PRIVACY POLICY - TERMS OF USE

INTRODUCTION

Wandity Ltd. (“we”, “us”, or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and our mobile applications, including any other media form, media channel, mobile website, or mobile applications related or connected thereto (collectively, the “Site”). This policy is compliant with the General Data Protection Regulation (GDPR). Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.

INFORMATION WE COLLECT

We may collect information about you in a variety of ways. The information we may collect on the Site includes:

Personal Data

Personally identifiable information, such as your name, shipping address, email address, and telephone number, and demographic information, such as your age, gender, hometown, and interests, that you voluntarily give to us when you choose to participate in various activities related to the Site and our mobile applications, such as online chat and message boards. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site and our mobile applications.

Derivative Data

Information our servers automatically collect when you access the Site or our mobile applications, such as your IP address, browser type, operating system, access times, and the pages you have viewed directly before and after accessing the Site.

Financial Data

Financial information, such as data related to your payment method (e.g., valid credit card number, card brand, expiration date) that we may collect when you purchase, order, return, exchange, or request information about our services from the Site or our mobile applications. We store only very limited, if any, financial information that we collect. Otherwise, all financial information is stored by our payment processors, and you are encouraged to review their privacy policy and contact them directly for responses to your questions.

Data From Social Networks

User information from social networking sites, such as, but not limited to Apple’s Game Center, Facebook, Instagram, Pinterest, Twitter, including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, if you connect your account to such social networks. If you are using our mobile applications, this information may also include the contact information of anyone you invite to use and/or join our mobile application.

Mobile Device Data

Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device, if you access the Site from a mobile device.

Third-Party Data

Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Site permission to access this information.

Data From Contests, Giveaways, and Surveys

Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.

Mobile Application Information

If you connect using our mobile applications:
Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s Bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Data. We may collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information, and IP address.
Push Notifications. We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

LAWFUL BASIS FOR PROCESSING

We process your personal data under the following lawful bases:

• Consent: Where you have given clear consent for us to process your personal data for a specific purpose.
• Contractual Necessity: Necessary for the performance of a contract with you or to take steps to enter into a contract with you.
• Legal Obligation: Required to comply with the law (not including contractual obligations).
• Legitimate Interests: Necessary for our legitimate interests, which are not overridden by your rights.

USE OF YOUR INFORMATION

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Site or our mobile applications to:

• Administer sweepstakes, promotions, and contests.
• Assist law enforcement and respond to subpoenas.
• Compile anonymous statistical data and analysis for use internally or with third parties.
• Create and manage your account.
• Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and the Site and our mobile applications to you.
• Email you regarding your account or order.
• Enable user-to-user communications.
• Fulfill and manage purchases, orders, payments, and other transactions related to the Site and our mobile applications.
• Generate a personal profile about you to make future visits to the Site and our mobile applications more personalized.
• Increase the efficiency and operation of the Site and our mobile applications.
• Monitor and analyze usage and trends to improve your experience with the Site and our mobile applications.
• Notify you of updates to the Site and our mobile applications.
• Offer new products, services, mobile applications, and/or recommendations to you.
• Perform other business activities as needed.
• Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
• Process payments and refunds.
• Request feedback and contact you about your use of the Site and our mobile applications.
• Resolve disputes and troubleshoot problems.
• Respond to product and customer service requests.
• Send you a newsletter.
• Solicit support for the Site and our mobile applications.

DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

Third-Party Service Providers

We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. These third parties are bound by confidentiality and data protection obligations and are only permitted to process your data for the purposes we specify.

Marketing Communications

With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

Interactions with Other Users

If you interact with other users of the Site and our mobile applications, those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts, following blogs.

Online Postings

When you post comments, contributions or other content to the Site or our mobile applications, your posts may be viewed by all users and may be publicly distributed outside the Site and our mobile applications in perpetuity.

Third-Party Advertisers

We may use third-party advertising companies to serve ads when you visit the Site or our mobile applications. These companies may use information about your visits to the Site and our mobile applications and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.

Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Business Partners

We may share your information with our business partners to offer you certain products, services or promotions.

Offer Wall

Our mobile applications may display a third-party hosted “offer wall.” Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for acceptance and completion of an advertisement offer. Such an offer wall may appear in our mobile application and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will leave our mobile application. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account.

Social Media Contacts

If you connect to the Site or our mobile applications through a social network, your contacts on the social network will see your name, profile photo, and descriptions of your activity.

Other Third Parties

We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.

Sale or Bankruptcy

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

LAWFUL BASIS FOR PROCESSING

We process your personal data under the following lawful bases:

• Consent: Where you have given clear consent for us to process your personal data for a specific purpose.
• Contractual Necessity: Necessary for the performance of a contract with you or to take steps to enter into a contract with you.
• Legal Obligation: Required to comply with the law (not including contractual obligations).
• Legitimate Interests: Necessary for our legitimate interests, which are not overridden by your rights.

TRACKING TECHNOLOGIES

Cookies and Web Beacons

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site and our mobile applications to help customize the Site and our mobile applications and improve your experience. When you access the Site or our mobile applications, your personal information is collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Site or our mobile applications. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site and our mobile applications to help customize the Site and our mobile applications and improve your experience. For more information on how we use cookies, please refer to our Cookie Policy posted on the Site, which is incorporated into this Privacy Policy. By using the Site, you agree to be bound by our Cookie Policy.

Internet-Based Advertising

Additionally, we may use third-party software to serve ads on the Site and our mobile applications, implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies or similar tracking technology to help manage and optimize your online experience with us. For more information about opting-out of interest-based ads, visit the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

Website Analytics

We may also partner with selected third-party vendors to allow tracking technologies and remarketing services on the Site and our mobile applications through the use of first-party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site and our mobile applications, determine the popularity of certain content, and better understand online activity. By accessing the Site and our mobile applications, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policies and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can visit the third-party vendor or the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

DATA RETENTION

We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than [specify period, e.g., 2 years].

POLICY FOR CHILDREN

We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and our mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

However, some browsers may let you disable some or all DNT signals, and you can adjust your browser settings to delete or refuse cookies, including those used for DNT.

YOUR DATA PROTECTION RIGHTS

Under the GDPR, you have the following rights regarding your personal data:

• Right to Access: You have the right to request copies of your personal data and to obtain information about how we process it.
• Right to Rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
• Right to Erasure: You have the right to request that we erase your personal data, under certain conditions.
• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
• Right to Object to Processing: You have the right to object to our processing of your personal data, under certain conditions.
• Right to Data Portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

To exercise any of these rights, please contact us using the contact information provided below. We will respond to your request within one month.

Automated Decision-Making and Profiling

We do not use automated decision-making or profiling to make decisions about you without your consent. If we introduce such processes in the future, we will inform you and provide you with the opportunity to opt-out.

Data Protection Officer (DPO)

If you have any questions or concerns about our use of your personal data, please contact our Data Protection Officer (DPO) at:

Wandity Ltd.
Gladstonos 12-14
Paphos
8046
Cyprus
Email: info@wandity.com

Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will notify you without undue delay and, where feasible, no later than 72 hours after becoming aware of it, in accordance with GDPR Article 33.

OPTIONS REGARDING YOUR INFORMATION

Account Information

You may at any time review or change the information in your account or terminate your account by:

• Logging into your account settings and updating your account.
• Contacting us using the contact information provided below. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use, comply with legal requirements, or as necessary for our legitimate interests.

Emails and Communications

If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:

• Noting your preferences at the time you register your account with the Site or our mobile applications
• Logging into your account settings and updating your preferences.
• Contacting us using the contact information provided below.
• If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

CONTACT US

If you have questions or comments about this Privacy Policy, or wish to exercise any of your data protection rights, please contact us at: