PRIVACY POLICY

1.Our details as the data controller

The provision of our applications (hereinafter “App”), whether via websites or through various app stores, is brought to you by Wise Wave Corporation Limited (the “Data Controller” of your personal data). Consequently, “We”, “Us” and “Ours” refers to the Data Controller.

We are based outside the European Economic Area and have nominated the following representative to promptly respond to any requests by our customers and relevant authorities via post (or just email us):

Tristenblake Limited
16 Panagias Chrysopolitissis,
Ypsonas, 4181
Limassol, Cyprus

In the alternative, you may email Us with regards to queries of any nature (in particular, to exercise Your Rights) at support@wisewaveltd.com


2.What personal data is processed and the legal basis for processing

There are different types of information we obtain, whether directly from you or automatically via your device when you use the App. Essentially, we only obtain what is strictly necessary to provide you with our services, no more, no less.

Information, relating to you or your device, is either identified automatically by Our systems, provided to Us by the operating system of your device or is input by you manually when filling out certain fields, authorizing certain actions in the Apps.

Strange, but that is it. The rest is the technical stuff that must be processed in order to provide you with our services.
3.What we do with your personal data

We protect your data and do not treat your personal data in any way that would surprise you (unless We told you about it and you made an informed decision to consent to such usage).

For instance, We encrypt the password created by you at the sign up stage and then store your personal data on secure servers that would prevent unauthorized access or destruction.

We use the advertising identifiers in strict compliance with the requirements of the operating systems (for otherwise We would be in breach of their usage terms). Thus, We only use those advertising identifiers to meet our contractual obligations towards the parties that brought you to Us and vice versa (whether by you clicking on an advertising banner in our partners’ apps, watching the ad or otherwise).

Unless you have asked us not to, We may rarely contact you by email about similar products and services to the App. Whenever We contact you, We would always give you the right to opt out prior to the first communication and at any time thereafter (see the section “Your Rights” below).

The purposes for processing the data provided by you include:

  • Providing you with Our services
  • Fraud prevention
  • Improving our services
  • Notifying you of any changes in our services

4.How long personal data is stored for

Depending on the type, your personal data is stored either until you delete the App or after six months of inactivity. Some data (such as IP addresses or blacklisted email addresses used for fraud) may be held for longer in our legitimate interests to protect our business from losses and also to respect your choice of opt-outs from marketing emails.

We are required by law to delete any information that is no longer necessary to provide Service to you. We assume that if you have not used our App for over six months (“Period of Inactivity”), you have left us indefinitely. We will delete any Personal Data that we have in our possession following the Period of Inactivity. But do not worry, you are always welcome to use our App again if you decide to come back by setting up a new account.

5.Security measures used by Us

Your data is stored on one of the secure servers that we rent and We use the recommended industry practices to keep your data secure. We use appropriate level of technical and organizational measures to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed.

Hetzner and Amazon (the “Hosting providers”) are contracted to store your personal data. Those Hosting providers are in possession of various international security certificates that ensure safety of your data with them. You can read more on the security measures of Hosting providers by following the links:

https://www.hetzner.com/assets/downloads/FOX-Certificate.pdf ISO 27001 certificate
https://d1.awsstatic.com/certifications/iso_27001_global_certification.pdf ISO 27001 certificate

Thus, having the appropriate security with the Hosting providers when storing your data, We have to ensure that access to such data is provided on a need-to-know basis. Access to the Hosting providers is controlled via various technical and organizational measures that include:

  • Two-factor authentication to access the Hosting providers;
  • Following the principle of least privilege;
  • All servers and services are subject to continuous monitoring. This includes the logging of personal access in the user interface.
  • Each employee has access to the systems/services only via his/her own employee access. The access rights involved are limited to the responsibilities of the respective employee and/or team.

6.Categories of recipients

We do not share your personal data with any third parties, except for:
  • the data processors (service providers) that act solely upon our instructions and in the performance of our duties to you;
  • as stated in this privacy policy; or
  • where We have to comply with a legal obligation.

This does not mean that We blindly follow disclosure orders. We will check each request to ensure it satisfies the relevant safeguards, contains a court order or is issued under a legislative measure for the prevention, investigation, detection or prosecution of criminal offences.

Independent Controllers

Once you access the rewarded ads section, you may be able to obtain free in-game virtual currency (as defined in our terms and conditions) in return for certain actions. As with everything else in this world, if you are not paying for the product – you are the product. Hence, after your consent given to us in the App, your personal data (non-invasive and general in most cases) will be processed by an independent third party that gets some benefit for processing your personal data for further targeted advertising.

If you do not wish to be targeted in this manner, the first ad you see in an app usually explains how you can opt-out of data collection in that particular app. You can opt-out then or at any time by clicking or tapping the “ℹ” button (or Data Privacy icon) on any ad you see.

