PRIVACY POLICY

This Privacy Policy sets out the basis on which Company collects, uses and shares Personal Data (as defined below) of Users in the course of rendering Services under Terms of Service available at https://wishlistgames.net/legal/tos (“Terms”) of which this Privacy Policy forms part. In the event that any matter or provision is not explicitly addressed or stipulated within these Terms, it shall be governed by and subject to the Terms. Capitalized terms not otherwise defined in this Privacy Policy shall have the meaning given to them in the Terms.

IMPORTANT NOTICE: IF YOU DO NOT AGREE TO THE PROCESSING OF YOUR PERSONAL DATA IN THE WAY THAT THIS POLICY DESCRIBES, PLEASE DO NOT PROVIDE YOUR DATA (WHEN COMPANY REQUESTS) AND STOP USING ANY SERVICES. BY USING THE SERVICES, USERS ARE EXPLICITLY AND SPECIFICALLY AGREEING TO THE COLLECTION, USE AND ANY OTHER WAYS OF OPERATION OF THEIR PERSONAL DATA AS OUTLINED IN THIS PRIVACY POLICY. COMPANY MAY AMEND THE PRIVACY POLICY FROM TIME TO TIME ACCORDING TO THE RELEVANT LAWS; USERS CAN FIND THE UPDATED PRIVACY POLICY ON THE PLATFORM. IN THE EVENT OF SUBSTANTIAL CHANGES, THE UPDATED PRIVACY POLICY SHALL BE SUBJECT TO A RELEVANT UPDATE NOTICE AND REFRESHING YOUR CONSENT. UNLESS YOU AGREE WITH THE REVISED VERSION OF THIS PRIVACY POLICY, COMPANY RESERVE THE RIGHT TO SUSPEND PROVIDING YOU WITH OUR SERVICES WHICH REQUIRE YOUR DATA PROCESSING BY US. IN CASE OF MINOR CHANGES, NO NOTICE FOLLOWS: YOU UNDERTAKE TO CHECK SUCH CHANGES YOURSELF. ANY UPDATES TO THIS PRIVACY POLICY COME INTO EFFECT THE NEXT DAY AFTER THE UPDATED VERSION OF THE PRIVACY POLICY IS PUBLISHED.

(1) DEFINITIONS

"Account" means a personal account registered by User using WLG ID (or registered before WLG ID but integrated to it) to play the Games and get the Services.

"Company" means WL Games LTD, registered at the address: Aigaiou, 83, 1st floor, Flat/office 104, Lakatamia, 2302, Nicosia, Cyprus. “We”, “Our” and etc. shall be referred to accordingly.

"Game(s)" means all games for personal computers (PCs), consoles and mobile devices developed and/or owned by the Company, that are available for use with WLG ID.

"Personal Data" means any information that can be directly or indirectly linked to an identified or identifiable individual. This includes but is not limited to names, addresses, phone numbers, email addresses, usernames, social media profiles, IP addresses, geolocation data, financial information, and any other data that can identify a User.

"User(s)" means a person who registered the Account using WLG ID or linked/integrated a previously created Account to WLG ID.

(2) INFORMATION COMPANY COLLECTS

2.1. Company is dedicated to protecting Your privacy and managing Your Personal Data responsibly. This section outlines the data Company gathers and the reasons for processing Your Personal Data when You utilize WLG ID. To meet these goals, and to adhere to relevant regulations, Company will engage in various activities with Your Personal Data, including collection, storage, aggregation, organization, extraction, comparison, utilization, and enhancement (collectively referred to as “Processing").

No Information Purpose Legal Basis
1 Data You provide for registering an Account via WLG ID: e-mail and/or mobile. To give You access to WLG ID and manage/administer the Services provided to You.

To enable Company to fulfill Company’s obligations to You as part of the Services (e.g. in cases where you request restoration of your account).

To provide You with updates and information on Company and selected third parties’ products and services Company think You may be interested in.
Contractual necessity.
Legitimate interests.
Consent.
2 Data You provide for verification (if necessary): a copy of Your identity document containing Your first name, surname, photograph, number of identity document, payment details, and other additional data that You may provide Company To identify You, verify Your Account, and prevent abuse and infringement of Your or other persons’ rights.

To verify Your identity if You lose Your credentials and wish to Access Your Account with Company.
Contractual necessity.
Legitimate interests.
Consent.
3 Additional data You provide when You edit Your Account, including Your first name and surname, nickname, gender, date of birth, avatar picture, and language preferences. To provide the access via WLG ID to our Services to You, to manage and administer WLG ID and Services, and as additional information to verify Your Account to prevent abuse and infringement of Your or other persons’ rights.

To provide You with updates and information on Company’s products and services Company thinks You may be interested in.

