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Privacy Policy




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Privacy Policy

This Privacy Policy is tailored to comply with the General Data Protection Regulation ((EU) 2016/679) (GDPR) and the California Consumer Protection Act (CCPA) and replaces our previous Privacy Policy.


  1. (a) www.iwaredesigns.co.uk
  2. (b) www.iwaredesigns.com
  3. (c) www.iwaredesigns.net
  4. (d) www.iwaredesigns.uk
  5. (e) www.iwaredesigns.ca
  6. (f) www.iwaredesignsgaming.com

Our nominated representative for the purpose of the Act is Mr Gavin Harwood: Contact us


  1. Introduction
    1. We are committed to safeguarding the privacy of our website visitors and service users. Our websites, the data controller and the Company owners may use any information submitted to assist you in answering any questions or queries that may be submitted.

    2. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

    3. We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website or use our online products and services. You consent to our use of cookies in accordance with the terms of this policy.

    4. In this policy, "we", "us" and "our" refer to iWare Designs Limited.

  2. How we use your personal data
    1. In this Section 2 we have set out:

    2. (a) the general categories of personal data that we may process;
    3. (b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
    4. (c) the purposes for which we may process personal data; and
    5. (d) the legal bases of the processing.

    6. We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, Gamer tags, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services. We strongly recommend and promote that any choice in Gamer Tags consider pseudonymisation to enhance privacy.

    7. We may process your application or purchase application data, this is data provided to us to store your personal information if you have provided it to us as part of registering on our system ("application data"). The application data may include your name, email address, postal address and telephone number. The source of the application data is you. The application data may be processed for the purposes of operating our website, a business sale or transaction, performance of a contract, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent and or our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

    8. We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include your personal data. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent and or our legitimate interests, namely the proper administration of our website and business and or the performance of a contract between you and us or another and/or taking steps, at your request, to enter into such a contract.

    9. We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

    10. We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users and candidates.

    11. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

    12. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

    13. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

    14. In addition, upon registration through our online products and services, you may provide to us a gamer tag, your email address and other information. Without that information, we cannot provide our services. We have installed physical, electronic and managerial processes that keep your information safe when it is collected and subsequently stored.

    15. Please do not supply any other person's personal data to us unless we prompt you to do so.

    16. iWare Designs Limited and its associated websites do not engage in sending out newsletters or any form of marketing. Further, iWare Designs Limited do not ask for personal financial details. All financial transactions carried out through our online products are performed by either Apple Inc. or Google Inc, iWare Designs Limited does not have access to any of your financial details.

    17. iWare Designs Limited and the use of it websites take a proactive approach to user privacy and to ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience.

    18. iWare Designs Limited and the use of their websites encourage the use of caution when clicking on any external web links mentioned in any place on any of the company’s websites as set out in this policy. The owners of iWare Designs Limited websites cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users are therefore encouraged and are asked to note that by clicking on any external links that they are doing so at their own risk and iWare Designs Limited and its owners cannot be held liable for any damage or implications caused by visiting any external links mentioned.

    19. iWare Designs Limited websites and its online Products do not contain any sponsored links or adverts unless provided through our advertising partners.

    20. iWare Designs Limited websites and its online products may contain adverts. The advertisements will typically be served through our advertising partners to whom may have detailed privacy policies relating directly to the adverts that they serve. By clicking on any advertisements, they will display information from the advertiser. Users should therefore note that they click on adverts at their own risk and iWare Designs Limited and its owners cannot be held liable for any damage or implications caused by third party adverts. Please refer to Section 17 Advertising of this document for more information.

  3. Providing your personal data to others
    1. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

    2. In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

    3. In the unlikely event that a liquidator, administrator or receiver is appointed over us or on any part of our assets, that insolvency practitioner may transfer your information to a third-party purchaser of the business provided that the purchaser undertakes to use your information for the same purposes as set out in this policy.

    4. If iWare Designs Limited were merged with or taken over by another organization, your personal data would become available to such organization provided that such organization provided an undertaking only to use it for the same purposes as are set out in this policy.

