Ork Manager – Privacy policy

At Goblinsama ltd. ("Goblinsama") we understand the importance of user privacy and data protection for those using its game Ork Manager: Coal and Top hats (the "Game").

In this policy, we describe the type of personal information that we may collect from you, what we do with them, how we process them and which steps we take to protect your privacy.

1. Relevant legislation

Along with our business, the Game are designed to comply with EU General Data Protection Regulation 2018 (GDPR), with regards to data protection and User privacy.

2. Who we are

Goblinsama is the data controller for this website. Our registered office is 3 St Davids Business Park, Dalgety Bay, Dunfermline, Fife, United Kingdom, KY11 9PF.

The data controller is who decides how your personal data is processed and for what purposes.

3. Which personal data we collect, how and why

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at <>.

3.1. Personal information

Personal information is any information that can be used to identify you, including your name and contact details.

Personal and non-personal data is collected directly from you, such as through registration or by logging the activities in the Game.

The type and quantity of information we hold about you and how we use it will depend on the purpose for which you provided it.

We may process certain types of personal data about you as follows:

  • Identity Data: may include your first name, last name, date of birth.
  • Contact Data: may include your email address.
  • Financial Data: may include your bank account and payment card details.
  • Transaction Data: may include details about payments between us and other details of purchases made by you.
  • Technical Data: may include your login data, Internet Protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
  • Profile Data: may include your username and password, purchases or orders, your interests, preferences, and feedback.
  • Usage Data: may include information about how you use our website, products and services.
  • Marketing and Communications Data: may include your preferences in receiving marketing communications from us and our third parties, and your communication preferences.

We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

3.2. How we collect your data

3.2.1. Direct interactions

You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including the following. In-game user registration

In order to play to the Game, you are required to complete a registration.

You will have to provide:

  • A public username (it will be published in online scoring boards when available)
  • Date of birth
  • Your email address
  • A secure password

The Game will send you email advises, for example to remind you deadlines or communicate updates, match results, etc.

To do this, we forward your email address and username to Mailgun, which is our mailing service provider.

You can unsubscribe at any time by sending us an email at our contact details (see Section 3).

We consider Mailgun as a third-party data processor (see Section 5). In-game purchases

The Game offers you the possibility of purchasing an in-game virtual currency to be used in the game.

All these type of transactions are managed by our third-party Humble Bundle, and the only personal information we obtain is your email address.

Other non personal data we receive are country where the transaction took place, the currency, the processor, and the platform.

You can find more about our third-party processors in Section 5. Newsletter

Just as you, we loathe Spam! If you would like to subscribe to our newsletter, you will receive periodic newsletter email from us (about once or twice a month), with the latest updates about Ork Manager, our other games and offers.

If you sign up for our newsletter, we will have your First and Last name and your email address, and these details will be forwarded to MailChimp, which is our email marketing service provider.

The email address will be stored in the MailChimp database until we change provider or you cancel your subscription to the newsletter. You can unsubscribe at any time by clicking the unsubscribe link at the bottom of the newsletter. If you unsubscribe, Goblinsama may still send you non-promotional communication, such as emails about your account, providing the Game or our ongoing business relations.

If you are under 13, you must get your parental consent before joining our email newsletter.

We consider MailChimp as a third-party data processor (see Section 5). Other direct interaction

You may provide data by communicating with us by post, phone, email or otherwise, including when you:

  • ask information about services;
  • give us feedback.

All the data will be processed only to answer your queries. We may use third-party to process your data (Section 5) and may retain data according to this privacy policy (Section 6).

3.2.2. Automated technologies or interactions

As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns.

We collect this data by using cookies, server logs and similar technologies.

We may also receive Technical Data about you if you visit other websites that use our cookies.

Please check our cookie policy (linked in paragraph 8.2) for further details.

3.2.3. Third parties or publicly available sources

We may receive personal data about you from various third parties and public sources as set out below. Technical Data

Technical Data from the following parties:

  • analytics providers such as Google based outside the EU;
  • advertising networks [such as Facebook, Twitter, Linkedin and YouTube based [inside OR outside] the EU];
  • search information providers [such as Google based [inside OR outside] the EU]. Contact, Financial and Transaction Data

Contact, Financial and Transaction Data from providers of technical, payment and delivery services [such as Humble Bundle, PayPal, and Stripe based [inside OR outside] the EU].

3.3. How we use your data

We will only use your personal data when legally permitted. The most common uses of your personal data are:

  • Where we need to perform the contract between us.
  • Where you give us your consent.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

You have the right to withdraw consent to marketing at any time by emailing us (at the address linked in paragraph 3).

4. How we store your personal data

Your data is stored in an SQL database.

This and the website are hosted on a VPS located in the United Kingdom.

All the traffic between your browser and our server is encrypted using HTTPS protocol.

5. About our third-party data processors

As many websites, we use some third-party service providers, that process personal data on our behalf. All these providers have been carefully selected and complies to the legislation of point 1.

  • Google (privacy policy) – based in US; compliant with the EU-US privacy shield
  • MailChimp (privacy policy) – based in US; compliant with the EU-US privacy shield
  • Mailgun (privacy policy) – company based in US, server located in EU; compliant with the EU-US privacy shield
  • Humble Bundle (privacy policy) – based in US; compliant with the EU-US privacy shield
  • OVH (privacy policy) – based in UK, EU
  • Facebook (privacy policy) – based in US; compliant with the EU-US privacy shield

Also, your personal data may be shared with parties set out below for the purposes set out in Section 3 above:

  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

5.1. International transfers

We share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA).

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  • Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Please email us at email address if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6. How long we keep your data

The information that we store won't be kept more than what is necessary for the purpose for which they have been collected. This means that data should be destroyed or erased from our system when no longer required.

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.

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

In some circumstances you can ask us to delete your data: see Section 8.

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.

7. Data security and breaches

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. What are your rights?

You have the right to be informed about the processing of your personal data ('right to be informed').

You have a right to ask us to confirm whether we are processing information about you, and to request access to this information ('right of access').

If at any point you believe the information we process on you is inaccurate you can request to have it corrected or deleted ('right to rectification'). We want to ensure that your personal data are always updated: if you change them, please let us know and we will be happy to update them for you.

You have the right to ask us to erase your data and prevent processing, for example withdrawing your consent ('right to erasure').

You can ask us to restrict our processing, for example if you are unsure of the accuracy of the data we process ('right to restrict processing').

You have the right to obtain and reuse your personal data for your own purposes ('the right to data portability').

You have the right to object to the processing on legitimate interests, on the purpose of research and statistics and for direct marketing ('right to object'), unless the processing is for demonstrable compelling legitimate grounds or for establishment, exercise or defence of legal claims.

If you wish to exercise any of your right, you can contact us at the contact details mentioned above.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ( We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

8.1. Third-party links

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

8.2. Cookies

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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see (

9. About this privacy policy

This privacy policy may change from time to time in line with legislation. We won't notify you any time it is updated, but we recommend you check this page occasionally for any policy changes.

If we make significant changes to this Privacy Policy, we will post a notice in the Game along with the updated Privacy Policy or contact you by email (using the address you have provided in the Game).

Your continued use of our Game will signify your acceptance of the changes to this Privacy Policy.