Privacy Notice

June 2020

This notice describes how we collect and use personal information about you.

This notice applies to personal information that we collect in connection with our websites at www.games-workshop.com, www.forgeworld.co.uk, www.blacklibrary.com, www.warhammer-community.com, www.warhammerdigital.com, warhammerworld.games-workshop.com, other micro-sites operated by us from time to time and any other websites on which it is posted, and our various social media accounts (“Websites”).

This notice also applies to personal information that is collected from you by our Customer Services team.

The data controller of your personal information collected through the Websites is Games Workshop Limited of Willow Road, Nottingham, NG7 2WS, United Kingdom.

Please read this notice carefully to understand how and why we are using your personal information.

1 What information do we collect about you?

We may collect, store, use and disclose the following categories of your personal information:

  • Personal contact details such as name, title, address, email address and telephone number.
  • Date of birth.
  • Nationality, country of residence and language.
  • Bank account, credit/debit card and payment information.
  • Details of purchases and transactions carried out through the Websites and fulfilled by us.
  • Information submitted as part of any competition operated through the Websites.
  • Information submitted as part of any survey operated through the Websites.
  • Records of correspondence with you whether by web form, telephone, email, text message, social media or otherwise.
  • Telephone call information, including call recordings, phone number and length of call.
  • Gift List information.
  • Social media profile information, including profile name and picture, where you interact with us through social media.
  • Photographs.
  • Product Interests and preferences .
  • Details of your visits to the Websites, and information about how your device has interacted with our Websites, including search and browsing history, the pages accessed and links clicked, mobile carrier time zone, broad geographic location (e.g. country or city level), device identifiers (e.g. Apple’s IDFA and Android’s advertising ID).
  • Information collected automatically from your device, including IP address, Media Access Control (MAC) address, device type, screen resolution, operating system name and version, unique device identification numbers, language and internet browser-type and version, broad geographic location (e.g. country or city-level location) and other technical information.
 

2 How is your personal information collected?

- Information provided directly

We collect personal information that you provide voluntarily. Certain parts of our Websites may ask you to provide personal information voluntarily, to register an account with us, to place an order with us, to subscribe to a service from us, to subscribe to marketing communications from us, and/or to submit enquiries to us.  We also collect information that you provide voluntarily to our Customer Services team, whether in writing or by telephone, email or otherwise.

- Information collected automatically

We also collect some information automatically when you visit the Websites. Collecting this information enables us to better understand the visitors who come to our Websites, where they come from, and what content on our Websites is of interest to them and to assist us to provide you with information about us or our products and services.

Some of this information may be collected by us, or our third party service providers, using cookies and similar tracking technology. We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you, including to serve internet-based advertising. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie-Notice.

We are committed to providing you with meaningful choices about the information collected on our Websites for third party purposes. However, we not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations and solutions.

- Information collected from third parties

We may also obtain additional information about you from third parties such as social media partners (when you post on our social media page or message us through a social media platform).

3 Why do we collect your personal information?

The situations in which we will process your personal information are listed below:

  • To create an account for you.
  • To help us provide a more personalised service suited to meet your preferences.
  • To ensure that the Websites are presented in the most effective manner for you and your device.
  • To send you newsletters or catalogues or provide you with information, products or services that you request from us, or which we feel may interest you.
  • To carry out our obligations arising from any contracts entered into between you and us
  • To check the authenticity of applications.
  • To process transactions and refunds with you.
  • To interact with you and handle and respond to communications with you.
  • To allow you to participate in interactive features of our Websites and service, when you choose to do so.
  • To promote customer interactions, activities and engagement.
  • To notify you about changes to our services or products.
  • To contact you and to update you in respect of any partially complete or incomplete orders you have made.
  • To carry out your requests in respect of any Gift List you may create.
  • To operate competitions on the Websites and communicate with entrants.
  • To obtain and analyse your feedback as part of customer surveys.
  • To reserve gaming tables.
  • To analyse customer behaviour and purchases within the Websites and improve the quality and relevance of our Websites to our visitors.
  • To facilitate the improvement and optimisation of our services to you.
  • To store information about your preferences to allow us to customise our site and newsletters according to your individual interests.
  • To monitor delivery and viewing of our newsletters to facilitate the improvement and optimisation of the delivery of the newsletter to you.
  • To handle any disputes which we may have with you.
  • To detect and/or prevent illegal or undesirable activities within the Websites.
  • To comply with applicable legal, data retention or reporting obligations.
  • Training purposes.

