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How To Play
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Article 4 of GDPR determines these important policy definitions:
Personal Data refers to any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
Processing refers to any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
Restriction of processing refers to the marking of stored personal data with the aim of limiting their processing in the future;
Filing system refers to any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis;
Controller refers to the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
Processor refers to a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
Recipient refers to a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. 2However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;
Third party refers to a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;
Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
Personal Data Breach refers to a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;
2. GDPR Principles
Article 5(1) of the GDPR sets out seven key principles which guide general data protection. The Crux Code Ltd acknowledge and set out to adhere to the following principles:
1. Lawfulness, Fairness and Transparency – Personal data collected or stored by The Crux Code will be processed lawfully, fairly and in a transparent manner in relation to individuals.
2. Purpose Limitation – The personal data collected by The Crux Code Ltd will be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.
3. Data Minimisation – The personal data collected by The Crux Code Ltd will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
4. Accuracy - The personal data collected by The Crux Code Ltd will be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
5. Storage Limitation – The personal data collected by The Crux Code Ltd will be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals
6. Integrity and Confidentiality – The personal data collected will be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
7. Accountability - The controller shall be responsible for, and be able to demonstrate compliance with the above terms and conditions of privacy.
3. Roles and Responsibilities
Not all organisations involved in the processing of personal data have the same degree of responsibility. It is the data controller that must exercise control over the processing and carry data protection responsibility for it.
Directive 94/46/EC Section 1(1) states:
“Data controller” means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be processed
“Data processor”, in relation to personal data, means any person (other than an employee of the data controller) who processes the data on behalf of the data controller.
“Processing”, in relation to information or data means obtaining, recording or holding the information or data or carrying out any operation or set of operations on the information or data, including—
a) organisation, adaptation or alteration of the information or data,
b) retrieval, consultation or use of the information or data,
c) disclosure of the information or data by transmission, dissemination or otherwise making available, or
d) alignment, combination, blocking, erasure or destruction of the information or data
Allocation of these roles
Data Controller – The following individual will take on this role: Damon Grose
Data Processor - The following individual will be responsible for this: Damon Grose
The Process of Storing Data
The Crux Code Ltd App sets out the following process of storing and handling personal data. In accordance with the design of the The Crux Code Ltd App, customer’s relevant information will be stored and processed as follows: The Crux Code Ltd do not store information but access relevant details stored within a secure server protected by the SSL. Such data will be accessed and used to provide relevant statistics concerning the use of the app and to provide trusted services. Data will only be seen by directors of The Crux Code Ltd through their personalised logins to the secure server. These passwords will be changed regularly and the server will not be accessed through unsecure laptops, PCs and mobile phones. Data will be destroyed as soon as customers decide to remove themselves from the service.
The Crux Code