What is your Privacy Policy?

Welcome to the Strategic Play® Group Ltd. privacy policy. Strategic Play respects your privacy and is committed to protecting your personal data. We want to play well with you and we want to be sure you understand the privacy policy we are following.

 

  1. Introduction

This privacy policy tells you how the Strategic Play Group uses your personal data when you visit our website, interact with us, and/or buy our goods/services.

It also tells you about your privacy rights and how the law protects you.

It is important that you read this privacy policy, together with any other privacy policies we may provide, so you are fully aware of how and why we are using your data.

This privacy policy was last updated on December 21, 2018.

If you have any questions or would like to exercise your privacy rights, please follow the instructions in this privacy policy. See: How to contact Strategic Play Group Ltd. about privacy, below.

  1. Our website and the Strategic Play Group 

Our website at Strategicplay.com and Strategicplaytraining.com (Web Pages), sells print goods and services aimed at business users, from startups and independent facilitators and management consultants to larger organizations. This website is not intended for children and we do not knowingly collect data relating to children.  Users must be over 18 years of age to use our Web Pages. 

When you purchase or interact with Strategic Play Group Ltd., you are working with two different legal entities:

  • Lloyd Smith Solutions, Box 200 Whistler, BC, Canada V0N 1B0, which owns the trade name Strategic Play® and
  • Strategic Play Group Ltd., located at #3-2131 Lake Placid Road, Whistler, BC, Canada, V0N 1B2
  • Strategic Play Group Ltd., is the data controller responsible for this website and any handling of personal data carried out by or on behalf of Strategic Play Group Ltd., is a data controller for any handling of personal data carried out by or on behalf of Strategic Play Group Ltd.

Strategic Play Group Ltd. and our licensed trainers work collaboratively to bring great goods and services to Strategic Play Group Ltd. customers all over the world and they may sometimes be acting as joint data controllers. When we mention “Strategic Play Group”, "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Strategic Play Group responsible for processing your data.

  1. Personal data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect a variety of information about our wonderful customers (you!) and visitors to the website. This personal data falls into these categories:

Identity Data includes title, first name, last name, username or similar identifier and an encrypted version of your login/password. If you interact with us through social media, this may include your social media username.

Contact Data includes a billing address, delivery address, email address, and telephone numbers.

Financial Data includes 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.

Profile Data includes your username and password, purchases, or orders made by you, preferences, feedback and survey responses, as well as any profile data we have added (for example, using analytics and profiling).

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.

Usage Data includes information about how you use our website, products, and services.

Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.

Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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. To provide better content and service, Strategicplay.com and the Strategicplaytraining.com website uses the web analytics service of our internet provider, Sencia. Sencia records basic interactions with our website and website forms. Sencia does not track your browsing habits across other third-party websites and all information about you that reaches Sencia contains no personal data about you.

However, if we combine or connect Aggregated Data with your personal data so 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 do not 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 and genetic and biometric data. Nor do we collect any information about criminal convictions and offenses.

Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and services you have asked for.

  1. How is your personal data collected?

We use different methods to collect data from and about you, including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, or through chat or social media.

This includes personal data you provide when you:

  • sign up to receive the Strategic Play newsletter;
  • make inquiries or request information be sent to you;
  • create an account on our website;
  • create designs for products on our website;
  • order our products or services;
  • ask for marketing to be sent to you;
  • engage with us on social media;
  • enter a competition, promotion or survey;
  • contact customer services;
  • leave comments or reviews on our products or services (please be kind!).

Automated technologies or interactions. As you interact with us, including via the moo.com website, we may automatically collect Technical Data about your equipment, browsing actions, and/or patterns. We may also collect Tracking Data when you use our website or when you click on one of our adverts (including those shown on third party websites).

Third parties or publicly available sources. We may receive personal data about you from various types of third parties, including:

  • Technical Data and/or Tracking Data from analytics providers, advertising networks and search information providers;
  • Contact, Financial and Transaction Data from providers of payment and fraud prevention services;
  • Identity and Contact Data from data partners;
  • Data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
  1. How we use your personal data
  • Where we need to perform the contract we are about to enter into or have entered into with you. For example, when you purchase our products that is a contract.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, when we carry out fraud screening as part of the checkout process.
  • Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.

Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent at any time.

See: Explaining the legal basis we rely on to process personal data, to find out more about the types of lawful bases that we will rely on to process your personal data.

