WANNA PLAY GAMES LTD

PRIVACY POLICY
Updated and Effective as of
January 20, 2022

TABLE OF CONTENTS
1.General.

2. Personal Data (types, purposes, legal basis).
3. Ways of using personal information.
4. Third-party processing personal data.
5. Store personal information.
6. Personal data protection.
7. User’s rights.
8. Age required.
9. Specific provisions applicable under California privacy law.
10. Contact details

1. GENERAL

Thank you for choosing to be part of our community! This privacy policy describes how our organization Wanna Play Games LTD is the legal entity incorporated in accordance with the laws of the Republic of Cyprus under the registration number HE 420296 with the following address of registration: 28 Oktovriou 367, MEDITERRANEAN COURT, 1st Floor, Flat/Office A5, 3107, Limassol, Cyprus (collectively, “we”, “us”, or “our”) collects, uses, stores, transfers and discloses personal information from our Users in connection with our Services. One way to protect your privacy is to learn how will be used personal information before you give it out. We attach great importance to your privacy right and truthfully explaining why and how we use your information. We hope you take some time to read through it carefully, as it is important. 

For the purpose of the General Data Protection Regulation 2016/679 and any implementing legislation (the "GDPR"), Wanna Play Games LTD will be the data controller responsible for any personal data we process.

In this privacy policy, the following definitions are used:
«Services» refers to our Apps, Websites, and any related services or properties we control; 
«Apps» refers to games, applications, and other products produced by us on any and all platforms; 
«Websites» refers to websites and other online properties we control, including http://wannaplay.games/;
«Personal Data» is used when referring to personal data that relates to you as an identified or identifiable individual; 
«Anonymous data» include data where the identity has been removed; 
«User, consumer» is any third party that use our Services. 

We have the right to update this Privacy Policy from time to time so please be sure to check regularly. We will notify you of any material changes by posting the new Privacy Policy on the primary access points to the Services or as otherwise required by applicable law.

Please read this Policy carefully and do not hesitate to contact us if you have any questions at support@wannaplay.games. Where applicable, if you do not provide us the relevant Personal Data, you may not be able to use our Services completely. You should not use the Services if you do not agree with this Policy, our Terms of Use.
How to contact us:

Name: Wanna Play Games LTD
Address: 28 Oktovriou 367, MEDITERRANEAN COURT, 1st Floor, Flat/Office A5, 3107, Limassol, Cyprus
E-mail: support@wannaplay.games

2. PERSONAL DATA (TYPES, PURPOSES, LEGAL BASIS)

When you use our Services, we can collect, use, receive, process, transfer and share some of your Personal Data for different legitimate purposes. You will find below explanations regarding what Personal Data we may collect, the reasons why we may collect this data and the legal bases relied on in each case. Please, be notice that the types of information that we may collect depend on how you use the Services and interact with us. 

We may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes. In such cases we may use anonymous information without further notice to you since such information is not considered as Personal Data and cannot be connected with you.

* Please note that location data refers only to data about a region/ state. We do no track your exact location.
We do not collect sensitive personal data and personal data that directly identifies end users (such as name, addresses, credit cards or other similarly regulated financial information, health information, or any other type).


We generally process your personal data on the following legal bases:Contract. You have entered a contract with us and we need to use some of your personal data to provide services you have requested or take steps that you request prior to providing services. For example, we cannot create an account for you if you do not provide required information like your email address. If you do not provide information indicated as required or mandatory within our service, it will not be available to you.Legal obligations. We may have to process or share your personal data to comply with legal obligations, such as to comply with a subpoena or legal process.Legitimate interests. We process your personal data for purposes that constitute our legitimate interests, such as fraud prevention and safety; protecting our, your or others’ property rights; exercising or defending legal claims; investigating violations of and enforcing our Terms of Use; analyzing and improving our services; and marketing and advertising.Consent. In some cases, we may process your personal data based on your consent, such as where we request access to data on your mobile device through the prompts in your device’s operating system. You have the right to withdraw your consent anytime in the manner indicated at the time consent is requested with no impact on the validity and lawfulness of collection or processing based on the consent made before its withdrawal.

