Our Privacy Policy for Grown Ups

• 1.
  About Us
• 2.
  Information we collect about You and How we

  use it

• 3.
  Cookies
• 4.
  How we use your Information and why
• 5.
  What if I don’t provide some or all of the information requested?
• 6.
  Will You be contacted for Marketing Purposes?
• 7.
  Adhering to COPPA and CCPA in the US
• 8.
  Competitions
• 9.
  Surveys
• 10.
  Internal Sharing
• 11.
  Sharing your Information with Third Parties
• 12.
  How long we hold your Data for
• 13.
  Your rights regarding your Personal Information
• 14.
  Updates to this Policy
• 15.
  Contacting Us

For the purposes of applicable data protection and privacy laws, Two Daughters Entertainment Limited (“Two Daughters”, “our”, “us”, “we”) (a limited company registered in England with company number 09864731 with its registered office at 71 Queen Victoria Street, London, England, EC4V 4BE), is considered the “Controller” in respect of the personal information that it collects, uses and manages in accordance with this privacy policy (“Policy”). Two Daughters is committed to protecting your privacy and maintaining the security of any personal information received from you. This Policy explains what personal information Two Daughters collects, uses, shares and otherwise processes about individuals (“you”) when you use our websites, or otherwise interact with any of our services, including by attending our events. Before you provide us with any personal information or browse our websites, you should read through this Policy in full. Our websites may contain links to other websites belonging to third parties which are not covered by this Policy. If you want to click through to a third-party website, please make sure that you read the privacy policy for that website.

We do not require your or your child’s personal information in order for you to use the websites. Information you provide: We do not collect sensitive information (also known as special category data) about anyone using the site except when you specifically, knowingly provide it and have consented to this. The “contact us” function generates an email to us and gives you/your child the option to give your/their email address. This means we will collect the email address and name associated with the chosen email address and any other personal information that you volunteer to us when you “contact us”, which we commit to delete once we have processed the request or query. If you sign up for a Moley newsletter or other email subscription for you or your child, we may collect the information you provide, such as your name and email address in order to send you the newsletter. When you enter or participate in our competitions, we may collect certain information from you, such as your name, email address and phone number. When you attend one of our events, we may collect the information you provide, such as your name, email address and phone number. We may also ask your permission to take photos at events that you attend to display on the Two Daughters website or in our other publicity materials. Information we collect automatically: As you interact with our websites, we will automatically collect some information about your device, such as IP address and other unique identifiers, from cookies and similar software which allow us to understand how you arrive on our websites and use and navigate around it. IP addresses and device identifiers are processed by Google Analytics to enable us to anonymously identify the location of users and establish the number of visits from different countries. More information about the process can be found on Google Analytics’ helpsite. Two Daughters does not view or store IP addresses and this information is not used for the purposes of identifying individuals. This information is used to help us improve the site. We also store some usage information in Google Analytics. Please see our cookie policy for further details. Information we collect from third parties: Information you provide through social media If you connect with us through a social media platform or navigate to a social media platform from one of our services, the social media platform will collect your information separately from us. You should review the social media platforms’ privacy policies to understand how they are using your information and your rights in relation to such information. We may also collect information you have publicly posted using your social media accounts when you navigate to a social media platform from one of our services, such as your username, comments, likes and interests. Information from our partners We collect information from our business partners and service providers. Our business providers include Roblox and other companies who make our services or content available to you or your child. The information our business partners provide to us varies depending on the nature of their services and may include IP addresses, device IDs or other unique identifiers and your online activity.

Our websites use cookies. For more information about what cookies are, what we use them for and how you can delete them, please read our cookie policy.

We have set out below a description of the purposes for which we collect and process your personal information and the legal bases we rely on to do so. We will process personal information about you only where we have a valid, legal basis for doing so. In practice this means that one of the following will apply for all of our processing of your personal information:

• we need to process personal information for the performance of a contract with you;
• you have consented to the processing;
• the processing is in our legitimate interests and is not overridden by your data protection interests or fundamental rights and freedoms; or
• the processing is necessary to comply with a legal obligation.