  4. International transfers of your personal data
    1. In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA). We do not anticipate that your personal data will be transferred to countries outside of the European Economic Area (EEA)

    2. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

  5. Retaining and deleting personal data
    1. This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

    2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

    3. We will retain your personal data as follows:

    4. (a) Personal Data information will be retained for a minimum period of 2 years following submission, and for a maximum period of 6 years following submission.

    5. In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria: (a) the period of retention of personal data category will be determined based on an annual review and will therefore be no longer than 12 months.

    6. Notwithstanding the other provisions and information in this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal or contractual obligation to which we are subject, or in order to comply with a statutory limitation period or in order to protect your vital interests or the vital interests of another natural person.

    7. For more detailed information on specific data we collect please refer to Section 14, 15 and 16 of this privacy policy.

  6. Amendments
    1. We may update this policy from time to time by publishing a new version on our website.

    2. You should check this page occasionally to ensure you are happy with any changes to this policy.

    3. We may notify you of changes to this policy through our website.

  7. Your Rights "Subject Access Requests"
    1. You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

    2. (a) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address.

    3. We may withhold personal information that you request to the extent permitted by law.

  8. Your Rights under GDPR and Data Protection Legislation
    1. In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

    2. Your principal rights under data protection law are:

    3. (a) the right to access;
    4. (b) the right to rectification;
    5. (c) the right to erasure;
    6. (d) the right to restrict processing;
    7. (e) the right to object to processing;
    8. (f) the right to data portability;
    9. (g) the right to complain to a supervisory authority; and
    10. (h) the right to withdraw consent.

    11. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

    12. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

    13. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

    14. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

    15. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

    16. iWare Designs Limited does not perform any form of marketing. If this change in the future, you have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

    17. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

    18. To the extent that the legal basis for our processing of your personal data is:

    19. (a) consent; or
    20. (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

    21. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

    22. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

    23. You may exercise any of your rights in relation to your personal data by emailing us: Contact us

  9. About cookies
    1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

    2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

    3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

  10. Cookies that we use
    1. We use cookies for the following purposes:

    2. (a) authentication - we use cookies to identify you when you visit our website and as you navigate our website
    3. (b) status - we use cookies to help us to determine if you are logged into our website
    4. (c) personalisation - we use cookies to store information about your preferences and to personalise the website and or online products for you
    5. (d) security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally
    6. (e) advertising - we use cookies to help us to display advertisements that will be relevant to you
    7. (f) analysis - we use cookies to help us to analyse the use and performance of our website, online products and services
    8. (g) cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally

  11. Cookies used by our service providers
    1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

  12. Managing cookies
    1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

    2. (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
    3. (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
    4. (c) http://www.opera.com/help/tutorials/security/cookies (Opera);
    5. (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
    6. (e) https://support.apple.com/en-gb/HT201265 (Safari); and
    7. (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

    8. Blocking all cookies will have a negative impact upon the usability of many websites.

    9. If you block cookies, you may not be able to use all the features on our website and our online products.

  13. Our details
    1. Our Company Number is 7387407 and our Registered Office is at Queens Head House, The Street, Acle, Norwich Norfolk, NR13 3DY.

    2. You can contact us:

    3. a) using our website contact form;

  14. Website Enquiries
    1. What data do we collect?
    2. When contacting us through our website you will be asked to enter your Name, Email Address and the nature of your query.

    3. Why we ask for this data?
    4. Your Name, Email Address and the nature of your query will then be emailed to our support email address.

    5. • We will use your name when replying to your query.
    6. • We will use your email address to reply to your query.
    7. • We will give you a response based on your query.

    8. Where the data stored.
    9. The email we receive will be stored locally in our place of business in the United Kingdom. This data is stored securely and does not leave our premises.

    10. How is the data managed?
    11. Once we have resolved your query we will delete the original email from our email client. We will deem the query resolved if either of the following conditions apply:

    12. • We receive an email from yourself confirming that your query has been resolved.
    13. • If no confirmation is received, then after seven days we will assume your query has been resolved.