3. WAYS OF USING PERSONAL INFORMATION
Purpose of this Privacy Policy is fulfillment of the provisions of the Terms of Service (“Contract”) concluded between the User and Wanna Play Games LTD. We collect user’s personal data when user starts using our Services. For example, we may use the Personal Data in the following ways:

(i) To provide User Service. Our main aim is to perform our contractual obligation towards User and make our Service available to User. We use information that you submit and information that is processed automatically to provide you with all requested services.
(ii) Account setup and administration: We use Registration information and information about your device to set up and administer your account, provide technical and customer support and training, verify your identity, and send important account, subscription, and Service information.
(iii) Providing you with interest-based (behavioural) advertising or other targeted content. We may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the Digital Advertising Alliance or Network Advertising Initiative consumer opt-out pages, which are located at http://www.networkadvertising.org/choices/ or http://www.aboutads.info/choices. Users in the European Union should visit the European Interactive Digital Advertising Alliance’s user information website https://www.youronlinechoices.eu/.
(v) To communicate with you. We use the information we have to communicate with you through newsletters, i.e. to send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.
(vi) Research and development: We use Personal Data for internal research and development purposes and to improve and test the features and functions of our Services. We use information that is processed automatically to better understand user behaviour and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our App.
(vii) Legal obligations: We may be required to use and retain Personal Data for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud.
(viii) Send you push notifications, related information, including confirmations and reminders (if you choose to allow that function)— user can choose to stop disable these at any time, by opting out or changing your browser or device settings.
(ix) We may use Automatically Collected information and Cookies information to maintain and improve our Services, including to do the following things: (a) automatically update the applications on your system; (b) remember your information so that you will not have to re-enter it during your visit or the next time you access our Services; (c) provide customized third-party advertisements, content and information, unless it will include instructions on how to opt out of receiving these advertisements, content and information in the future; (d) monitor the effectiveness of third-party marketing campaigns; (e) monitor aggregate site usage metrics such as total number of visitors and pages accessed.

4. THIRD-PARTY PROCESSING PERSONAL DATA

We may share your information to third-party companies to perform certain services, including but not limited to hosting services, payment processing, analytics, customer service and to assist us in our marketing efforts. We share your Personal Data with certain third parties as part of our operation of the Service, whether shared by us or gathered directly by third parties through SDKs integrated into the Service. This data sharing enables us to provide you with the Service in the optimal way, such as serving you personalized, relevant advertisements within the Service. We hereby undertake not to conduct any disclosure or transfer of the User’s personal data to any third parties, except Processors, mentioned in this paragraph, without receipt of personal consent of the User. The following companies are the Processors of the Personal Data of the Services of Wanna Play Games LTD (In case you want to learn more about the services and privacy options please consult their websites and privacy policies):

Survey Serving TechnologyWe use Pollfish SDK. Pollfish is an on-line survey platform, through which, anyone may conduct surveys. Pollfish collaborates with Publishers of applications for smartphones in order to have access to users of such applications and address survey questionnaires to them. When a user connects to this app, a specific set of user's device data (including Advertising ID, Device ID, if and where the app-user has enabled access to his Advertising and/or Device ID, either through his system's settings or via a consent-prompt shown to him) and further response meta-data is automatically sent, via our app, to Pollfish servers, in order for Pollfish to discern whether the user is eligible for a survey. Pollfish is a US based entity, therefore you specifically agree and consent to the transfer of such data to the US. Pollfish collects and processes your Data in accordance with all applicable GDPR requirements. For a full list of data received by Pollfish through this app, and for further information on how Pollfish processes such data please read carefully the Pollfish respondent terms located at https://www.pollfish.com/terms/respondent. These data will be associated with your answers to the questionnaires whenever Pollfish sends such questionnaires to eligible users. Your data may be transferred by Pollfish to non EEA countries in accordance with all applicable GDPR requirements, including use of EU Commission Standard Contractual Clauses. Pollfish may share such data with third parties, clients and business partners, for commercial purposes. By downloading the application, you accept this privacy policy document and you hereby give your consent for the processing by Pollfish of the aforementioned data. Furthermore, you are informed that you may disable Pollfish operation at any time by visiting the following link https://www.pollfish.com/respondent/opt-out. We once more invite you to check the Pollfish respondent's terms of use, if you wish to have more detailed view of the way Pollfish works and with whom Pollfish may further share your data."