Our legitimate interests: We use your information where this is necessary to achieve legitimate interests provided these interests are not outweighed by your interests or fundamental rights and freedoms. We use the information we collect to: Manage our services. We use the information we have to manage the websites, such as to communicate with you on service related matters and notify you about changes to our websites, manage competitions including verifying your eligibility and selecting winners, send personalised communications and respond to and process any queries or reports by email (including when you tell us about a problem, or ask for a copy of your information). Legitimate interest relied upon: To provide the websites and keep you updated with information about our services and any changes to our websites. To respond to questions or problems you may have in relation to the websites in order to develop and improve our services. Information used: Information you provide, Information we collect automatically and Information we collect from third parties. Ensure the security and stability of the websites: We use the information we have to ensure the safety and security of the websites, including by troubleshooting, testing, identifying and combating technical or security issues (e.g. technical bugs). Legitimate Interest relied upon: To ensure the ongoing safety, security and functioning of our websites. Information used: Information you provide and Information we collect automatically. Improve our websites: We use the information we have to conduct analysis and research about our websites, services and events that we manage and host. Legitimate Interest relied upon: To enable us to study how users use our websites in order to develop and improve the websites and overall user experience. Information used: Information you provide, Information we collect automatically and Information from third parties. Share your information with third parties: We share your information with third parties whose platforms or services are integrated within the websites. Legitimate interest relied upon: To provide you with a seamless experience on our websites and optimise user experience. Information used: Information you provide, Information we collect automatically and Information from third parties. Compliance with our legal obligations: We may use your personal information to comply with applicable laws and regulations Your consent: We will ask for your consent beforehand if we need it to process your personal information.

The impact of this will depend on what information you withhold but the main impacts may be:

• We may not be able to respond fully to requests and queries you may have
• We cannot personalise the service you receive

Where you have consented to us doing so, we may send you marketing communications via email or SMS text message, including invitations to events. You can “opt-out” from receiving such communications by clicking on the “unsubscribe” link provided at the bottom of each marketing email and updating your preferences, or by contacting us via our “Contact Us” page or by post to Data and Analytics team, Two Daughters Entertainment Limited, 60 Kings Road, London, SW3 4UD. Children will not be contacted for marketing purposes unless we have obtained the correct level of parent consent to do so.

Children’s Online Privacy Protection Act (COPPA) is a United States federal law which was put in place to better protect the personal data and rights of children under 13 years of age. Under COPPA, operators of websites or online services that are either directed to children under 13, or which have actual knowledge that they are collecting personal information from children under 13 must give notice to parents and get their verifiable consent before collecting, using, or disclosing such personal information and must keep secure the information they collect from children. “Verifiable” here means using a method of attaining consent that is not easily faked by a child and that is demonstrably likely to be given by an adult (eg. control questions). Even after consenting, parents must also have the option to disallow disclosure to third parties if so desired, unless such disclosures are part of the service (for example, social networking). As the Moley website itself does not collect personal information from children, we do not need to apply parental verification under the COPPA rules. In 2018, The US state of California also introduced the California Consumer Privacy Act (CCPA). For the CCPA, an individual under the age of 16 must provide opt-in consent for their personal information to be sold. Children under the age of 13 must provide valid parental consent in order for their information to be sold. The CCPA applies to any business that does business in California, operates for a profit and collects consumer data - but companies are exempt if they meet all three of the following criteria:

• The company makes less than $25 million in annual revenue
• The company holds the personal information of fewer than 50,000 consumers, households, or devices
• The company makes less than 50% of its income by selling the personal data of consumers

At present, the Moley website is therefore exempt under these criteria but, nonetheless, we pledge not to sell on any personal data we may collect form children in California, now or in the future, without first getting verified parental consent. If we run specific competitions in the United States, we will always ensure that our privacy provisions are in line with COPPA and CCPA rules.

We may occasionally ask our users questions to gauge their opinions on relevant topics. These surveys will be seen randomly by users within games or activities pages. All information gathered from these surveys is anonymous and stored as aggregated data. No personal data is collected or stored in this process and the data collected is not used to profile or target a child as it cannot be linked to an individual. Aggregated and anonymised data may be shared with third parties. The questions asked via these surveys may sometimes be sponsored by third parties so they can better understand the opinions of our audience at an aggregate and anonymised data level. When a survey is sponsored it will be very clearly marked as so and all questions are audited and approved by Two Daughters insight professionals before publication. Use of the website does not require any user to respond to survey questions and they are completely optional to answer. In setting our surveys, Two Daughters is seeking to understand the likes, dislikes and trends within its audience base. This is used to inform editorial decisions and to help third party brands improve their propositions.

As a Moley fan or enthusiast you may have signed up for a Moley newsletter or other email subscription for you or your child. Two Daughters may share your personal information with people within the company who have a “need to know” that data for business or legal reasons, for example, to direct a query that you have submitted to the relevant department. We will only share the information needed to provide you with the services you are using and will not routinely share data we hold about you.

We may from time to time provide your or your child’s personal information to third parties for the purposes providing our services, including: (i) public and government authorities; (ii) courts or regulators; (iii) Two Daughters’ professional advisors, such as lawyers, auditors and insurers; (iv) suppliers of IT services; and (v) third party providers engaged by Two Daughters or with whom it otherwise has a business relationship, for the purposes of: (a) hosting the websites and providing the services; (b) carrying out marketing campaigns; (c) protecting any intellectual property rights in any materials displayed on or otherwise available from the websites; (d) seeking legal or other professional advice; (d) responding to a legal request or comply with a legal obligation; and (e) as may otherwise be necessary in connection with the processing purposes identified in this Policy. We may disclose your Personal Information to third parties in the event that we sell, buy or merge any business or assets, including to the prospective seller or buyer of such business or assets. Finally, we may share non-personal information with other third parties that are not described above. When we do so we may aggregate or de-identify the information so that a third party would not be likely to link data to you, your computer, or your device.

Two Daughters may transfer your personal information and/or store it outside of the UK in order to operate our business or the Websites. When transferring any personal information outside of the UK we only do so under one of the legally recognised transfer mechanisms for ensuring the data is adequately safeguarded. Where personal information is transferred outside of the UK, you can request a copy of the appropriate safeguards which we have put in place to protect your personal information and privacy rights in these circumstances, using the contact details set out in the ‘Contacting us’ section below. We work with the following third-party providers to support the operation of the Site and provide a better experience. These third-party providers do not share children’s personal information with any other providers. For more information please refer to these third-party providers’ privacy policies as listed below. We use Threei to build our websites and web games. We use Google Analytics to help analyse your use of the websites:

• Google’s privacy policy

Your personal information is not kept for longer than is necessary for the purposes for which it is collected. This means that data and records (including personal information) are destroyed or erased from our systems when no longer required. For example, data collected by us through the “Contact Us” page is deleted as soon as the query raised is resolved. Competition entries are kept whilst the competition remains open. Once the competition has concluded and prizes are confirmed to be received, all data collected during the competition is deleted.

Applicable data privacy laws give rights to individuals in respect of personal information that organisations hold about them. If you wish to:

• request access to or a copy of the personal information that we hold about you; or
• request that we rectify or delete your personal information; object to / restrict the processing of your personal information; or request portability of your personal information,
• withdraw consent at any time where we are relying on consent to process your personal information (this will not affect the lawfulness of any processing we conducted prior to your withdrawal),

please submit your written request to via our “Contact Us” page or by post to Data and Analytics team, Two Daughters Entertainment Limited, 60 Kings Road, London, SW3 4UD. We ask that you always inform us of changes to your personal information so that we can keep it up to date.

We keep our Policy under regular review.

If you have any questions about privacy, or wish to update your details or action any of your other data rights at any time, please contact us via our “Contact Us” page, email us at hello@twodaughtersentertainment or by post to our Data and Analytics team, Two Daughters Entertainment Limited, 60 Kings Road, London, SW3 4UD. If you are not satisfied with the handling of your concern or complaint by Two Daughters, you can escalate this to the Information Commissioner’s Office (ICO). Last updated November 2023.