    14. If for any reason you need further support we will keep your emails until we have resolved your query.

    15. We use a seven-day rolling backup system, this means that when your email query has been deleted from our email software, it will take a further seven days for your data to be purged from our backup system.

    16. How can your data be removed?
    17. Your emails and associated data will be deleted automatically after a maximum fourteen days. If you have any questions or concerns about the deletion of your data you can contact our Compliance Manager (See Section 20 for details).

  15. Emails
    1. Where the data is stored.
    2. The emails we receive will be stored locally in our place of business in the United Kingdom. This data is stored securely and does not leave our premises.

    3. How is the data managed?
    4. Once we have resolved your query we will delete the original email from our email client. We will deem the query resolved if either of the following conditions apply:

    5. • We receive an email from yourself confirming that your query has been resolved.
    6. • If no confirmation is received, then after seven days we will assume your query has been resolved.

    7. If for any reason you need further support we will keep your emails until we have resolved your query.

    8. We use a seven-day rolling backup system, this means that when your email query has been deleted from our email software, it will take a further seven days for your data to be purged from our backup system.

    9. How can your data be removed?
    10. Your emails and associated data will be deleted automatically after a maximum fourteen days. If you have any questions or concerns about the deletion of your data you can contact our Compliance Manager (See Section 20 for details).

  16. Application & Software
    1. What data do we collect?
    2. When creating an account to play online with other users we ask for a Gamer Tag, Email Address and Password. Your Gamer Tag should be a pseudonymisation to enhance privacy.

    3. Why we ask for this data?
    4. Your Gamer Tag, Email Address and Password will be used to create an account on our server. This will enable you to sign in and play online with our Apps.

    5. • Your Gamer Tag will be displayed on your opponent’s device.
    6. • Your Email Address will only be used for account management (Resetting your password).

    7. End users that have created a Gamer Tag and Password to sign into our server will be able to send and receive friend requests. This allows you to play against specific people that you have accepted to be a friend. Your online status will be made available to your friends.

    8. Where and how the data is stored.
    9. Your Gamer Tag, Email Address and Password is stored on our server. Your Email Address and Password are encrypted.

    10. Our server is located in the United Kingdom. Our server is backed up automatically, and the backups are also stored in the United Kingdom.

    11. How is the data managed?
    12. The data stored on our online server is used solely for signing in to play our Apps online. The data is not used for any other purposes and is not sold or given to 3rd parties. Once a day a list of newly registered Gamer Tags is emailed to our team for review and assessment for offensive material. Any accounts that have offensive Gamer Tags will be removed instantly.

    13. How can your data be removed?
    14. You can delete your online account at any point by signing into the online gaming section of the App and select the “Delete Account” option located on the screen.

    15. You will be asked to confirm your choice.

    16. If you chose to delete your account the account will be removed instantly from our server and your Gamer Tag will become available for someone to choose.

    17. Alternatively, you can contact our Compliance Manager at any time and request your data to be deleted from our systems (See Section 20 for details).

    18. Deleted accounts cannot be recovered.

  17. Advertising
    1. Our online products may use advertising partners and they can personalise your advertising experience. We would ask you to provide consent to this enhanced ad experience as you will see ads that may be more relevant to you. Depending on your privacy settings, our advertising partners may collect and process personal data such as device identifiers, location data and other demographic and interest data about you to provide the personalised advertising experience. If you are in an EEA country our online products will ask your permission before personalising adverts.

    2. By providing consent, you are confirming that you are over the age of 18 and would like a personalised ad experience.

    3. By not providing consent, you understand that you will still see adverts, and they may not be as relevant to your interests.

    4. If you have given consent and change your mind, you can withdraw your consent at any time by either:

    5. (a) From within our apps. How do I change my advert preferences? (iOS and Android).
    6. (b) Enabling the Opt out of Ads Personalisation setting on your device. https://support.google.com/ads/answer/2662922?hl=en-GB (Android);
    7. (c) Enabling the Limit Ad Tracking setting on your device. https://support.apple.com/en-gb/HT202074 (iOS).