Additionally, all users, regardless of their location, may opt-out of all personalized advertising by enabling privacy features on their devices such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See your device’s Help system for more information.

7.Transfer of your data abroad

To any extent that data is accessed from abroad, We follow set contractual safeguards and protections to ensure that your data is as safe abroad as it is within the EEA.

Where a third party accesses your data on our behalf or upon our instructions (be it inside or outside the EEA), We use the relevant legal basis to comply with the data protection legislation. In cases where there is no finding of an adequacy decision by the European Commission, we use model contracts to safeguard your rights and data.

8.Social Network Services (SNS)

When you log in to use any of Our Apps via an SNS (such as Facebook) you provide Us with certain information from you profile for that site. The information provided via SNS varies and depends on a particular SNS (for instance, Facebook provides information on your name, age range, picture, gender, friends list and email address). You can untick the boxes for information you prefer not to share with us during the sign up process.

You can find out more about these settings at the SNS where you play Our App (for instance, you can edit the privacy and settings of your apps with Facebook by following the link https://www.facebook.com/help/218345114850283?helpref=about_content.

Your activity when playing the App via an SNS will also be subject to the SNS’ privacy policy for their part of data processing.

9.Your rights

You are entitled to the full spectrum of the rights under the General Data Protection Regulation and We will go out of our way to accommodate any valid request. You can either exercise your rights by deleting certain features through your device or by emailing us at support@wisewaveltd.com to exercise all the other rights.

You have a wide array of rights that we respect. Among those the right to:

  • Require access to your personal data;
  • Require rectification of your personal data;
  • Require erasure of your personal data;
  • Withdraw consent to processing of your personal data, where applicable;
  • Lodge a complaint with your national supervisory authority (in the EEA) if you believe that your privacy rights have been breached;
  • Not to be discriminated against for exercising any of your rights.

You may be required to prove through a certain procedure that the request emanates from the data subject (i.e. contact us from within the app itself and confirm a code that we would send to the registered email address). This is so that we do not disclose personal data to those that are not entitled to it.

If your personal data is erased at your request or in accordance with our data retention policy, We only retain such information that is necessary to protect our legitimate interests or to comply with a legal obligation.

Please note, all requests should be emailed to Us at support@wisewaveltd.com, sent to us by post or via an App’s related internet website (where applicable).

10.Children’s privacy

The Apps are intended strictly for over 18 year old persons. We never knowingly collect or solicit any information from anyone of 13 years and younger. The App and its content are not directed at nor made look to appeal to such persons. Parents or guardians that believe that We hold information about their children aged 13 and under may contact Us at support@wisewaveltd.com

11.Cookies and similar technologies

We use certain cookies when you visit Our Websites, but We give you an opportunity to choose which of those optional, non-essential cookies you would want to keep. Check the relevant cookie policy for the website you are visiting.

There is no consensus on how mobile application companies should interpret the DNT signals. For the purposes of the CalOPPA, We do not currently respond to DNT signals whether that signal has been received on a computer or a mobile device.

12.Notice to California Residents

For the purposes of the California Consumer Privacy Act of 2018 (the “CCPA”):

  • We do not sell nor share consumer personal information as per sections 1798.140(ad)(2) and 1798.140(ah)(2) respectively.

  • In accordance with section 1798.130(a)(5):
a. the list of your rights is specified in section 9 of this privacy policy;
b. the categories of personal information We collect and have collected about consumers in the preceding 12 months and the business purpose for collection are listed in section 2 of this privacy policy.

  • In accordance with section 1798.130(a)(1)(A) and (B), consumers can contact us via an email address provided herein. And where an internet website is separately accessible for a particular App, that internet website is also available to submit any requests consumers may have.

  • As per the last sentence of section 1798.130(a)(2)(A), We do not wish to collect more information than we already hold about consumers when dealing with verifiable requests, and, as such, We require the consumers to use the account they hold with us to submit a verifiable consumer request. Put simply, We have an obligation to reduce the risk of processing unauthorized requests. Thus, if you contacted us from an email address asking for information relating to a user with a completely different email address and user ID, We would ask you to use the in-App chat to authenticate the request. And this has to be done to a reasonably high degree of certainty.

  • You may designate an authorized agent to make a request on your behalf. In order to do this, you should, firstly, provide the agent with written and signed permission to submit a request on your behalf. Secondly, you must verify your own identity directly with us and confirm the authority of the agent. Please, note that We retain the right to refuse a request from an allegedly authorized agent absent the legal proof of authority.

13.Contact us

Feel free to contact us at any time should you have any questions in relation to this privacy policy, either via email, by post or within App.

Wise Wave Corporation Limited
Attention: Data Protection
Unit H, 11/F., King Palace Plaza, 55 King Yip Street, Kwun Tong, Kowloon, Hong Kong
Support Team: support@wisewaveltd.com

v.240825