To tailor and improve the advertisements that may be presented in Company’s other products and services that You may choose to use, and to measure the effectiveness of these advertisements.
Legitimate interests
Contractual necessity
Consent
4 Additional data received when You access the Account or use the Services, including information regarding technical devices, technical interaction with the Service such as Your IP-address, time of registration, device IDs, country and language settings, device model and operating system used, system information and memory usage data, Your installed apps, type of browser, Your Internet provider and/or phone network operator, network type, screen resolution and RAM size. For internal review in order to constantly improve the content of the Services, to optimize Your user experience, to understand any errors You may encounter when using WLG ID or Services, to notify You of changes to WLG ID or Services.

To tailor and improve the advertisements that may be presented in Company’s other products and services that You may choose to use, and to measure the effectiveness of these advertisements.
Legitimate interests
Contractual necessity
Consent
5 Information obtained as a result of Your behavioral actions using WLG ID or Services, as a result of Your use of the payment features (for example, the first and last four digits of Your bank card), information about payments (date, amount, payment type, payment status), information about goods and services purchased (name, amount). To give You access to WLG ID and manage/administer the Services provided to You.

To tailor and improve the advertisements that may be presented in Company’s other products and services that You may choose to use, and to measure the effectiveness of these advertisements.
Legitimate interests
Contractual necessity
6 Information that is created by You while placing requests to Company’s Service Support. To verify Your identity and to fulfill Your support request.

To investigate any complaints on Your behalf and to provide You with a more efficient Service.
Contractual necessity and legitimate interests.
7 Data collected via third parties, including Your social network IDs, application store IDs, nickname, e-mail, when You authorize in WLG ID via Your social or application store accounts and/or connect Your social account to WLG ID (e.g. Facebook, Twitter, Google). To give You access to WLG ID and manage/administer the Services provided to You. Contractual necessity and legitimate interests.
8 Information that is necessary for Company to perform legal and compliance obligations To comply with legal obligations, respond to legal requests, and protect Company’s rights and interests. Legal obligations and legitimate interests
9 Other purposes Company will seek Your explicit consent before processing Personal Data for certain purposes, such as marketing. You have the right to withdraw Your consent at any time. Consent

2.2. Company will only process Your Personal Data for the purposes outlined in this Privacy Policy statement or for any other purpose that is explicitly communicated to You at the time of data collection. Company will not use Your Personal Data for purposes incompatible with those described above unless required or permitted by applicable laws.

2.3. By using WLG ID and/or the Services You acknowledge and agree to the processing of Your Personal Data for the purposes specified in this Privacy Policy statement.

2.4. If You have any questions or concerns about how Company processes Your personal data, please review Company full Privacy Policy or contact Company via Support Services (Section 9).

BUT PLEASE NOTE that despite Company’s best efforts to ensure the security and protection of Your Personal Data, Company cannot guarantee absolute invulnerability to Your privacy. In today's world, there are numerous factors and risks that can impact the security of Your data, and despite Company’s protection standards, some of them may remain beyond Company’s control. Please exercise caution and prudence when providing Your personal information online and when using WLG ID/Services.

2.5. Company implements appropriate safeguards to ensure the security and confidentiality of Your Personal Data. These safeguards may include:

2.5.1. Encryption. Data may be encrypted during transfer to protect it from unauthorized access.

2.5.2. Contractual Agreements. Company enters into agreements with third parties that specify the necessary data protection measures.

2.5.3. Compliance Certification. Company may choose to work with service providers who adhere to recognized data protection frameworks or certifications.

(3) TERMS OF COLLECTING THE INFORMATION

3.1. The Company is committed to retaining Your Personal Data only for as long as it is necessary to provide You with the Services/WLG ID. Company recognizes the importance of protecting Company Users' privacy and have implemented measures to ensure that Your Personal Data is kept no longer than required.

3.2. The retention of Your Personal Data will be determined by the following criteria:

3.2.1. Necessity of access via WLG ID to the Service. Personal Data will be maintained as long as it is necessary to provide access via WLG ID to the Services effectively to You. Once WLG ID and/or the Services are no longer required, or You choose to discontinue the use of WLG ID and/or the Services, Company will proceed with the data deletion protocols.

3.2.2. Lawful Basis for Processing. Company ensures that a valid lawful basis exists for processing Your Personal Data. Company’s retention practices are subject to this lawful basis, which may include compliance with Company’s contractual obligations, legal requirements, tax, and accounting rules, or other regulatory purposes.

3.2.3. Completion of Purpose. Upon fulfilling the specific purposes for which Your Personal Data was collected, such as a completed transaction or a resolved customer service issue, Company will erase the Personal Data without undue delay.

3.2.3. Completion of Purpose. Upon fulfilling the specific purposes for which Your Personal Data was collected, such as a completed transaction or a resolved customer service issue, Company will erase the Personal Data without undue delay.

3.2.4. Withdrawal of Consent. Where Your consent is the basis for the processing of Personal Data, and You withdraw this consent, Company will remove Your Personal Data from Company’s records unless another legal ground for processing exists.

3.2.5. Regulatory Requirements. If Company is required by law to retain Your Personal Data for a certain period even after the fulfillment of the purposes for which it was collected, Company will comply accordingly.

