Privacy Policy

PRIVACY POLICY

LAST UPDATED: October 22nd, 2024

Welcome to Voldex Entertainment Ltd’s privacy policy.

We are Voldex Entertainment Ltd (“Voldex”, “we”, “us”, or ”our”) as the context dictates). Our company registration no. is 14559649 and our registered address is at Duo, Level 6, 280 Bishopsgate, London, EC2M 4RB, United Kingdom.

We are registered with the Information Commissioner’s Office (ICO): [ZB756439].

We are the controller of the personal information we process about or relating to you. In this privacy policy, references to “your personal information” and “personal information about you” includes personal information relating to you.

This privacy policy applies to individuals who visit our website at, https://voldex.com/ (the “Website”), engage with us via our Website, mobile applications, online games, or social media accounts (collectively, our “Platforms”) or access our Platforms.

It also applies to all our business contacts, including our partners, contractors, suppliers, and investors that engage with us as well as candidates and job applicants that apply to work with us.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your information.

OUR PRIVACY STATEMENT: At Voldex, data protection is important to us. We believe in a responsible and pro-active approach when dealing with personal information. This privacy policy sets out how and why we collect, store, use and share personal information, our dedication to protect it, as well as your rights in relation to your personal information and details of how to contact us and supervisory authorities if you have a question, comment or complaint.

CHILDREN: We strive to provide age-appropriate experiences for children. Depending on the age of the child accessing our online services, parents or guardians may need to provide permission to enable their child to access certain online features of our Platforms. For further information, please see our section ‎8 (Children) below.

  1. The types of personal information we collect

We collect and use the following information about you:

  • Identity Data including your gender, first name, surname.
  • ID Verification Data including any applicable national identification number, passport, and any other type of government-issued IDs.
  • Contact Data including your address, email address, and telephone numbers.
  • Financial Data including your payment, credit history, and bank account details.
  • Technical Data including your IP address, device type, browser type and broad geographical location when you visit or engage with our Platforms.
  • Transactional Data including information about our business dealings, transactions and interactions with you.
  • Usage and Online Activity Data including pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Platform, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
  • Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences.
  • Social Media Data including your social media profile information.
  • Recruitment Data including your CV, information held on your social media accounts such as LinkedIn, data relating to your performance during the application process and information provided by recruitment agencies, third party references, health information to make reasonable adjustments, information from background checks, and any relevant recruitment test results.
  • Other Data. Any additional personal information you provide when you engage with us.
  1. How we use your personal information

The personal information we process depends on our relationship with you as follows:

Individual Data Processed
Visitors / users of our Platforms Identity Data

Contact Data

Technical Data

Transactional Data

Usage and Online Activity Data

Marketing and Communications Data

Social Media Data

Other Data
Business contacts Identity Data

ID Verification Data

Contact Data

Transactional Data

Financial Data

Marketing and Communications Data

Other Data
Candidates and Job applicants Identity Data

ID Verification Data

Contact Data

Transactional Data

Marketing and Communications Data

Recruitment Data

Other Data

We use personal information relating to you that we collect, or that you provide to us, for the following purposes:

  • To deliver, manage and improve our Platforms;
  • To engage with you and to provide our products and services;
  • To provide you with marketing and promotional information related to our services which we believe may be of interest to you if this is in accordance with your marketing preferences;
  • To keep our Platforms secured;
  • To respond to your queries and provide assistance when needed;
  • To perform our contracts with our business contacts;
  • To perform our day-to-day business activities;
  • To better understand the usage trends of our Platforms, products, and services;
  • To determine the effectiveness of our marketing campaigns;
  • To enable user-to-user sharing;
  • To process your application to work for us (including to onboard our talent pool, consultants, and contractors), improving the application process, and for carrying out pre-employment checks;
  • For research and development purposes to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymised data from personal information we collect by removing personal information that makes the data personally identifiable to you;
  • To manage and administer our investor relationships; and
  • To comply with the law.

We will only use your personal information for the purposes for which we have collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain to you the lawful basis which allows us to do so.

  • If you fail to provide personal information

Where we need to collect personal information by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

  1. Lawful basis for processing

We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case, the legal basis will be one of the following:

  • Consent. This applies where, for example, we obtain your consent to certain marketing communications.
  • Our legitimate business interests. Where it is necessary for us to supply the services or perform our business activities, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights.
  • Performance of an agreement with you. For example, where we have entered into a contract to provide our services to you.
  • Compliance with the law. Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.
  1. Sharing your personal information with third parties

We may share your personal information with the following parties as described in this privacy policy, in other applicable policies, or otherwise at the time of collection:

  • Our group companies. Our corporate parent, subsidiaries, and affiliates.
  • Service providers. Third parties that provide services on our behalf or help us operate our Platforms or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).
  • Advertising partners. We may allow third-party advertising partners to use technologies and other tracking tools to collect information regarding your use of the Platforms, our products, services, and your device (such as your IP address, mobile identifiers, pages visited, location, browser information, time of day).
  • Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so. We will share personal information that is needed for these third parties to provide the services that you have requested.
  • Business partners. For example, third parties with whom we co-sponsor events and those with whom we jointly offer products and services.
  • Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
  • Authorities and others. Law enforcement, government authorities, and private parties, if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request.
  • Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Voldex, financing of Voldex, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Voldex as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

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

  1. Marketing

We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

We are committed to protecting and respecting your personal information. We will not sell or rent your personal information to any third parties.

You may opt-out of direct marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at [email protected]. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

  1. Cookies

Our Platforms use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our Platforms and also allow us to improve them. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree.

Cookies contain information that is transferred to your computer's hard drive. We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our Platforms.
  • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Platforms when they are using them. This helps us to improve the way our Platforms work, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our Platforms. This enables us to personalise our content for you, greet you by name and remember your preferences.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

  • Cookie Title
  • Purpose
  • NONE

N/A

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Platforms may become inaccessible or not function properly.

We do not share the information collected by the cookies with any third parties, unless as otherwise specified in this privacy policy.

  1. Children

Although our Platforms, and most of our products and services are intended adults, we recognise the importance of protecting the personal information of children who may access our Platforms and our products and services online. We consider the best interests of children when determining the age-appropriate experience they receive and take into account the developmental maturity of children of different ages.

When a user or visitor of our Platforms identifies themselves as being a child under the age of 18, we take additional steps to protect their personal information. For example, we are committed to:

  • complying with all applicable laws, regulations, codes, and practices to safeguard the children’s personal information in that territory;
  • obtaining consent from parents or legal guardians for the use of their children's personal information, when required by applicable law;
  • disabling features in our Platforms and certain products or services that could allow a child to share information that directly identifies them, unless a parent has provided relevant consent to us or the third-party platform on which their child is playing; and
  • collecting and using certain information for limited purposes only. For example, we may send local in-app notifications, which do not rely on collecting personal information.

We do not intentionally collect or use personal information about users under the age of 18 for marketing and advertising purposes. However, we may send direct marketing communications to young people above the age of 18. When we do so, we will always require the consent of the young person by asking them to actively opt-in to our direct marketing communications and to confirm that they are above the age of 18.

If we become aware that a child has provided us with personal information without parental consent, we will delete any personal information we have collected, unless we have a legal obligation to keep it. We recommend that an adult is always present to monitor the online data sharing activities of their children.

  1. How long we keep your personal information

We retain your information for as long as it is necessary for the purposes for which it was collected and processed. Additionally, we retain data for the purposes of satisfying any legal, regulatory, accounting, finance, tax, reporting and insurance requirements, after which we take steps to destroy or de-identify personal data when the information is no longer required for any purpose for which it may be used or disclosed by us, and we are no longer required by law or regulation to retain the information. Please note that this will be assessed on a case-by-case basis.

Where we can erase your data sooner, we will do so. 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 unauthorised 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.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

  1. Is your personal information transferred internationally?

Our servers are located in the UK. However, we may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country

In the event that we transfer your personal information internationally, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this privacy policy. In these cases, we rely on approved data transfer mechanisms (such as the EU and UK “Standard Contractual Clauses”) to ensure your information is subject to adequate safeguards in the recipient country.

If you are located in the UK or EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.

  1. Data Security

We have put in place appropriate security measures designed to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We take steps to ensure that your personal information is treated securely and in accordance with this privacy policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, for example, by encryption or by using pseudonymisation, we cannot guarantee the security of your personal information transmitted via the internet; any transmission is at your own risk.

We have appropriate technical and organisational measures designed to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other individuals. We maintain these technical and organisational measures and will amend them from time to time to improve the overall security of our systems.

In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.

