1. INTRODUCTION

When you supply any personal data to us we have legal obligations towards you in the way we use that data.  It is important that you read this Policy together with any other privacy notice or fair processing notices that we may provide on the Site at or around the time that we collect or process personal data about you (for example, fair processing notices that we may display to you at the time that you sign up to receive e-mail updates from us) so that you are fully aware of how and why we are using that data.  This Policy supplements other notices on our Site and is not intended to override or replace them.

By visiting or otherwise using our Site, you agree to its terms (including as amended from time to time) and this Privacy Policy. If, for any reason, you do not agree to the terms of this Policy, please stop using this Site.  We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to let users of the Site know. However, it is your responsibility to check this Policy before each use of the Site – for ease of reference the top of this Policy indicates the date on which it was last updated.

Please note that our Site is designed partly for children under the age of 13 (each “Child” or “Children ”). If you are under the age of 13, you may only use the Site and provide personal information if you have the consent of, and are supervised by, a parent or guardian. If we believe a child using the Site is under 13 we will not process any personal information of that child without the consent of the parent or guardian. If the user is 13 or over we will only collect and process personal information as the long as we believe the user understands what is involved.

2. MINORS

We take many special precautions to protect the privacy of children under 13.  At our websites through our apps intended for children, we do not collect personal contact information (like full name, birthdate, phone number or home address) from children without the consent of a parent or legal guardian, except in limited circumstances authorized by law. We collect some information (like IP address, mobile device UDID, operating system, etc.) automatically and use technology like cookies to provide functionality and support our operations. We do not permit interest-based advertising on Sites or Apps directed to children under 13 or where we have actual knowledge that a child is under 13. We do not ask for more personal information than is necessary for a child to participate in an activity.

We take steps to prevent children from posting or publicly disclosing personal contact information. Parents can ask us to update or delete their children’s information. We use technology, like cookies, to recognize visitors by their user name when they revisit our Site and to screen for age in accordance with the Children’s Online Privacy Protection Act (“COPPA”). We may also use technology for similar purposes in our Apps.

We also use technology to facilitate the ability to play games, to recognize returning visitors, for research, and for other purposes, including to screen under-age visitors from certain features or areas intended for older visitors, and to collect certain information automatically. We require our advertising service partners to comply with self-regulatory guidelines on targeted advertising. We do not permit interest-based advertising on Sites directed to children under 13 or where we have actual knowledge that a child is under 13.

3. WHAT INFORMATION DO WE COLLECT?

What is personal data?

Where this Policy refers to ‘personal data’ it is referring to data about you/your child from which you/ your child could be identified – such as name, date of birth, contact details and even IP address.

By law all organisations who process your/your child’s personal data in Canada are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the ‘Your Rights’ section of this Privacy Policy.

What types of data we collect from you when you use the Site?

The personal data we collect may include:

• Identity Data which includes your/your child’s name, date of birth and gender.
• Contact Data which includes your e-mail address, work address, work e-mail address and delivery address.
• Technical Data which includes your IP address, your login data and browser type and version.
• Usage Data which includes information about how you use the Websites.
• Marketing and Communications Data which includes your preferences in receiving marketing from us and our third parties.

4. HOW IS YOUR PERSONAL INFORMATION COLLECTED?

Direct interactions

When you use the Site to request marketing be sent to you, participate in social media functions, contact us by email or by post, take part in an online survey, enter into competitions or report a problem with a Site, we may collect, store and use the personal data that you disclose to us.

Automated technologies or interactions

We shall also collect information about you when you/your children visit and interact with the Site through the use of technologies such as cookies. The following are examples of information we may collect:

• information about your device, browser or operating system;
• your IP address;
• information about links that you click and pages you view on our Website;
• length of visits to certain pages;
• subjects you viewed or searched for;
• page response times;
• records of download errors and/or broken links;
• page interaction information (such as details of your scrolling, clicks, and mouse-overs);
• methods used to browse away from the page; and
• the full Uniform Resource Locators (URL) clickstream to, through and from this Website (including date and time).

We use the data described above for several different reasons. Firstly, we use it to ensure that the Site works properly and that you are able to receive the full benefit of it. Second, we use the data to monitor online traffic and audience participation across the Site.

Information we collect from other sources

From time to time we may also obtain personal data from other sources, for example your username, location and IP address whenever you/ your children view one of our YouTube videos whilst logged into your YouTube or Google account.

Updating your information

If you want to update the information you have previously given to us, you can contact us at info@campbonkers.com

5. HOW AND WHY DO WE USE YOUR PERSONAL DATA:

Lawful basis for processing your information

We will only use your/your children’s personal data when the law allows us to. Most commonly we will use your/your children’s personal data in the following circumstances:

• Where you have asked us to do so, or consented to us doing so;
• Where we need to do so in order to perform a contract we have entered into with you;
• Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and
• Where we need to comply with a legal or regulatory obligation.

Sharing your personal data

Depending on how and why you provide us with your/your children’s personal data we may share it in the following ways:

• we may share your children’s personal data with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries
• with selected third parties who we sub-contract to provide various services and/or aspects of the Site’s functionality, such as where third-party plugins provide functionality such as message boards or image hosting services (see “Service Providers” below); and
• with analytics and search engine providers that assist us in the improvement and optimisation of this Site as described above.
• We may also disclose your personal data to third parties in order to enforce or apply our Site’s terms of use or terms and conditions; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Links to third party sites

Where we provide links to third party websites, plug-ins and applications that are not affiliated with www.campbonkers.com such sites are out of our control and are not covered by this Policy. If you access third party sites using the links provided, the operators of these sites may collect personal data from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those websites.

6. FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will hold the personal information we collect on our systems only for as long as required to provide you with the services you have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain the personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. In some circumstances you can ask us to delete your/your children’s data: see ‘Your Rights’ below for further information. In some circumstances we may anonymise your/ your children’s personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

7. SECURITY

WSS takes the protection of your/your children’s information very seriously. We have put in place appropriate security measure to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including use of secure servers and passwords. Where we have given you a password that enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. YOUR RIGHTS

As a data subject you have a number of rightsin relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.

Right of Access

You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).

Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data. You can exercise this right at any time by writing to us by contacting us and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.

Your Right to Rectification and Erasure

You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”). You can exercise this right at any time by contacting us and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

Your Right to Restrict Processing

Where we process your personal data on the basis of a legitimate interest (see the sections of this Policy which explain how and why we use your information) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid. You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.

Your Right to Portability

Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format. Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.

Your Right to object to processing

You may object to processing of your personal data where we rely on legitimate interest for processing that personal data. We will comply with your request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.

Your Right to stop receiving communications

Where we send you e-mail marketing communications (or other regulated electronic messages) you have the right to opt-out at any time. You can do this by using the ‘unsubscribe’ link that appears in the footer of each communication (or the equivalent mechanism in those communications). Alternatively, if for any reason you cannot use those links, or if you would prefer to contact us directly – you can unsubscribe by writing to us at info@campbonkers.com and telling us which communications you would like us to stop sending you.

Your Right to object to automated decision making and profiling

You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.

Exercising your rights

When you write to us making a request to exercise your rights, we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity. It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information, then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you). If you have any queries regarding this Privacy Policy, if you wish to exercise any of your rights set out above or if you think that the Privacy Policy has not been followed, please contact us by emailing info@campbonkers.com.