Privacy Policy

Privacy
Policy

Last updated: 1 September 2026


This privacy policy explains how XPlay Ltd (“XPlay”, “we”, “us” or “our”) collects, uses, stores and protects personal data.


Important information and who we are


Purpose of this privacy policy


This privacy policy gives you information about how XPlay collects and uses your personal data through your use of www.xplay.design, when you communicate or engage with us and when you enquire about or use our professional services.


This may include personal data you provide when you:


  • contact us through our website or by email;

  • enquire about our services;

  • become, or represent, a client, supplier, partner or prospective client;

  • work with us on a design, development, technology or consultancy project;

  • subscribe to communications from us;

  • attend a meeting or event involving XPlay; or

  • otherwise communicate or do business with us.


Our website and services are primarily intended for businesses and professional users. They are not intended for children and we do not knowingly collect personal data relating to children through our website.


Controller


XPlay Ltd is the controller responsible for your personal data.


XPlay Ltd is a private limited company registered in England and Wales under company number 16785967, with its registered office at:


124-128 City Road

, London, 

EC1V 2NX, 

United Kingdom.


If you have any questions about this privacy policy or how we use your personal data, please tap here to email us.


The types of personal data we collect about you


Personal data means information about an individual from which that person can be identified.


Depending on how you interact with XPlay, we may collect, use, store and transfer the following categories of personal data:


Identity Data includes your first name, last name, title, job title, company or organisation and other professional identifiers.


Contact Data includes your business or personal email address, telephone number, business address and other contact information you provide to us.


Business Data includes information relating to your company, organisation, role, business requirements, projects, enquiries and your professional relationship with XPlay.


Contract and Transaction Data includes information relating to proposals, statements of work, contracts, services supplied by or to XPlay, invoices, payments and transaction records.


Financial Data may include bank account details and other payment information where required for invoicing, receiving payments, making payments or managing our commercial relationship with you. XPlay does not normally need to collect payment card details through its public website.


Project Data includes information provided to us in connection with design, development, AI, software, payment, banking, hardware, IoT or other technology projects. This may include names and professional contact details of individuals involved in those projects.


Technical Data includes your internet protocol (IP) address, browser type and version, device information, time zone setting, operating system, platform and other technology used to access our website.


Usage Data includes information about how you interact with and use our website.


Communications Data includes correspondence between you and XPlay, including emails, enquiries, meeting information, feedback and other communications.


Marketing and Communications Data includes your preferences regarding communications or marketing from us.


We may also collect, use and share aggregated data, such as statistical information about use of our website.


Aggregated data may be derived from personal data but is not treated as personal data where it does not directly or indirectly identify an individual.


If we combine or connect aggregated data with personal data so that it can identify you, we will treat the combined information as personal data in accordance with this privacy policy.


Special category personal data


XPlay does not normally seek to collect special category personal data through its website or as part of its ordinary business activities.


This includes information concerning health, race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, genetic or biometric information or information concerning a person’s sex life or sexual orientation.


Please do not provide this type of information to us unless it is genuinely necessary and appropriate for a specific purpose.


How is your personal data collected?


We use different methods to collect personal data from and about you.


Information you provide directly to us


You may give us personal data when you:

  • contact XPlay through our website;

  • communicate with us by email, telephone or other means;

  • enquire about our services;

  • request a proposal or quotation;

  • enter into a contract with us;

  • participate in a project, meeting or business relationship with XPlay;

  • provide goods or services to XPlay;

  • subscribe to communications from us; or

  • otherwise interact with our business.


Automated technologies


As you interact with our website, we may automatically collect Technical Data and Usage Data concerning your equipment, browsing actions and patterns.

We may collect this information through cookies, server logs and similar technologies.

Please see our Cookie Policy for further information about the cookies and analytics technologies used by our website.


Third parties and publicly available sources


We may receive personal data from third parties and publicly available sources where appropriate for our business.


These may include:


  • analytics providers such as Google;

  • website, hosting and technology service providers;

  • professional advisers;

  • clients, suppliers and business partners;

  • companies or organisations with which you work;

  • payment and banking service providers;

  • professional networking platforms;

  • company websites and business directories; and

  • publicly available sources such as Companies House.