Our Services allow in-app purchases. In-app purchases are not mandatory and it is up to you whether to pay for accessing such functionality or not. You should know that we don’t process payments directly, payments processed via Apple App Store (Apple, https://www.apple.com/legal/privacy/en-ww/) and through the Google Play Store (Google, https://policies.google.com/privacy). We don’t collect or store payment data, details or payments-related personal data. Payment processing takes place through a payment system, integrated into the app store, appropriate for your platform. 

5. STORE PERSONAL INFORMATION
We will keep your Personal Information for the length of time required to provide you with the Service and for the reasons described in this privacy policy, unless a longer retention period is required or permitted by law. Afterwards, we delete all aforementioned data in our possession within a reasonable timeframe. We do not verify the correctness of personal data that we collect or you provide. In all cases, Wanna Play Games LTD does not retain such data for more than 5 years. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account. 

6. PERSONAL DATA PROTECTION

6.1. We understand that unfortunately, the transmission of Information via the internet is not completely secure. We do all our best to maintain the privacy and integrity of your Information. We have implemented industry standard security measures, which include the encryption to protect your personal information, including all information you input into your habit data or share in Services, and this information is not available to third parties.
6.2. We work in the international space and provide our Services to our Users around the world. We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. You acknowledge and agree that The locations of servers for the services include:
(1) Cyprus and Germany (The European Union) - the servers located in European Union which automatically process your personal data and obtain the access to your personal data for the purposes of manual processing;Your data will be processed on our servers which may not be located in your country of residence and can be accessed by our support, engineering around the world. No matter where our servers are located, we will make great efforts to take the appropriate safeguards to guarantee your rights in conformity with this Privacy Policy and any applicable laws. This means that your personal information can be transferred to a third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of a personal data as your country does. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

 7. USER’S RIGHTS

We attach great importance to user’s privacy and would like to explain your data protection rights.  

(i) The right to withdrawal. It’s important to remember that if we process your data based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Withdrawal is made by the mere notification of the Wanna Play Games LTD via its Support service, i.e. by sending an e-mail to the address support@wannaplay.games with the topic «Consent withdrawal» or in the Settings menu of the application.
(ii) The right to know what Personal Data we hold, how and why we handle your Personal Data. You can ask us for a copy of your Personal Data. If you would like to exercise your right of access, please contact us as described below and let us know what information in particular you would like to receive. 
(iii) The right to opt-out of direct or target interest advertising on mobile applications by checking the privacy settings on your device settings menu. Please note that even if you use your right to opt-out it you will still receive advertising, but not direct or target interest. On Apple you can opt-out this by going to Settings > Privacy > Advertising and turning on “Limit Ad Tracking”. On Android you can opt-out by going to Settings > Google services > Ads and turning on choosing “Opt out of Ads Personalization”.
(iv) The right to request an update or correction (rectify) to any of your Personal Data which is out of date, incomplete or incorrect (according to Article 16 of the GDPR). In certain specific circumstances you have the right to ask us to delete your Personal Data which we are holding about you.
(v) The right to delete your personal data. (Right to be forgotten).
(vi) The right to object. You have the right to object to ours processing of your personal data, under certain conditions.(vii) The right to restrict processing of your personal data under the conditions set out in Article 18 of the GDPR or any other applicable laws in your country of residence.
(viii) The right to portability of your personal data. In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller.
(ix) The right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Please see this directory for contact details: https://edpb.europa.eu/about-edpb/board/members_en. If you are in Switzerland, please visit this FDPIC site for contact details: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.
(x) The right to opt-out of direct or target interest advertising on mobile applications by checking the privacy settings on your device settings menu. Please note that even if you use your right to opt-out it you will still receive advertising, but not direct or target interest. On Apple you can opt-out this by going to Settings > Privacy > Advertising and turning on “Limit Ad Tracking”. On Android you can opt-out by going to Settings > Google services > Ads and turning on choosing “Opt out of Ads Personalization”.
(xi) The right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. You have the right to request us for copies of your personal data. To request to review, update, or delete your personal information, please submit a request. We will respond to your request within 30 business days. The User is empowered to request one copy of the personal data undergoing processing free of charge. Any additional copies are provided on a reimbursement basis.

