Privacy Policy
Effective date: 19/02/2024
WICKLE LTD, a company incorporated under the laws of Cyprus, with the registered office A.G. Leventi, 5, THE LEVENTIS GALLERY TOWER, 13th floor, Flat/Office 1301, 1097, Nicosia, Cyprus, registration number HE 456129 (“Company”, “we”, “us” or “our”, “Provider”, “controller”).
The Privacy Policy (“Policy”) is an internal part of the Terms and defines the relationship between the player (“user” or “you”, “your”) and the Company. This Policy sets forth the general rules of collection, processing, distribution, use, and storage of Website user’s Personal Data including any dispute concerning privacy under the current General Data Protection Regulation (GDPR), Personal Information Protection and Electronic Documents Act, other privacy legislation and following the data protection regulations in Curaçao applicable to the Company (“applicable legislation”).
Please note that this Privacy is subject to change periodically. Your continued use of Services following any modifications will be considered as your acceptance of those changes. Therefore, we recommend checking this Privacy regularly for updates.
- Collection of Personal Data
We collect information that either on its own or when combined with other data in our possession, has the potential to identify you (“Personal Data”). The collection of Personal Data includes the following:
- Personal Data you provide to us directly.
Name, email address, phone number, mail address, account credentials, payment card information, Services you have purchased from us, as well as any inquiries you have made (incl. current and historical data, such as the dates of services, inquiries, or transactions), information that you provide by interacting with Services, and contents of any messages you send to us.
- Personal Data we receive automatically when you Use Services.
- Log file/ Device information: IP address of the requesting entity or of your end-user device; access status/HTTP status code; date and time of the request, time zone; requested URL; data transferred in each case, and how you interacted with our website and use Services; website from which the request originates; your browser type, version and language, operating system, interface, and name of your internet service provider (HTTP headers); user device ID; first user authorization date and time.
- Cookies: To operate and manage our Services and enhance your user experience, we utilize cookies. A “cookie” is a small piece of information that a website sends to your browser when you visit it. You have the option to configure your browser settings to accept all cookies, reject all cookies, or receive notifications whenever a cookie is sent, allowing you to decide on accepting it each time. However, please note that refusing a cookie may prevent you from using certain areas or features of a website, and it may also impact the display or functionality of a website. For more detailed information on cookies, please see our Cookies Policy.
- Third-party analytics: To analyze user behavior and improve user experience, we may utilize various online analytics products that employ cookies when you use our Services.
- Personal Data provided to us from third parties.
Under certain circumstances, we may receive information from third parties.
You may deal with us anonymously or by using a pseudonym, however, please be aware that this may limit the Services that we can provide to you if it is impracticable for us to deal with you in such an unidentified manner.
Processing of Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data to uniquely identify a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation are prohibited.
We do not use automatic decision-making or profiling to process and use data subject’s Personal Data.
The Company processes and stores the Personal Data of the data subject only for the period necessary to achieve the purpose of storage. If the storage purpose is not applicable, or if a storage period expires, the Personal Data is routinely blocked or erased.
- Collection Purposes
We may use your Personal Data for the purposes below:
To provide, administer, maintain, improve, test, fix, and analyze the Services.
Developing and testing new products and features.
Monitoring metrics such as the total number of users, website traffic, and demographic patterns.
Linking or combining information obtained from other sources, including information provided by you, to better understand your needs and enhance the Services.
Communication with you and update our records.
Our marketing purposes.
Fulfilling our legal obligations and adhering to legal processes.
Prevention of fraud, criminal activity, or misuse of our Services, and ensuring the security of our IT systems, architecture, and networks.
Fulfilling any other purpose for which you have provided the information.
We do not engage in the sale, trade, or transfer of your Personal Data to third-party for commercial purposes.