We will only process personal data obtained from these sources where we have an appropriate legal basis to do so.


How we use your personal data


Legal basis


UK data protection law requires us to have a lawful basis for processing personal data.


Depending on the circumstances, we may rely on one or more of the following:


Performance of a contract


Where processing is necessary to perform a contract with you or to take steps at your request before entering into a contract.


Legitimate interests


Where processing is necessary for XPlay’s legitimate business interests and those interests are not overridden by your fundamental rights and freedoms.


Our legitimate interests may include operating and developing our business, communicating with clients and prospective clients, providing and improving our services, protecting our systems and intellectual property, managing commercial relationships and maintaining the security of our website and technology.


Legal obligation


Where processing is necessary for us to comply with a legal, regulatory, accounting or other obligation that applies to XPlay.


Consent


Where you have given us clear consent to process your personal data for a particular purpose.

Where we rely on consent, you may withdraw that consent at any time.

Last updated: 1 September 2026


This privacy policy explains how XPlay Ltd (“XPlay”, “we”, “us” or “our”) collects, uses, stores and protects personal data.


Important information and who we are


Purpose of this privacy policy


This privacy policy gives you information about how XPlay collects and uses your personal data through your use of www.xplay.design, when you communicate or engage with us and when you enquire about or use our professional services.


This may include personal data you provide when you:


  • contact us through our website or by email;

  • enquire about our services;

  • become, or represent, a client, supplier, partner or prospective client;

  • work with us on a design, development, technology or consultancy project;

  • subscribe to communications from us;

  • attend a meeting or event involving XPlay; or

  • otherwise communicate or do business with us.


Our website and services are primarily intended for businesses and professional users. They are not intended for children and we do not knowingly collect personal data relating to children through our website.


Controller


XPlay Ltd is the controller responsible for your personal data.


XPlay Ltd is a private limited company registered in England and Wales under company number 16785967, with its registered office at:


124-128 City Road

, London, 

EC1V 2NX, 

United Kingdom.


If you have any questions about this privacy policy or how we use your personal data, please tap here to email us.


The types of personal data we collect about you


Personal data means information about an individual from which that person can be identified.


Depending on how you interact with XPlay, we may collect, use, store and transfer the following categories of personal data:


Identity Data includes your first name, last name, title, job title, company or organisation and other professional identifiers.


Contact Data includes your business or personal email address, telephone number, business address and other contact information you provide to us.


Business Data includes information relating to your company, organisation, role, business requirements, projects, enquiries and your professional relationship with XPlay.


Contract and Transaction Data includes information relating to proposals, statements of work, contracts, services supplied by or to XPlay, invoices, payments and transaction records.


Financial Data may include bank account details and other payment information where required for invoicing, receiving payments, making payments or managing our commercial relationship with you. XPlay does not normally need to collect payment card details through its public website.


Project Data includes information provided to us in connection with design, development, AI, software, payment, banking, hardware, IoT or other technology projects. This may include names and professional contact details of individuals involved in those projects.


Technical Data includes your internet protocol (IP) address, browser type and version, device information, time zone setting, operating system, platform and other technology used to access our website.


Usage Data includes information about how you interact with and use our website.


Communications Data includes correspondence between you and XPlay, including emails, enquiries, meeting information, feedback and other communications.


Marketing and Communications Data includes your preferences regarding communications or marketing from us.


We may also collect, use and share aggregated data, such as statistical information about use of our website.


Aggregated data may be derived from personal data but is not treated as personal data where it does not directly or indirectly identify an individual.


If we combine or connect aggregated data with personal data so that it can identify you, we will treat the combined information as personal data in accordance with this privacy policy.


Special category personal data


XPlay does not normally seek to collect special category personal data through its website or as part of its ordinary business activities.


This includes information concerning health, race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, genetic or biometric information or information concerning a person’s sex life or sexual orientation.


Please do not provide this type of information to us unless it is genuinely necessary and appropriate for a specific purpose.


How is your personal data collected?