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it, such as: (i) for the purpose of performing a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, iii) where we have your consent to do so, or (iv) where we have a legal obligation to collect personal information from you.

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be for our legitimate commercial interest, to operate the Websites and make these available to you as necessary to provide our products and services to you, for interacting with you, responding to your queries and maintaining good customer relations, for monitoring our communications with you, analysing customer behaviour and purchases, undertaking and optimising marketing and contacting you in respect of incomplete orders, operating our Gift List and digital voucher services, obtaining customer feedback, handling disputes, staff development and for the purposes of detecting or preventing illegal or undesirable activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us (section 15)

4 What if you fail to provide personal information?

If you fail to provide certain information when requested we may not be able to perform any contract we have entered into with you, or we may be prevented from complying with our legal obligations.

5 What if we want to use your information for a different purpose?

We will only use your personal information for the purposes for which we 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 will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.

6 How secure is your information?

We will use appropriate technical and organizational measures to protect your personal information from accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access.

7 Who might we share your information with?

We may share your personal information in the situations detailed below:

  • Service providers

    We share your personal information with third parties who provide services to us. The following activities all involve the processing of personal information and are carried out by third party service providers: website hosting, website optimization and analytics, edge caching services, payment processing, delivery, monitoring and optimisation of checkout reminder emails and marketing materials, customer survey services, hosting and maintenance of customer services case management platform, maintenance of call recording system, hosting and maintenance of social media platforms, document and information collaboration and sharing, IT services. Further details in respect of our third party service providers are available on request. Please contact us (section 13) for further information.

    We take steps to ensure that service providers who process personal information take appropriate security measures to protect your personal information. We only permit them to process your personal data for specified purposes in accordance with our instructions.

  • Games Workshop group

    We may share your personal information with other entities in our group of companies for our internal business purposes, to provide our products and services to you, regular reporting activities on company performance, in the context of business reorganisation or group restructuring, or for system maintenance support.

  • Sale or restructure

    We may share your personal information in the context of the possible sale or restructuring of the business or assets of the business (or due diligence leading up to such a transaction), provided that we inform the buyer it must use your personal information only for the purposes disclosed in this notice.

  • Law, legal rights and vital interests

    We may also need to share your personal information with a law enforcement body, regulator, government agency, court, tribunal or other third party where we believe disclosure is necessary (i) to comply with applicable law, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any person.

  • Consent

    We may share your personal information where you have specifically consented to such disclosure. This includes, for example, publication of Gift Lists.

8 Do you transfer my information outside of the European Union?

We may transfer personal information collected within the European Economic Area (EEA) to jurisdictions outside of the EEA. For example, our Websites are hosted on servers within Europe and the United States of America, and our third party service providers operate around the world.  We will only transfer your personal information outside the EEA if adequate protection measures are in place.  To ensure that your personal information does receive an adequate level of protection outside the EEA we use the following protection measures:

  • Transferring to countries approved by the European Commission
  • Using model contractual clauses approved by the European Commission
  • Requiring companies we transfer information to in the United States to be signed up to the EU/US Privacy Shield Framework

Further details in respect of protective measures used outside of the EEA are available on request. Please contact us (section 15) for further information.

9 How long do we keep hold of your information?

We retain your information for as long as necessary for the purposes described above, including for the purposes of satisfying any legal, accounting, or reporting requirements under applicable law.

When we have no ongoing legitimate business need to process your personal information and are not required to retain it under applicable law, we endeavour to either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we endeavour to securely store your personal information and isolate it from any further processing until deletion is possible.

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 it has been processed, 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 for any purpose and without further notice to you.

10 What are your rights in connection with your personal information?

In certain circumstances, under applicable privacy laws, you may have the right to:

  • Request access to a copy of the personal information we hold about you
  • Request correction of any incomplete or inaccurate information we hold about you
  • Request erasure of information where there is no good reason for continued processing
  • Object to processing of your information where we are relying on a legitimate interest to process your information.
  • Where we are processing your information for a particular purpose based on your consent, you have the right to withdraw your consent at any time.
  • Request restriction to suspend our processing of your personal information.
  • Request transfer of your personal information to another party which you have provided to us.
  • Opt out of marketing communications which we send you at any time.

