Gravity Sketch encourages you to review the privacy statements of websites you choose to navigate to from Gravity Sketch so that you can understand how those websites collect, use and share your information. Gravity Sketch is not responsible for the privacy statements or other content on websites outside of the Gravity Sketch website.
Collection of your Personal Information
Gravity Sketch may collect and process personal data, such as your name and email address if you enter these on the contact form on our website or to fulfil our contractual obligations – to provide our software including the Platform, invoice and receive payment for software, send updates, news and information about our software and related services. We may gather additional personal or non-personal information in the future.
We may collect, use, store and transfer different kinds of personal data about you, we have grouped such data together as follows:
Identity Data includes first name, last name, username or similar identifier, title, gender, and social media accounts.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of software you have purchased from us.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device model and other technology on the devices you use to access this website or our Platform.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our Platform (including the amount of internet data used).
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Other Data includes other personal data or information relating to such personal data that you have uploaded to the Platform.
We do not knowingly collect any Special Categories of Personal Data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) or information about criminal convictions and offences.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your name, email address and contact details in person, or by filling in forms on our website or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:
Automated technologies through the use of our website or software. In your use of our Platform (including receiving our newsletter), certain Usage Data is transmitted to us such as the device you are using, and other such data.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our software). In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.
Purposes for which we will process your personal data
We may collect and use your personal information to operate our website(s) and mobile applications and deliver the software you have requested. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new user
Performance of a contract with you
To process and deliver software including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/software, to develop them and grow our business)
To administer and protect our business, website and software (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT software, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/software, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, software, Platform, products/software, marketing, customer relationships and experiences
(f) Marketing and Communications
Necessary for our legitimate interests (to define types of customers for our software, to keep our Platform updated and relevant, to develop our business and to inform our marketing strategy
To make suggestions and recommendations to you about goods or software that may be of interest to you
Necessary for our legitimate interests (to develop our products/software and grow our business)
Gravity Sketch may also use your personally identifiable information to inform you of other products or software available from Gravity Sketch and our partners. Gravity Sketch may also contact you via surveys to conduct research about your opinion of our website and software. Gravity Sketch does not sell, rent or lease or provide in any other way its customer lists to third parties.
Gravity Sketch may keep track of the websites and pages our users visit within Gravity Sketch and which software our users access. This data is used to deliver customised content within Gravity Sketch to customers whose behaviour indicates that they are interested in a particular subject area.
Change of purpose
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Transfer of Personal Data
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions and applicable law.
You agree that we may share data with the third parties set out below for the purposes set out in the table above:
All such third parties are required to maintain the confidentiality of your information.
Whenever we transfer your personal data out of the EEA or UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We may disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to:
(a) conform to the edicts of the law or comply with legal process served on Gravity Sketch Ltd or the site
(b) protect and defend the rights or property of Gravity Sketch Ltd; and,
(c) act under exigent circumstances to protect the personal safety of users of Gravity Sketch Ltd, or the public.
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. 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.
For example, sensitive information between your browser and the Platform is transferred in encrypted form using Secure Socket Layer (SSL). When transmitting sensitive information, you should always make sure that your browser can validate the Platform’s certificate.
Your passwords and information are stored in the Gravity Sketch’ database in encrypted form. We do not disclose your account details, postal or email addresses to anyone except when legally required to do so. However, it is your responsibility to keep your password secure. Unfortunately, the transmission of information via the internet is not completely secure. Although Gravity Sketch will do its best to protect your personal data, we cannot guarantee the security of your data transmitted to the Platform, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try and prevent any unauthorised access.
Gravity Sketch will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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. Data reviewed regularly for relevance. Any data deemed no-longer relevant is deleted. Gravity Sketch may keep your personal data for at least six years from the date of the last interaction for insurance and liability purposes. Gravity Sketch shall keep staff and consultant personal data for at least seven years. Gravity Sketch shall keep emails of clients and prospective clients for as long as it has a legitimate interest to do so. You can request details of retention periods for different aspects of your personal data by contacting us at [email protected].
As noted above, where we have taken steps to anonymise your personal data (so that it can no longer be associated with you) we may use this for analytical, research and statistical purposes and to help us to improve our products and software, in which case this is no longer personal data and we may use this information indefinitely without further notice to you.