We use different methods to collect personal data from and about you.


Information you provide directly to us


You may give us personal data when you:

  • contact XPlay through our website;

  • communicate with us by email, telephone or other means;

  • enquire about our services;

  • request a proposal or quotation;

  • enter into a contract with us;

  • participate in a project, meeting or business relationship with XPlay;

  • provide goods or services to XPlay;

  • subscribe to communications from us; or

  • otherwise interact with our business.


Automated technologies


As you interact with our website, we may automatically collect Technical Data and Usage Data concerning your equipment, browsing actions and patterns.

We may collect this information through cookies, server logs and similar technologies.

Please see our Cookie Policy for further information about the cookies and analytics technologies used by our website.


Third parties and publicly available sources


We may receive personal data from third parties and publicly available sources where appropriate for our business.


These may include:


  • analytics providers such as Google;

  • website, hosting and technology service providers;

  • professional advisers;

  • clients, suppliers and business partners;

  • companies or organisations with which you work;

  • payment and banking service providers;

  • professional networking platforms;

  • company websites and business directories; and

  • publicly available sources such as Companies House.


We will only process personal data obtained from these sources where we have an appropriate legal basis to do so.


How we use your personal data


Legal basis


UK data protection law requires us to have a lawful basis for processing personal data.


Depending on the circumstances, we may rely on one or more of the following:


Performance of a contract


Where processing is necessary to perform a contract with you or to take steps at your request before entering into a contract.


Legitimate interests


Where processing is necessary for XPlay’s legitimate business interests and those interests are not overridden by your fundamental rights and freedoms.


Our legitimate interests may include operating and developing our business, communicating with clients and prospective clients, providing and improving our services, protecting our systems and intellectual property, managing commercial relationships and maintaining the security of our website and technology.


Legal obligation


Where processing is necessary for us to comply with a legal, regulatory, accounting or other obligation that applies to XPlay.


Consent


Where you have given us clear consent to process your personal data for a particular purpose.

Where we rely on consent, you may withdraw that consent at any time.

Purposes for which we use your personal data


We may use your personal data for the following purposes:


To respond to enquiries and communicate with you


We may use Identity, Contact, Business and Communications Data to respond to enquiries and communicate with you about XPlay and our services.
Legal basis: Legitimate interests or taking steps before entering into a contract.


To assess and discuss potential projects or services


We may use Identity, Contact, Business, Project and Communications Data to understand your requirements, discuss potential projects and prepare appropriate proposals.
Legal basis: Legitimate interests or taking steps before entering into a contract.


To provide our services


We may use Identity, Contact, Business, Project and Communications Data to provide design, development, AI, software, payments, hardware and consultancy services.
Legal basis: Performance of a contract and legitimate interests.


To manage our business relationships


We may use Identity, Contact, Business, Contract, Transaction and Communications Data to manage our relationships with clients, suppliers, contractors and business partners.
Legal basis: Performance of a contract and legitimate interests.


To prepare proposals, contracts and invoices


We may use Identity, Contact, Business, Contract and Financial Data to prepare proposals, statements of work, contracts and invoices.
Legal basis: Performance of a contract and legitimate interests.


To manage payments and accounting
We may use Identity, Contact, Financial and Transaction Data to receive and make payments and maintain appropriate financial and accounting records.
Legal basis: Performance of a contract and compliance with legal obligations.


To operate and protect our website and technology
We may use Technical and Usage Data to operate, maintain and secure our website, systems and technology.
Legal basis: Legitimate interests.


To understand and improve our website
We may use Technical and Usage Data to understand how visitors use our website and to improve its design, performance, content and usability.
Legal basis: Consent where required and legitimate interests where permitted.


To protect XPlay and our intellectual property
We may use Identity, Contact, Business, Technical and Communications Data where necessary to protect our business, systems, confidential information and intellectual property.
Legal basis: Legitimate interests and compliance with legal obligations where applicable.


To manage legal matters
We may process relevant personal data where necessary to establish, exercise or defend legal claims.
Legal basis: Legitimate interests and compliance with legal obligations where applicable.


