Privacy Policy

Last updated: 13/4/2026

Effective date: 13/4/2026

1. Introduction

1.1 This privacy policy ("Privacy Policy") explains how Walrus Ventures Ltd ("we", "us" or "our"), a company registered in England and Wales, collects, uses, stores and shares your personal data when you visit our website manipulategame.com (the "Site") or purchase products from us ("Products").

1.2 We are the data controller responsible for your personal data. Our contact details are:

Company: Walrus Ventures Ltd

Email: Josh@WalrusVentures.com

1.3 We are committed to protecting your privacy and handling your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1.4 This Privacy Policy should be read alongside our Terms and Conditions.

2. Personal Data We Collect

We may collect the following categories of personal data:

2.1 Information you provide directly

(a) Name (first and last) — collected when you register an account or place an order.

(b) Email address — collected when you register an account, sign up to our mailing list, or contact us.

(d) Delivery and billing address — collected when you place an order.

(e) Payment details — collected when you place an order (processed by our payment provider — see Section 7).

(f) Any other information you include in correspondence with us — collected when you contact us via email or social media.

2.2 Information collected automatically

When you visit our Site, we may automatically collect:

(a) Device and browser information — browser type/version, operating system, screen resolution.

(b) Network information — IP address.

(d) Cookie data — see Section 5 below.

3. How and Why We Use Your Personal Data

Under UK GDPR, we must have a lawful basis for processing your personal data. Below we set out the purposes for which we process your data and the legal basis we rely on in each case.

(a) To fulfil your order (processing, payment, dispatch, returns) — Lawful basis: Performance of a contract with you.

(b) To manage your account on the Site — Lawful basis: Performance of a contract with you.

(c) To respond to your enquiries and provide customer support — Lawful basis: Legitimate interest (to respond to communications).

(d) To improve our Site and Products — Lawful basis: Legitimate interest (to enhance our offerings).

(e) To analyse how customers use the Site — Lawful basis: Legitimate interest (to understand usage patterns).

(f) To send you marketing communications about our Products and news — Lawful basis: Consent (which you can withdraw at any time — see Section 9).

(g) To detect and prevent fraud or illegal activity — Lawful basis: Legitimate interest (to protect our business and customers); legal obligation.

(h) To comply with legal obligations — Lawful basis: Legal obligation.

Where we rely on legitimate interest, we have assessed that our interests do not override your fundamental rights and freedoms. You can ask us for details of this assessment at any time.

4. Data Retention

4.1 We retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy, or as required by law.

(a) Order and transaction records — retained for 6 years from the date of the transaction (to comply with HMRC requirements).

(b) Customer account data — retained until you request deletion of your account, or after 3 years of inactivity.

(d) Website analytics and cookie data — retained as per cookie expiry (see Section 5).

(e) Customer support correspondence — retained for 2 years from resolution of the enquiry.

4.2 When personal data is no longer required, we will securely delete or anonymise it.

5. Cookies and Similar Technologies

5.1 Cookies are small text files placed on your device when you visit our Site. They help us provide you with a good experience and allow us to improve the Site.

5.2 Types of cookies we use

(a) Strictly necessary cookies — essential for the Site to function (e.g. shopping basket, security). Consent is not required for these cookies.

(b) Performance / Analytics cookies — help us understand how visitors use the Site (e.g. most visited pages). Data is typically anonymised. Your consent is required.

(d) Targeting / Advertising cookies — deliver relevant advertisements and track campaign effectiveness. Your consent is required.

5.3 Managing your cookie preferences

(a) When you first visit our Site, a cookie banner will ask for your consent to non-essential cookies.

(b) You can change your preferences at any time by clicking "Manage Cookies" in the Site footer.

(c) You can also control cookies through your browser settings. Note that blocking certain cookies may affect Site functionality.

5.4 For more information about cookies, visit www.allaboutcookies.org.

6. Who We Share Your Data With

6.1 We do not sell your personal data.

6.2 We may share your personal data with the following categories of third parties, only to the extent necessary:

(a) Payment processors — to process card/digital payments securely.

(b) Fulfilment and delivery partners — to dispatch and deliver your orders.

(d) Analytics providers — to analyse Site usage (anonymised where possible).

(e) Professional advisors — for legal, accounting or insurance purposes.

(f) Law enforcement or regulators — where required by law or to protect our legal rights.

6.3 In the event of a merger, acquisition or reorganisation, your personal data may be transferred to the successor entity, and we will notify you of any such change.

7. Payment Processing

7.1 When you make a purchase, your payment is processed securely by our third-party payment provider. We do not store your full credit or debit card details on our servers.

7.2 Your payment data is handled in accordance with the Payment Card Industry Data Security Standard (PCI DSS).

8. International Data Transfers

8.1 Your personal data may be transferred to, and processed in, countries outside of the United Kingdom — for example, if our service providers or their servers are located overseas.

8.2 Where we transfer personal data outside the UK, we ensure appropriate safeguards are in place, including:

(a) Transfers to countries with an adequacy decision from the UK Secretary of State.

(b) Use of UK International Data Transfer Agreements (IDTAs) or Standard Contractual Clauses (SCCs) approved by the Information Commissioner's Office (ICO).

8.3 You may contact us for details of the specific safeguards applied to any transfer.

9. Your Rights

9.1 Under UK GDPR, you have the following rights in relation to your personal data:

(a) Access — you can request a copy of the personal data we hold about you.

(b) Rectification — you can request correction of inaccurate or incomplete data.

(c) Erasure ("right to be forgotten") — you can request deletion of your data where there is no compelling reason for us to continue processing it.

(d) Restriction — you can request that we restrict processing of your data in certain circumstances.

(e) Data portability — you can request your data in a structured, commonly used, machine-readable format.

(f) Object — you can object to processing based on legitimate interest or for direct marketing.

(g) Withdraw consent — where processing is based on consent, you can withdraw it at any time without affecting prior processing.

9.2 To exercise any of these rights, please contact us at Josh@WalrusVentures.com. We will respond within one month of your request.

9.3 You will not normally be charged a fee, but we may charge a reasonable fee if your request is clearly unfounded or excessive.

9.4 We may need to verify your identity before processing your request.

10. Marketing and Opting Out

10.1 We will only send you marketing communications where you have given your consent (e.g. by signing up to our mailing list).

10.2 You can opt out of marketing at any time by:

(a) Clicking the unsubscribe link in any marketing email.

(b) Emailing us at Josh@WalrusVentures.com with the subject "Unsubscribe".

10.3 Opting out of marketing will not affect communications necessary to fulfil your orders or manage your account.

11. Children's Privacy

11.1 Our Site and Products are not directed at children under the age of 13, and we do not knowingly collect personal data from children under 13.

11.2 If you believe we have collected data from a child under 13, please contact us immediately and we will take steps to delete it.

12. Data Security

12.1 We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure or destruction.

12.2 However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

12.3 If we become aware of a data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours and, where required, notify you without undue delay.

13. Links to Third-Party Websites

13.1 Our Site may contain links to third-party websites (e.g. social media platforms, review sites, Kickstarter). We are not responsible for the privacy practices of those sites.

13.2 We encourage you to read the privacy policy of every website you visit.

14. Complaints

14.1 If you are unhappy with how we have handled your personal data, please contact us first at Josh@WalrusVentures.com so we can try to resolve the issue.

14.2 You also have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Website: ico.org.uk

Telephone: 0303 123 1113

Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

15. Changes to This Privacy Policy

15.1 We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated "Last updated" date.

15.2 Where changes are significant, we will make reasonable efforts to notify you (e.g. via email or a notice on the Site).

15.3 We encourage you to review this Privacy Policy periodically.

16. Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us:

Email: Josh@WalrusVentures.com

Company: Walrus Ventures Ltd