It is also acknowledged that when you register to LandingPad.me, it is possible for Gravity Sketch to connect your LandingPad.me account to your Gravity Sketch account on Steam or Oculus Store, and that Gravity Sketch may use statistics relating to your usage of the Gravity Sketch Platform, including but not limited to organisation ID, username, login IP address, login and log out times, crash reports, file type, file size, tool usage and use of LandingPad.me, for analytical, research, and statistical purposes and to help us to improve our products and software.
Children Under Sixteen
Gravity Sketch does not knowingly collect personally identifiable information from children under the age of sixteen. If you are under the age of sixteen, you must ask your parent or guardian for permission to use this website or our software.
Opt-Out & Unsubscribe
We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from us by contacting us or selecting the “Unsubscribe” option on their email.
Your Legal Rights
You have the right to:
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Our Platform may use “cookies” to help you personalize your experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you visit the Gravity Sketch Website or App, a cookie helps Gravity Sketch to recall your information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, and so on. When you return to the same Gravity Sketch Website or App, the information you previously provided can be retrieved, so you can easily use the Gravity Sketch features that you customized.
You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Gravity Sketch Platform or websites you visit.
Gravity Sketch may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs. Gravity Sketch may also use web beacons and tracking URLs in emails to determine whether a recipient opened the email or accessed a certain link.
Gravity Sketch may use the following cookies:
If you wish to view a cookie’s code, just open your cookie file in your browser and click on a cookie to open it. You’ll see a short string of text and numbers. The numbers are your identification card, which can only be seen by the server that gave you the cookie. For information on how to do this on the browser of your mobile phone you will need to refer to your device manual.
The law allows us to store cookies on your computer if they are essential to the operation of our website. We need your consent to set non-essential cookies on your computer.
When you use our website for the first time we give you the opportunity to accept or decline cookies.
If you wish to withdraw consent for any reason, please contact Daniela Paredes Fuentes at [email protected].
Some of the cookies we use are essential if the website is to operate properly. If you decline them, some of the features of the website may not work as well as we intend and you may not be to access or use some features.
Unless you have set your browser so that it will decline cookies, our system will set some cookies as soon you use the website.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. For information about this you should look in your browser’s ‘help’ facility.
However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
If you have previously used our website and/or software and no longer wish to accept cookies, you should be aware that some cookies will have been set. You may delete these cookies at any time by following the instructions at: https://www.aboutcookies.org/how-to-delete-cookies/
More information on cookies can be found on allaboutcookies.org.
You may be able to opt out of receiving personalized advertisements from advertisers or advertising networks who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out sections on the websites of each of those organizations. Links to those sites are here:
Network Advertising Initiative: http://www.networkadvertising.org/choices/
Digital Advertising Alliance: http://www.aboutads.info/choices/
We use Google Analytics. The information generated by the Google Analytics cookie (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our websites and/or software compiling reports on activity and providing other software relating to activity and internet usage.
Google may also transfer this information to third parties where required to do so by law, or where third parties process the information on Google’s behalf.
To see more information on the cookies set by Google Analytics see: Cookies and Google Analytics.
To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout
Gravity Sketch Limited
3 Space International House
6 Canterbury Crescent, London
United Kingdom, SW9 7QD
Effective as of 6 November 2020
1.1 Unless otherwise defined herein, defined terms used in this Annex shall have the meaning giving to them in the Agreement.
1.2 For the purposes of this Annex, Data Protection Legislation means the Data Protection Act 2018 and Regulation (EU) 2016/679 of the European Parliament on the protection of natural persons with regard to the processing of personal data and any act of UK parliament which brings this into force.
1.3 For the purposes of this Annex the terms “controller”, “personal data”, “processor”, “sub-processor”, “data subject”, “process” and “processing” have the meaning set out in Data Protection Legislation.