To comply with legal and regulatory requirements
We may use Identity, Contact, Contract, Financial and Transaction Data to meet applicable legal, tax, accounting and regulatory requirements.
Legal basis: Compliance with legal obligations.


To send relevant business communications
We may use Identity, Contact, Business and Marketing Data to send relevant information about XPlay, our services, projects, technology or other business developments where permitted.
Legal basis: Legitimate interests or consent, depending on the circumstances..

Purposes for which we use your personal data


We may use your personal data for the following purposes:


To respond to enquiries and communicate with you


We may use Identity, Contact, Business and Communications Data to respond to enquiries and communicate with you about XPlay and our services.
Legal basis: Legitimate interests or taking steps before entering into a contract.


To assess and discuss potential projects or services


We may use Identity, Contact, Business, Project and Communications Data to understand your requirements, discuss potential projects and prepare appropriate proposals.
Legal basis: Legitimate interests or taking steps before entering into a contract.


To provide our services


We may use Identity, Contact, Business, Project and Communications Data to provide design, development, AI, software, payments, hardware and consultancy services.
Legal basis: Performance of a contract and legitimate interests.


To manage our business relationships


We may use Identity, Contact, Business, Contract, Transaction and Communications Data to manage our relationships with clients, suppliers, contractors and business partners.
Legal basis: Performance of a contract and legitimate interests.


To prepare proposals, contracts and invoices


We may use Identity, Contact, Business, Contract and Financial Data to prepare proposals, statements of work, contracts and invoices.
Legal basis: Performance of a contract and legitimate interests.


To manage payments and accounting
We may use Identity, Contact, Financial and Transaction Data to receive and make payments and maintain appropriate financial and accounting records.
Legal basis: Performance of a contract and compliance with legal obligations.


To operate and protect our website and technology
We may use Technical and Usage Data to operate, maintain and secure our website, systems and technology.
Legal basis: Legitimate interests.


To understand and improve our website
We may use Technical and Usage Data to understand how visitors use our website and to improve its design, performance, content and usability.
Legal basis: Consent where required and legitimate interests where permitted.


To protect XPlay and our intellectual property
We may use Identity, Contact, Business, Technical and Communications Data where necessary to protect our business, systems, confidential information and intellectual property.
Legal basis: Legitimate interests and compliance with legal obligations where applicable.


To manage legal matters
We may process relevant personal data where necessary to establish, exercise or defend legal claims.
Legal basis: Legitimate interests and compliance with legal obligations where applicable.


To comply with legal and regulatory requirements
We may use Identity, Contact, Contract, Financial and Transaction Data to meet applicable legal, tax, accounting and regulatory requirements.
Legal basis: Compliance with legal obligations.


To send relevant business communications
We may use Identity, Contact, Business and Marketing Data to send relevant information about XPlay, our services, projects, technology or other business developments where permitted.
Legal basis: Legitimate interests or consent, depending on the circumstances..

Marketing


XPlay is primarily a business-to-business company.


We may occasionally send information about XPlay, our services, technology, projects, events or other relevant business developments to professional contacts where permitted by law.


Where consent is required, we will obtain it before sending marketing communications.


You can ask us to stop sending marketing communications at any time by tapping here to emailing us here or using an unsubscribe option provided in the relevant communication.


Opting out of marketing communications will not affect service-related, contractual or other necessary communications between you and XPlay.


Artificial intelligence and third-party technology


As a technology business, XPlay may use software, cloud services and artificial intelligence tools to support aspects of our internal operations and professional services.


Where personal data is processed using such technology, we will seek to use it only where appropriate and in accordance with applicable data protection requirements.


We do not intentionally use confidential client information or personal data to train publicly available artificial intelligence models unless this has been appropriately agreed or otherwise lawfully permitted.


Where we use third-party technology providers to process personal data on our behalf, we will take appropriate steps to protect that information and manage those providers in accordance with applicable data protection law.


Sharing your personal data


We may share personal data with third parties where reasonably necessary to operate XPlay, provide our services or comply with legal obligations.