You may send the request aimed at exercising your rights provided herein to our email or to our business address: 28 Oktovriou 367, MEDITERRANEAN COURT, 1st Floor, Flat/Office A5, 3107, Limassol, Cyprus. If you make a request, we have one month to respond to you.

8. AGE REQUIRED 
Our Services usually have a minimum age requirement of users and are not directed to children, and we do not knowingly collect Personal Data relating to children. Children should never disclose their name, address or phone number, or any personal information, without their parents’ prior permission. We consider a user to be a child if they are under the age of 13, unless more stringent regulation applies in their country of residence. In EU countries, users under the age of 16 are considered children, unless the data protection regulation of their country of residence specifies another age. If you become aware that your child has provided us with Personal information without your consent, please contact us and we will take the required steps to delete such information.

9.  SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW 

This is additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 (“CCPA”). We adopted this paragraph to comply with CCPA and any terms defined in the CCPA have the same meaning when used in this notice.California law requires us to disclose information about the categories of personal information we collect and how we use them, the categories of sources from which we collect personal information, and the third parties with whom we share personal information. We have provided detailed descriptions above in this policy. In particular, our Services have collected the following categories of personal information from its consumers within the last twelve (12) months:

We do not rent, sell, or share Personal Information with nonaffiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light” law (Civil Code § 1798.83), unless we have your permission. We do share personal information with the Processors of the Personal Data of the Services of Wanna Play Games LTD mentioned in paragraph 4.
As a California resident, you have the rights listed below:
- You can request information about how we have collected and used your personal information during the past 12 months including the categories of personal information collected, the sources from which we collected personal information, the business or commercial purpose for collecting personal information, and the third parties with whom we shared personal information.
- You can request a copy of the personal information that we have collected about you during the past 12 months. Also, according to the California “Shine the Light” law users who are California residents have the right to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. To make such a request from us, if entitled, please use the contact information listed below.
- You can ask us to delete personal information we have collected from you. We may need certain types of information so that we can provide our Services to you. If you ask us to delete some or all of your information, you may no longer be able to access or use the Services.
- You have the right to be Free from Discrimination. We may not discriminate against you because you have exercised your rights, including, for example, by denying you access to our online services or charging you different rates or prices for the same online services, unless that difference is reasonably related to the value provided by your data.
- You have the right to opt out of the sale of Personal Information, which is defined in a way that may include the transfer of data to third parties to personalize ads for you. Please note that the CCPA defines the term “sale” very broadly to include any exchange of data for consideration of any kind, not simply selling your data for monetary compensation. Depending upon the circumstances, the term “sale” could include a company providing a resident’s data to another entity to assist the company with targeted advertising. We do not sell to third parties, and within the last 12 months have not sold, any of your personal information. If you opt out of the ‘sale’ of your information, we will not sell your information, including to our advertising partners, but you may continue to receive ads from our Services, which may not be as tailored to your interests.
- You may exercise your California privacy rights described above by emailing us. We will need to confirm your identity (e.g. first name, last name, account name, email address, state of residence, etc.) and California residency to process your requests to exercise your information, access or deletion rights. We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.

10. CONTACT DETAILS OF THE WANNA PLAY GAMES LTD:
If you have any questions or comments about this policy, you may contact us:
via email at: support@wannaplay.games.
via post to: 
28 Oktovriou 367, MEDITERRANEAN COURT, 1st Floor, Flat/Office A5, 3107, Limassol, Cyprus
The Company name: Wanna Play Games LTD