3.3. Upon reaching the end of the retention period or once the purposes for Personal Data collection have been achieved, Personal Data will be securely deleted or, where applicable, anonymized. Company ensures the deletion process will safeguard Your privacy and security.

Company also provides Users with the ability to manage their own data. You can request data deletion or a copy of Your data at any time, provided that no legal or regulatory requirements compel Company to retain certain personal information.

(4) SHARING OF YOUR INFORMATION

Company will not rent or sell Your information to third parties outside WLG ID without Your consent, except as noted in this Policy.

4.1 Parties with whom Company may share Your information:

Company may share Your information with businesses that are legally part of the same group of companies that the Platform is part of, or that become part of that group ("Affiliates").

Company also may share Your information as well as information from tools like log files, and device identifiers and location data, with third-party organizations that help Company provide the Service to You ("Service Providers").

(5) YOUR CHOICES ABOUT YOUR INFORMATION

5.1. If You wish to make changes to Your account, You can do so by logging in and modifying Your profile settings. This gives You the flexibility to update any necessary information whenever You need to.

5.2. If You need to review, update, correct, or delete any of the Personal Data that is stored in Your Account, You can contact Company, and Company will assist You with this process. Company understands that Your Personal Data is important, and Company wants to ensure that it is accurate and up to date.

You generally have the following rights, which You can usually exercise free of charge:

Your Right Right Explanation
1 Right to information You have the right to request information about the scope of Personal Data processed by the Company by notifying in writing.
2 Right to access You have the right to receive one (1) copy of the processed Personal Data without any charge. For further demanded copies, the Company will charge the fee.
3 Right to rectification You have the right to rectify inaccurate personal Data concerning You via a written request.
4 Right to erasure (“right to be forgotten”) and to restrict processing You have the right to demand deletion or restriction of processing, and the right to object to processing based on legitimate interest under certain circumstances unless the Company has an opposite obligation required by applicable law. In these cases, the Company can stop providing the Products if it is no longer possible so please consider this when deciding to exercise these rights.
5 Right to portability You have the right to exercise the right of data portability, which means a right to get Personal Data and transfer these to another controller.
6 Other rights You have other rights in accordance with this Privacy Policy and applicable laws.

(6) PROCEDURE FOR REMOVAL OF PERSONAL DATA

6.1. This procedure applies to all Users who wish to have their Personal Data deleted from WLG ID:

6.1.1. User Request for Data Removal. Users who want their Personal Data removed should submit a formal request to the Platform via Company’s Support Services (Section 9). The request should be made in writing, clearly stating the User's identity and the specific Personal Data they want to be removed. Users should also provide any relevant supporting documentation to validate their request.

6.1.2. Verification of Request. Upon receiving the removal request, Company will initiate the verification process. The Company will compare the provided information with the existing User records to ensure the authenticity of the request. If any discrepancies or doubts arise during verification, the Company may request additional information or clarification from the User.

6.1.3. Evaluation of Legitimate Grounds. As part of the verification process, Company will assess the legitimacy of the User's grounds for data removal. Legitimate grounds may include violations of privacy rights, infringement of intellectual property, or any other relevant legal obligations. Company will evaluate the situation and determine whether the User's request aligns with the Platform's policies and legal requirements.

6.1.4. Removal of Personal Data. If the removal request is deemed legitimate, the Company will proceed with removing the requested Personal Data from the User's Account and associated records. The removal process may involve permanently and irreversibly deleting the data from all storage systems, backups, and any other data repositories.

6.1.5. Confirmation of Removal. Once the Personal Data is successfully removed, Company will send a notification to the User, confirming the deletion. The notification will also inform the User about any potential limitations or exceptions to the removal, as dictated by applicable laws or WLG ID policies.

6.2. Company will retain records of the deletion confirmation for a reasonable period, as required by applicable laws and regulations. This retention serves as evidence of compliance with the User's removal request.

6.3. Company will continuously monitor compliance with this procedure to ensure all removal requests are promptly addressed.

(7) CHILDREN'S PRIVACY

7.1. The Platform is committed to protecting the privacy and safety of individuals, particularly children. Company do not intentionally gather or request any Personal Data from children (relevant age threshold determined by local laws), nor does Company permit them to create an Account on WLG ID. The Services and the content within it are not intended for children.

7.2. If it comes to Company’s attention that Company has unintentionally collected Personal Data from a child without obtaining appropriate parental consent, Company will promptly delete that information. Ensuring the security and privacy of Company’s Users, especially young ones, is of utmost importance to Company.

(8) CHANGES TO PRIVACY POLICY

he Company may modify or update this Privacy Policy from time to time, so please review it periodically. Company may provide You with notices of modifications or updates as appropriate under the circumstances. Your continued use of WLG ID as an access to the Service after any modification to this Privacy Policy will constitute Your acceptance of such modification.

(9) HOW TO CONTACT COMPANY

For questions or concerns regarding these Privacy Policy, please contact Company at https://support.wishlistgames.net/

Any matters not explicitly defined by this Privacy Policy are subject to the terms and provisions outlined in the Terms.