These may include:


  • cloud hosting and IT providers;

  • website and analytics providers;

  • professional advisers, including lawyers, accountants and auditors;

  • banks and payment service providers;

  • contractors, consultants and specialist service providers working with XPlay;

  • clients or business partners where necessary for a relevant project;

  • insurers;

  • government, regulatory, tax or law enforcement authorities where required by law; and

  • prospective purchasers, investors or advisers in connection with a potential investment, financing, restructuring, merger or sale of all or part of our business.


We require third parties processing personal data on our behalf to handle that information appropriately and in accordance with applicable law.


We do not sell your personal data.


International transfers


Some of the technology and service providers used by XPlay may process or store personal data outside the United Kingdom.


Where we transfer personal data outside the UK, we will take appropriate measures where required by data protection law to ensure that the information receives an appropriate level of protection.


These measures may include transferring information to a country recognised as providing adequate protection or using appropriate contractual safeguards.


You can contact us if you would like further information about safeguards relevant to your personal data.


Data security


We take appropriate technical and organisational measures designed to protect personal data against accidental loss, unauthorised access, alteration, disclosure or misuse.


Access to personal data is restricted where appropriate to employees, contractors, advisers and service providers who have a legitimate need to access it.


However, no internet transmission or information storage system can be guaranteed to be completely secure.


Data retention


We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including satisfying legal, regulatory, tax, accounting and reporting requirements.

The appropriate retention period depends on factors including the amount, nature and sensitivity of the personal data, the purposes for which it is processed, legal requirements and whether those purposes can be achieved by other means.

We may retain information for longer where reasonably necessary in connection with a complaint, dispute, investigation or potential legal claim.

When personal data is no longer required, we will delete, anonymise or otherwise securely dispose of it where appropriate.


Your legal rights


Under UK data protection law, depending on the circumstances, you may have the right to:


  • request access to personal data we hold about you;

  • request correction of inaccurate or incomplete personal data;

  • request erasure of your personal data in certain circumstances;

  • object to processing based on legitimate interests in certain circumstances;

  • request restriction of processing;

  • request transfer of certain personal data to you or another organisation;

  • withdraw consent at any time where we rely on consent; and

  • complain to the relevant data protection supervisory authority.


These rights are subject to legal conditions and exemptions.


If you wish to exercise any of these rights, please tap here to email us.


We may need to request information from you to confirm your identity before responding to a request. This is a security measure intended to ensure personal data is not disclosed to someone who is not entitled to receive it.


Complaints


We would appreciate the opportunity to address any concerns about how we handle your personal data directly.


You can tap here to email us.


You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection matters.


Third-party links


Our website may contain links to third-party websites, services or applications.


Clicking those links or enabling those connections may allow third parties to collect or process information about you.


We do not control third-party websites and are not responsible for their privacy practices. We encourage you to read the privacy policy of any third-party website or service you use.


Cookies


Our website uses cookies and similar technologies as described in our Cookie Policy.


Where required, non-essential cookies will only be used after you have provided the appropriate consent.


Changes to this privacy policy


We may update this privacy policy from time to time to reflect changes in our business, website, services, technology or legal obligations.


The latest version will be published on our website and the date at the top of this policy will indicate when it was most recently updated.


Contact us


If you have questions about this privacy policy, our use of your personal data or wish to exercise your data protection rights, please contact:


XPlay Ltd
124-128 City Road
London
EC1V 2NX
United Kingdom


Company number: 16785967


Email: Tap here to email us.

Marketing


XPlay is primarily a business-to-business company.


We may occasionally send information about XPlay, our services, technology, projects, events or other relevant business developments to professional contacts where permitted by law.


Where consent is required, we will obtain it before sending marketing communications.


You can ask us to stop sending marketing communications at any time by tapping here to emailing us here or using an unsubscribe option provided in the relevant communication.


Opting out of marketing communications will not affect service-related, contractual or other necessary communications between you and XPlay.


Artificial intelligence and third-party technology


As a technology business, XPlay may use software, cloud services and artificial intelligence tools to support aspects of our internal operations and professional services.


Where personal data is processed using such technology, we will seek to use it only where appropriate and in accordance with applicable data protection requirements.