2. DATA PROTECTION OBLIGATIONS
2.1 Customer Instructions. Customer appoints GRAVITY SKETCH as a processor to process personal data provided by Customer (of the types and category set out in the schedule to this Annex) on behalf of, and in accordance with, Customer’s instructions as set out in the Agreement and this Annex, as otherwise necessary to provide the services, or as otherwise agreed in writing (“Permitted Purposes”). The Customer is responsible for compliance with its obligations under Data Protection Legislation and will ensure that it has all necessary appropriate consents and notices in place to enable lawful transfer of the Personal Data to GRAVITY SKETCH for the duration and purposes of the Agreement. GRAVITY SKETCH agrees not to access or use personal data provided by Customer, except as necessary to maintain or provide the services, or as necessary to comply with the law or other binding governmental order.
2.2 Technical and Organisational Measures. GRAVITY SKETCH shall ensure that it has in place appropriate technical and organisational measures, reviewed and approved by the Customer, to protect against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data, appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures (those measures may include, where appropriate, pseudonymising and encrypting personal data, ensuring confidentiality, integrity, availability and resilience of its systems and services, and regularly assessing and evaluating the effectiveness of the technical and organisational measures adopted by it).
2.3 Assistance with compliance. GRAVITY SKETCH shall assist the Customer, at the Customer’s cost, in responding to any request from a data subject and in ensuring compliance with its obligations under Data Protection Legislation with respect to security, breach notifications, impact assessments and consultations with supervisory authorities or regulators.
2.4 Data Subject Rights. As part of the GRAVITY SKETCH services GRAVITY SKETCH undertakes to provide Customer with the ability to delete and amend personal data or request the same, which may be used by Customer to assist in its obligations under Data Protection Legislation with respect to responding to requests from data subjects.
2.5 Confidentiality Obligations of GRAVITY SKETCH Personnel. GRAVITY SKETCH will ensure that any person it authorises to process the personal data shall protect the personal data in accordance with GRAVITY SKETCH’s confidentiality obligations under the Agreement.
2.6 Return or Deletion of personal data. Following the date of termination, GRAVITY SKETCH shall be permitted to retain personal data in its possession for up to 6 years for liability and/or insurance purposes (except where GRAVITY SKETCH is required by law to keep a copy) unless GRAVITY SKETCH receives, within 10 business days prior to the scheduled time for disposal, a written request for the provision to the Customer of a copy of the then most recent back-up of the personal data held by GRAVITY SKETCH. If GRAVITY SKETCH receives such notice, it will use reasonable endeavours to provide that copy to the Customer within 10 business days.
2.7 Security Incident Reporting. If GRAVITY SKETCH becomes aware of any accidental, unauthorised or unlawful destruction, loss, alteration, or disclosure of, or access to personal data provided by Customer (a “Security Incident”), GRAVITY SKETCH shall notify Customer promptly (not later than 48 hours) and provide Customer promptly with a detailed description of the Security Incident and the identity of each affected data subject, with periodic updates, and any other information Customer may reasonably request in relation to such Security Incident.
2.8 Subcontracting. Customer consents to GRAVITY SKETCH engaging third party sub-processors to process personal data for Permitted Purposes provided that:
2.8.1 GRAVITY SKETCH imposes data protection terms on any sub-processor it appoints that require it to protect the personal data to the standard required by Data Protection Legislation; and
2.8.2 GRAVITY SKETCH remains liable for any breach of this Annex that is caused by an act, error or omission of its sub-processor.
2.9 Transfer of data outside the EEA. GRAVITY SKETCH shall not transfer personal data outside the EEA unless it has complied with its obligations under Data Protection Legislation in ensuring adequate safeguards in relation to such transfer.
2.10 Audit. GRAVITY SKETCH shall maintain complete and accurate records and information to demonstrate its compliance with this clause 2 and allow for audits by the Customer (or the Customer’s designated auditor) solely for the purpose of checking compliance with this Annex, provided that it is given reasonable notice of such audit, such audit is conducted in a manner so as not to interfere with GRAVITY SKETCH’ day to day business operations, and such audit is at Customer’s cost.
3.1 This Annex forms an integral part of the Agreement.
1.1 Nature and purpose of processing
To provide the services as described the Agreement.
1.2 Duration of the processing
For as long as is necessary to provide the services under the Agreement, and up to six years from termination for liability and/or insurance purposes.
1.3 Categories of Data Subject
Customer’s clients and Authorised Users and suppliers, or as specified in the Agreement
1.4 Types of personal data
Personal data including the following: