only be shared between us & third parties in the ways that are described in this Privacy Notice

Personnel: We seek to keep your information confidential but may disclose it to our personnel insofar as it is reasonably necessary for the purposes set out in this Privacy Notice.

Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via 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.

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 & law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; & 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 data 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 Disobey, our customers, or others.

Clients: We work with various clients when providing our Services. We select our clients carefully, & we provide them with as little personal data as possible in the context of our Services. For example, where we are providing Services to support a deal between an influencer & a brand, we may provide the brand with the influencer’s address so that it may post a sponsored item to the influencer.

Third-Party Suppliers & Sub-contractors: We use a range of suppliers & sub-contractors to operate our business & provide our Services. Suppliers who may receive your personal data for the reasons set out in this Privacy Notice include:

• IT Service Providers: We use a range of suppliers to provide our business infrastructure, including: email service providers; software providers including accounting software providers, e-signature software providers & business management providers; web hosts; IT support consultants; & suppliers of security technology. 
• Payment providers: Where you instigate a payment with us, your payment-related information will be processed by our payment providers, including invoicing software businesses.
  
  
• Delivery Providers: Where we need to ship something to you, your shipping-related information will be processed by a third-party delivery service.
• Professional advisors: We may share personal data with professional advisors, such as legal advisors, insofar as reasonably necessary to manage business risk, obtain professional advice, or for the establishment, exercise or defence of legal claims.
• Business support: We may share personal data with third parties who provide us with business-support services, in the context of recruitment.

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6. Your rights in relation to your personal data which we process‍

You have the following rights over how we process personal data relating to you, although each right is subject to certain qualifications, requirements & exemptions. You can contact us to make a request to exercise one of your rights (including by sending an email to privacy@disobey.gg).

• Right to be informed: A right to be informed about the collection & use of your personal data (as explained in this Privacy Notice).
• Right to access & rectification: A right to ask for a copy of data we are processing about you & have inaccuracies corrected.
• Right to object: A right to object to the processing of your personal data in certain circumstances.
• Right to erasure & restrict processing: A right to request the restriction, suppression or erasure of your personal data.
• Right to data portability: A right to obtain a machine-readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer.

Right to complain: You may make a complaint to a data protection regulator. Contact information for the Information Commissioner’s Office (the UK’s independent authority set up to uphold information rights) is available here: https://ico.org.uk/make-a-complaint/.

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7. Data retention

We will hold your personal data on our systems for as long as is necessary for the relevant purpose & to maintain business records for tax, legal & regulatory reasons or as otherwise described in this Privacy Notice.

To determine the appropriate retention period for personal data, we consider the amount, nature, & sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data & whether we can achieve those purposes through other means, & the applicable legal & regulatory requirements.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you), in which case we may use this information for research or statistical purposes.

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8. Security

We will take all reasonable technical & organisational precautions to prevent the loss, misuse or alteration of your personal data. 

Please be aware that although we endeavour to provide reasonable security for the information we process & maintain, no security system can prevent all potential security breaches.

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9. International data transfers

Our servers are located worldwide, including in the UK & USA.

Where we transfer your information outside of the UK, we are required to have agreements in place with the recipient which include standard data protection clauses adopted by the Information Commissioner’s Office. The intention of these clauses is to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by emailing privacy@disobey.gg.

It is possible that your personal data may be transferred outside of the UK by third parties, such as social media providers. We recommend that you refer to the privacy policies &/or terms & conditions of these third parties if you are concerned about your data being transferred internationally.

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10. Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners & operators of the site. The table below explains the cookies we use & why.

11. Children

We do not knowingly solicit data from, offer Services to or market to, children under the age of 18. 

If you are under 18, or if a parent or guardian becomes aware that their child has provided us with information, please contact us at privacy@disobey.gg.

12. Contact information

If you have any questions about this Privacy Notice, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us by emailing us at: privacy@disobey.gg.