We do not intentionally use confidential client information or personal data to train publicly available artificial intelligence models unless this has been appropriately agreed or otherwise lawfully permitted.


Where we use third-party technology providers to process personal data on our behalf, we will take appropriate steps to protect that information and manage those providers in accordance with applicable data protection law.


Sharing your personal data


We may share personal data with third parties where reasonably necessary to operate XPlay, provide our services or comply with legal obligations.


These may include:


  • cloud hosting and IT providers;

  • website and analytics providers;

  • professional advisers, including lawyers, accountants and auditors;

  • banks and payment service providers;

  • contractors, consultants and specialist service providers working with XPlay;

  • clients or business partners where necessary for a relevant project;

  • insurers;

  • government, regulatory, tax or law enforcement authorities where required by law; and

  • prospective purchasers, investors or advisers in connection with a potential investment, financing, restructuring, merger or sale of all or part of our business.


We require third parties processing personal data on our behalf to handle that information appropriately and in accordance with applicable law.


We do not sell your personal data.


International transfers


Some of the technology and service providers used by XPlay may process or store personal data outside the United Kingdom.


Where we transfer personal data outside the UK, we will take appropriate measures where required by data protection law to ensure that the information receives an appropriate level of protection.


These measures may include transferring information to a country recognised as providing adequate protection or using appropriate contractual safeguards.


You can contact us if you would like further information about safeguards relevant to your personal data.


Data security


We take appropriate technical and organisational measures designed to protect personal data against accidental loss, unauthorised access, alteration, disclosure or misuse.


Access to personal data is restricted where appropriate to employees, contractors, advisers and service providers who have a legitimate need to access it.


However, no internet transmission or information storage system can be guaranteed to be completely secure.


Data retention


We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including satisfying legal, regulatory, tax, accounting and reporting requirements.

The appropriate retention period depends on factors including the amount, nature and sensitivity of the personal data, the purposes for which it is processed, legal requirements and whether those purposes can be achieved by other means.

We may retain information for longer where reasonably necessary in connection with a complaint, dispute, investigation or potential legal claim.

When personal data is no longer required, we will delete, anonymise or otherwise securely dispose of it where appropriate.


Your legal rights


Under UK data protection law, depending on the circumstances, you may have the right to:


  • request access to personal data we hold about you;

  • request correction of inaccurate or incomplete personal data;

  • request erasure of your personal data in certain circumstances;

  • object to processing based on legitimate interests in certain circumstances;

  • request restriction of processing;

  • request transfer of certain personal data to you or another organisation;

  • withdraw consent at any time where we rely on consent; and

  • complain to the relevant data protection supervisory authority.


These rights are subject to legal conditions and exemptions.


If you wish to exercise any of these rights, please tap here to email us.


We may need to request information from you to confirm your identity before responding to a request. This is a security measure intended to ensure personal data is not disclosed to someone who is not entitled to receive it.


Complaints


We would appreciate the opportunity to address any concerns about how we handle your personal data directly.


You can tap here to email us.


You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection matters.


Third-party links


Our website may contain links to third-party websites, services or applications.


Clicking those links or enabling those connections may allow third parties to collect or process information about you.


We do not control third-party websites and are not responsible for their privacy practices. We encourage you to read the privacy policy of any third-party website or service you use.


Cookies


Our website uses cookies and similar technologies as described in our Cookie Policy.


Where required, non-essential cookies will only be used after you have provided the appropriate consent.


Changes to this privacy policy


We may update this privacy policy from time to time to reflect changes in our business, website, services, technology or legal obligations.


The latest version will be published on our website and the date at the top of this policy will indicate when it was most recently updated.


Contact us


If you have questions about this privacy policy, our use of your personal data or wish to exercise your data protection rights, please contact:


XPlay Ltd
124-128 City Road
London
EC1V 2NX
United Kingdom


Company number: 16785967


Email: Tap here to email us.

  • KEEP XPLAYING

Warm introductions work best.

Cold ones are welcome too.

  • KEEP XPLAYING

Warm introductions work best.

Cold ones are welcome too.