  1. Explaining the legal bases we rely on to process personal data

 

The table here shows you a description of all the ways we plan to use personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

We do not carry out any automated decision making.

If you ever have any questions about this, all you have to do is ask. See: How to contact Strategic Play about privacy, below.

  1. Advertising, marketing, and your communications preferences

We may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you and tell you about them. This is what we call direct marketing.

We may carry out direct marketing by email, phone, text, or post. For example, you might have the Strategic Play newsletter hit your inbox or a cool promotion land on your doormat.

On our website, we always try hard to make it really clear what we are doing and what communications you will be sent, whether it is you deciding to sign up to the Newsletter or as part of creating an account or the purchase journey. And you have a right at any time to change your mind and say no thank you and opt out (but we’d be really sorry to see you go, so please gives us a chance by fine-tuning your preferences before really leaving us!). The easiest way to opt out is to use the unsubscribe link at the bottom of the communication, and you can do this anytime, but we hope you don’t.

  1. Disclosures of your personal data

We do not share your personal data with others unless:

  1. We are sending you products directly from the printer where the product is made and they need your address for shipping;
  2. We are registering your information with the LEGO® Systems Group in Denmark, with your expressed agreement;
  3. We are listing your name on our website to share with direct clients who are looking for facilitators like you, which you have also expressed agreement;
  4. The law otherwise requires it.

We may share personal data with the following categories third parties:

  • suppliers and service providers, such as technology service providers, payment processing and fraud prevention providers, manufacturers, and post and courier services;
  • Strategic Play Group affiliated companies;
  • auditors and professional advisers like bankers, lawyers, accountants, and insurers;
  • government, regulators, and law enforcement.

We may also share data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  1. Payment information

Strategic Play uses third party payment processors Monaris and PayPal to process payments made for products and services via the Website. All online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards (which are high!) and your billing information, which is only used by these payment processors for the purpose of performing fraud protection, is encrypted before being communicated to them. Subject to the below exceptions, your credit card details are communicated directly from your browser to these payment processors. Strategic Play never (ever!) sees your full Permanent Account Number (PAN). This means the payment form is either off-site or displayed in a frame on the payment page.

  1. Third-Party Links

This website may include links to third-party websites, plug-ins, and applications (for example, the ability to sign in with Facebook). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

  1. Data Retention 

We will only keep your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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

By law, for Canadian tax purposes, we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for seven years after they stop being customers.

In some circumstances you can ask us to delete your data; Please see: Your legal rights, below for further information.

In some circumstances, we may anonymize your personal data (so 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.

  1. Your legal rights

If the General Data Protection Regulation applies to you because you are in the European Union, you have rights under data protection laws in relation to your personal data:

  • The right to be informed. That is an obligation on us to inform you how we use your personal data (and that is what we are doing in this privacy policy);
  • The right of access. That is a right to make what is known as a ‘data subject access request’ for a copy of the personal data we hold about you;
  • The right to rectification That is a right to make us correct personal data about you that may be incomplete or inaccurate;
  • The right to erasure. That is also known as the ‘right to be forgotten,’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there is an overriding legal reason we need to keep it);
  • The right to restrict processing. That is a right for you in certain circumstances to ask us to suspend processing personal data;
  • The right to data portability. That is a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);
  • The right to object. That is a right for you to object to us processing your personal data. For example, if you object to us processing your data for direct marketing;
  • Rights in relation to automated decision making and profiling. That is a right you have for us to be transparent about any profiling we do, or any automated decision-making.

These rights are subject to certain rules around when you can exercise them. 

If you wish to exercise any of the rights set out above, please contact us at:  Hello@strategicplay.com

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. How to contact Strategic Play about privacy 

If you have any questions about this privacy policy, or would like to exercise any of your rights, please email us strategicplay%23com|hello or write to us with your letter addressed to: Data Privacy Manager, Strategic Play Box 220 Whistler, BC, Canada, V0N 1B1.

If you need help with our products and services, or this website generally, please contact us: strategicplay%23com|hello  

  1. A little request from us to you

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You can do this by updating your account.

  1. Changes to this privacy policy

The General Data Protection Regulation is new and we are still reviewing new bits of guidance about how businesses should follow it. So you may see little updates to our privacy policy over the coming months. Be sure to check in and have a read every now and then.

Thank you again for working and playing with us – we hope together we can build great things!