We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

  1. Your Rights

We take your privacy seriously and want you to be aware of your rights, as follows:

  • you have the right to request (i) confirmation of whether we process your personal information and (ii) access to a copy of the personal information retained;
  • you have the right to request rectification or removal of your personal information or restriction of the processing of your personal information;
  • where processing of your personal information is either based on your consent or necessary for the performance of an agreement with you and processing is carried out by automated means, you have the right to receive the personal information concerning you in a structured, commonly used and machine-readable format or to have your personal information transmitted directly to another company, where technically feasible (data portability);
  • where the processing of your personal information is based on your consent, you have the right to withdraw your consent at any time without impact to any data processing activities that have taken place before such withdrawal;
  • you have the right not to be subject to any decisions based solely on automated processing, including profiling, which has legal or other similarly significantly effects on you unless we have your consent, it is authorised by law or it is necessary for the performance of an agreement;
  • you have the right to object to processing if we are processing your personal information on the basis of our legitimate interest unless we can demonstrate compelling legitimate grounds which may override your right. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your personal information, and to balance our legitimate interests in carrying out the processing and your objection to this processing;
  • the right to object to processing your personal information for direct marketing purposes; and
  • the right to lodge complaints before the competent data protection regulator, the UK Information Commissioner’s Office, and you may do so at https://ico.org.uk/make-a-complaint/.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details. This is a security measure to ensure that personal information 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.

  1. Queries and complaints

In the event that you wish to discuss, or make a complaint about, how we process your personal information, please contact us in the first instance at [email protected]. and we will endeavour to deal with your request as soon as possible.

This is without prejudice to your right to submit your complaint to the relevant data protection authority.

  1. Changes

We will generally notify you of any material changes to this privacy policy, through a notice provided via the Platform or otherwise supplied to you. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such privacy policy. Your continued engagement with us after the date of the updated privacy policy constitutes your acceptance of the updated privacy policy. If you do not agree to the updated privacy policy, you must stop your engagement with us.

  1. California Privacy Rights

If you are a resident of California, you have certain rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). This section describes your rights and explains how to exercise them.

  1. Right to Know

You have the right to request that we disclose certain information about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.

The categories of sources for the personal information we collected about you.

Our business or commercial purpose for collecting, selling, or sharing that personal information.

The categories of third parties with whom we share that personal information.

The specific pieces of personal information we collected about you.

You may submit a request to know by contacting us at [email protected] or via mailing address:

Voldex Entertainment Limited

Duo, Level 6, 280 Bishopsgate, London, EC2M 4RB, United Kingdom

  1. Right to Delete

You have the right to request that we delete any personal information we have collected from you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information unless an exception applies.

Submit your request to delete via [email protected]

  1. Notice of No Sale or Sharing of Personal Information

We do not sell or share the personal information of our users, as defined under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). This means we do not disclose personal information to third parties in exchange for monetary compensation or for cross-context behavioral advertising purposes.

If our practices change in the future, we will update this privacy policy accordingly and provide users with the necessary opt-out mechanisms as required by law.

  1. Right to Correct

You have the right to request that we correct inaccurate personal information about you. To request a correction, please contact us at [email protected]

  1. Right to Limit Use of Sensitive Personal Information

You have the right to limit how we use your sensitive personal information (such as your precise geolocation, financial data, or government identifiers). If we collect sensitive personal information, we will only use it for purposes allowed by law, such as providing services to you or detecting security incidents. You may request limitations on the use of sensitive personal information by contacting us at [email protected]

  1. Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA/CPRA rights. This means that we will not deny you services, charge you different prices, or provide you with a different quality of services unless such differences are related to the value of your data.

  1. Submitting a Verifiable Request

To exercise your rights under the CCPA/CPRA, you can contact us through the following methods:

Email: [email protected]

Mail:

Voldex Entertainment Limited

Duo, Level 6, 280 Bishopsgate, London, EC2M 4RB, United Kingdom

You may also designate an authorized agent to make a request on your behalf. To do so, we will need to verify the identity of the agent and confirm your authorization.

  1. Notice of Financial Incentives

We may offer financial incentives, such as discounts or other benefits, in exchange for your personal information. When we offer these incentives, we will explain the terms and obtain your explicit consent to participate, which you can revoke at any time. The value of your personal information will be reasonably related to the value of the incentive provided. To learn more about these incentives and your rights, please contact us at : [email protected].

  1. Opt-Out of Sale/Sharing for Minors

If you are between the ages of 13 and 16, you have the right to opt-in to the sale or sharing of your personal information. If you are under 13, your parent or guardian must provide this consent. To opt-in or opt-out, please contact us at : [email protected].

  1. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the nature and sensitivity of the personal information and the purposes for which we process it. If we no longer need your personal information, we will either delete it or anonymize it.

  1. Authorized Agents

You may designate an authorized agent to make requests on your behalf to exercise your privacy rights under the CCPA/CPRA. To verify an authorized agent, we will require proof of your written authorization and may need to verify your identity directly.

  1. How to contact us