If you want to exercise any of the rights available to you under applicable privacy laws, please contact us (section 15)or click here.

You will not have to pay a fee to exercise any of your rights, however we may charge a reasonable fee if your request is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Please note that we may need to request information from you to confirm your identity and establish your entitlement to these rights.

If you are not satisfied with our processing of your personal information, you also have the right to make a complaint to the relevant supervisory authority.

If you are based in the European Union, please see here for the relevant contact details.

11 Information for California residents

The following paragraphs in this section provide details under the California Consumer Privacy Act (CCPA) and apply solely to California residents. In this section, the term ‘personal information’ shall be as defined in the CCPA:

The following chart lists the categories of information we collect and the entities to whom we disclose such information:

Categories of information collected Categories of third parties to whom we disclose the information:
Identifiers (such as name, address, email address)
  • Service providers
  • Other individuals, services, and partners at your request
  • Entities for legal purposes
  • Entities for sales or transfer of business or assets
Commercial information (such as transaction data)
  • Service providers
  • Other individuals, services, and partners at your request
  • Entities for legal purposes
  • Entities for sales or transfer of business or assets
Financial data (such as credit card information)
  • Service providers
  • Other individuals, services, and partners at your request
  • Entities for legal purposes
  • Entities for sales or transfer of business or assets
Internet or other network or device activity (such as browsing history)
  • Service providers
  • Other individuals, services, and partners at your request
  • Entities for legal purposes
  • Entities for sales or transfer of business or assets
General geo-location information (such as co-ordinates based on IP address)
  • Service providers
  • Other individuals, services, and partners at your request
  • Entities for legal purposes
  • Entities for sales or transfer of business or assets
Audio or visual information (such as call recordings)
  • Service providers
  • Other individuals, services, and partners at your request
  • Entities for legal purposes
  • Entities for sales or transfer of business or assets
Legally protected classifications (such as gender)
  • Service providers
  • Other individuals, services, and partners at your request
  • Entities for legal purposes
  • Entities for sales or transfer of business or assets

We may obtain the information listed above from a variety of sources, including from:

  • You
  • Your devices
  • Your social media accounts
  • Other individuals such as your friends or family

We may use the categories of information listed above for the purposes listed in “Why do we collect your personal information?” in Section 3 of this notice.

Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. Additionally, California customers may request, once per year, that we disclose the identity of any third parties with whom we have shared personal information for the third parties’ direct marketing purposes within the previous calendar year, along with the type of personal information disclosed. We do not engage in any such activity and have not engaged in such activity in the past twelve months.

Additional California privacy rights:

California law may permit you to request that we:

  • provide you with the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we shared personal information;
  • provide access to and/or a copy of certain information we hold about you;
  • delete certain information we have about you.

Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the services to you and for compliance with applicable law. If you ask us to delete certain information, you may no longer be able to access or use the Services.

For the fastest response to requests to exercise any of these rights, please visit this page. You may also make a request by calling us at 1-800-394-4263 (US only). You will be required to verify your identity before we fulfil your request.

12 Information for Nevada Residents

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident and you have purchased products from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting us (section 15). You will be required to verify your identity before we fulfil your request.

13 What we ask of you?

It is important that the personal information we hold about you is accurate and current. Please contact us (section 15) immediately and inform us of any changes to the personal information which we hold about you.

 

If you provide us with information about another person (e.g. gift recipient), you confirm that you have informed them of our identity, the purposes for which their personal data will be processed, and that you have obtained their permission to such processing by us.

14 Change to this privacy notice

We may update this notice from time to time. When we update this notice, we will take appropriate measures to inform you, consistent with the significance of the changes. We will obtain your consent to any material changes if and where this is required by law.

You can see when this notice was last updated by checking the date displayed at the top of this notice.

15 Contact us

This notice is overseen by the Privacy Team of the Games Workshop group.If you have any questions, complaints or requests please make contact with our Privacy Team by email: privacy@gwplc.com. You may also call us toll free at 1-800-394-4263 (US only).