    8. Our Partners may also provide ways for you to opt out from or limit their collection of information from and about you. Please refer to their privacy policies to learn more about the privacy practices of our Partners. Please note however, that we have no control and we are not responsible for the privacy practices of our Partners.

    9. Our current advertising partners are listed below, please take time to read their privacy policies:

    10. (a) Meta Audience Network. https://www.facebook.com/about/privacy/update
    11. (b) Google AdMob. https://policies.google.com/technologies/partner-sites
    12. (d) ironSource. https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy
    13. (c) Unity Ads. https://unity.com/legal/privacy-policy
    14. (e) Digital Turbine. https://www.digitalturbine.com/appreciate-end-user-privacy-policy
    15. (f) AppLovin. https://www.applovin.com/privacy
    16. (g) Chartboost. https://www.chartboost.com/legal/privacy-policy
    17. (h) Liftoff. https://liftoff.io/privacy-policy

  18. California Consumer Protection Act
    1. This section applies to California state residents only.

    2. As a company we do not directly collect, use or sell personal data.

    3. Our online products may use advertising partners and they can personalise your advertising experience. However to comply with CCPA you can opt out of personalized adverts using any of the methods outlined in Section 18.5 below.

    4. If you choose to opt out you will still see adverts that may not be as relevant to your interests, but they will not be using your data unless you have given our advertising partners permission directly. See Section 17.5 for a full list of our advertising partners.

    5. If you have given consent and change your mind, you can withdraw your consent at any time by either:

    6. (a) From within our apps. How do I change my advert preferences? (iOS and Android).
    7. (b) Enabling the Opt out of Ads Personalisation setting on your device. https://support.google.com/ads/answer/2662922?hl=en-GB (Android);
    8. (c) Enabling the Limit Ad Tracking setting on your device. https://support.apple.com/en-gb/HT202074 (iOS).

  19. Apple Arcade
    1. In this Section 19 we cover our Privacy Policy and Data Usage for our Apple Arcade games (“games”, “game”). This section only apples to users that have downloaded and installed our games using the Apple Arcade subscription service.

    2. Our games use only services provided by Apple. For information on data stored by Apple services, please refer to Apple’s Privacy Policy. We do not store personal or gameplay data on our servers. We do not share any data with third parties.

    3. All data described in this section is stored locally on your device or used for online game play (If allowed through Game Center) or sent only to Apple for optional use with Game Center or iCloud.

    4. Our games collect gameplay data and stores it locally on your device. This data is anonymous and only relates to the game. While playing our games online, gameplay data is sent to our online server and then onto your online opponent. This data is limited to the game you are playing online and is anonymous. Examples of gameplay data are;

    5. (a) Game environment data including positional information of objects.
    6. (b) Game statistics, such as players score, number of fouls, types of shots played etc…
    7. (c) Style of game being played.
    8. (d) Games played and lost, progress in local leagues and tournaments.

    9. If you do not want the Games to collect this data and information, then you must delete the games from your device. If you have enabled device synchronization using iCloud, you will also need to delete this data from iCloud.

    10. In order to participate in Apple’s Game Center, the Games will also collect (i) your Apple Game Center Team Player ID and (ii) your progress in the games (e.g., gameplay statistics and achievements). You can turn off tracking of this information by signing out of Game Center - but if you do, then online multiplayer features will not work, leaderboards and achievements will only update locally and not on Game Center.

    11. We handle data from children under 13 years of age, or equivalent minimum age in the child’s relevant jurisdiction, in the same way as other users and as described in this Policy. We do not collect any personal data or identifiers, only anonymous gameplay data for the functionality of the game only. If you are a parent, you can decline to have that gameplay data collected from your child by turning off iCloud for our game and signing your child out of Game Center, this will keep any gameplay data local to the device.

    12. If you have any questions, comments or concerns about this section please contact our Compliance Manager (See Section 20 for details).

  20. Data Compliance Manager
    1. Our Data Compliance Manager is Mr. Gavin Harwood and can be contacted via email: Contact us