- Your rights
As a data subject, you have the following rights under the applicable law:
To be informed about the collection and use of Personal Data;
To have access to the Personal Data we hold about you;
To rectify if any Personal Data we hold about you is inaccurate or incomplete;
The right to be forgotten. This means the right to ask us to delete any Personal Data we hold (please note that there may be some legal obligations that may prohibit us from deleting all or any Personal Data, for example, Anti-Money Laundering legislation);
To restrict the processing of your Personal Data, and the right to object to us using your Personal Data for purposes, e.g. for marketing purposes;
To data portability (obtaining a copy of your Personal Data to re-use with another service or organization). We will provide such copy free of charge unless the request is manifestly unfounded or excessive, where in such case a reasonable fee for administration costs may be charged;
You have certain rights concerning automated decision-making and profiling;
To complain to a supervisory authority.
- Cookie policy
Upon visiting the Website, our system automatically gathers details about your visit, including information such as your browser, IP address, and the referring website. This data collection may occur collaboratively with our platform providers and partners, from whom we may receive general demographic or usage data related to our Website visitors. It’s important to note that we do not utilize automatically collected information to personally identify you without obtaining additional consent.
To acquire the mentioned information, we employ cookies and similar tracking tools. Some of these cookies are crucial for the proper functioning of the Website, while others enhance your overall experience and assist us in delivering improved services. The following outlines the types of cookies we use and their respective purposes.
Required cookies: enable the navigation and basic functionality of the websites, e.g., access to member areas of the Website.
Functional cookies: allow us to analyze your website usage and your selections on the website (e.g. your session key, language, or region), so we can save these settings and offer you a more personalized experience.
Advertising cookies: allow us to gauge how effective our content marketing is. These cookies are provided by our partners to track website visits and new player registrations from advertising. We do not share your personal information (such as name or email) with affiliated partners except for data on-site visits collected directly by such Advertising Cookies. However, your data from on-site visits may be linked with other personal information collected through other sources by the providers. The latter external data processing is governed by the privacy notices and policies of these third-party providers.
In addition to the information mentioned above, we engage various third-party service providers who also utilize cookies on this Website to deliver the services they provide to us. These services encompass, but are not limited to, enhancing your experience by monitoring your activity on the Website and assessing the effectiveness of both the Website and our marketing campaigns.
While most online browsers automatically accept cookies, you have the option to block some or all cookies or delete those that have already been set by adjusting your browser settings. Nevertheless, we advise against blocking or deleting your cookies, as doing so may limit your use of our Website.
- Disclosure
In certain circumstances, your Personal Data may be shared with third parties without additional notice, unless otherwise mandated by law. The disclosure of your Personal Data nformation may involve the following entities:
Service providers and vendors responsible for managing the Services.
Third-party providers offering services through our platform.
Providers of email management and distribution tools.
Providers of hosting services, cloud services, security, fraud prevention services, and other information technology services providers.
Service providers engaged in supporting and maintaining our systems.
Your and/or our representatives, professional advisers, affiliates, subsidiaries, and agents.
Payment processors.
Event management services, email communication software, email newsletter services, and web analytics services.
In the event of a business transaction, such as a merger, acquisition, or asset sale, or in the case of bankruptcy or cessation of operations, it is conceivable that some or all of our assets, including your Personal Data, may be disclosed or transferred to a third-party acquirer as part of the transaction.
We may disclose your Personal Data to third parties and legal and regulatory authorities and transfer your Personal Data outside the EEA. It may be processed by a staff member operating outside the EEA who works for us or one of our suppliers. Such staff may be engaged in, amongst other things, the fulfillment of your order, the processing of your payment details and the provision of support services. By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and following this Privacy policy.
- Security measures
We prioritize the security of your Personal Data and implement appropriate technical and organizational measures to ensure its protection. These measures are specifically designed to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to your Personal Data. To achieve this, we employ a range of methods, including restricting physical access to our premises, implementing controls to limit both electronic and physical access to the Personal Data in our possession, utilizing technology security measures to safeguard data, and imposing security requirements on any third-party providers to ensure the protection of your Personal Data.
- Contact us
If you have any questions regarding this Policy, please feel free to reach out to us via email at [email protected] or through our mailing address:
WICKLE LTD
A.G. Leventi, 5, THE LEVENTIS GALLERY TOWER,
13th floor, Flat/Office 1301, 1097, Nicosia, Cyprus