WagrGames Inc PRIVACY POLICY

Last Updated: 25th March 2025

This Privacy Policy for WagrGames Inc, a Delaware limited liability company ("Company", "we", "us" "our") describes how we collect, use and disclose information about users of the Company’s website (wagr.co), the Company app (“App”), services, tools and features (collectively, the “Services”). For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services. Please read this Privacy Policy carefully. By using, accessing, or downloading any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, you may not use, access, or download any of the Services. This Privacy Policy incorporates by reference our Terms of Service, which include an arbitration agreement and class action waiver that govern how disputes between us will be resolved.

1. UPDATING THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make material changes to the way in which we use information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on our website and/or the App, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Policy, please do not access or continue to use the Services.

2. OUR COLLECTION AND USE OF INFORMATION

When you access or use the Services, we may collect certain categories of information about you from a variety of sources. This Privacy Policy covers our use of any information that can or could be used to identify you (“Personal Data”). It does not cover information which cannot be used to identify you (“Anonymous Data”). We need to collect and use certain Personal Data to provide the Services to you and fulfill the promises we make to you in the Terms of Service. Some features of the Services may require you to directly enter certain information about yourself. We provide you with choices regarding the collection, use, and sharing of your Personal Data. You may elect not to provide this information, but doing so may prevent you from using or accessing certain features. Information that you directly submit through our Services may include:

A. Account and Registration

Users may access our App only if they register an Account with us. The Personal Data we collect as part of the Account creation process may include your first and last name, email, username, password, information to confirm you are old enough to use the Services and use the App, payment information for any in-app purchases or storage of funds in your account (for example, your name and email associated with your payment account), and other information. We may also ask or allow you to submit certain optional information, which may include an updated username, preferences, and other profile information.

B. External Account Sign-On

You may be required to have an account with a supported external single sign-on service in order to use some of our Services. Where this is the case, the Personal Data we collect also depends on which external accounts you choose to use, their privacy policy, and what your privacy settings with those services allow us to see when you use their services to access our Services.

  • If you choose to link your Google account to the Services, we will collect your Google email address and an authentication token provided by Google.
  • If you choose to link your Facebook account to the Services, we will collect a unique user ID provided by Facebook and, if permitted by you, your Facebook registered email address
  • If you choose to link your Apple account to the Services, we will collect your email address on file with your Apple ID account or a private relayed email address if you use the Hide My Email option provided by Apple.

Depending on the particular Service you sign up for, we may support other external single sign-on services and collect additional Personal Data from them. Some external providers may notify you that they make additional information, such as your public profile, available to us when you use their single sign-on services. We do not collect this information from external providers.

C. Location of Your Device

We collect and use your device location information as you use our Services (and, if you elect to turn on background location tracking for participating Services, while you are not directly interacting with these Services), including how you move around and events that occur during in app activity or gameplay. Our Services may include location-based games whose core feature is to provide an experience tied to your real-world location, so we need to know where you are to operate these apps and games for you, and to plan the location of in-game resources. We may identify your location using a variety of technologies, including GPS, the WiFi points you are accessing the Service through, and mobile/cell tower triangulation. We also collect and use your in-game or in-app actions and achievements, as well as certain information about your mobile device (including device identifiers, device OS, model, configuration, settings, and information about third-party applications or software installed on your device), to operate the Services for you and to personalize your gameplay and experience. We will also generate an internal account ID when you use certain Services to associate you with an account. We use this information to deliver efficient technical assistance and responsive customer support tailored to your needs.

Managing Location Data Collection

Our Services rely on location data for core gameplay features, such as location-based matchmaking and in-game rewards. You can control location tracking

  • App Settings : Disable “Background Location Access” to restrict tracking when not actively using the app.
  • Device Settings : Adjust location permissions via your mobile operating system (iOS: Settings > Privacy > Location Services; Android: Settings > Location). using the app.
  • In-App Controls : Toggle location tracking off within the app’s privacy settings.
  • Note : TSome game features may not function properly if location tracking is disabled.

D. Personal Data.

When you interact with our Services (e.g., making purchases, subscribing, registering for events, entering competitions, or communicating with us), we collect personal data such as your name, address, phone number, country, age, and email. This data is used to fulfill services and provide customer support.

Legitimate Interests

We use your personal data for the following purposes based on legitimate interests:

  • Usage Data :
  • Communication : Adjust location permissions via your mobile operating system (iOS: Settings > Privacy > Location Services; Android: Settings > Location). using the app.
  • User Content : Toggle location tracking off within the app’s privacy settings.
  • Updates and News : TSome game features may not function properly if location tracking is disabled.
  • Personalized Offers : TSome game features may not function properly if location tracking is disabled.
  • Personalized Ads: TSome game features may not function properly if location tracking is disabled.
  • Social Features. : TSome game features may not function properly if location tracking is disabled.
  • Service Improvement : TSome game features may not function properly if location tracking is disabled.
  • Live Contests : TSome game features may not function properly if location tracking is disabled.
  • Anti-Fraud Measures : TSome game features may not function properly if location tracking is disabled.
  • Legal Compliance : TSome game features may not function properly if location tracking is disabled.

Automated Decision-Making & User Rights

We use automated systems to monitor gameplay, detect fraud, and enforce our Terms of Service. These systems analyze user behavior, game patterns, and transactions to maintain fair play.

  • Fraud Detection & Account Restrictions: If your account is flagged by our automated system, you will receive a notification explaining the reason.
  • Appealing Automated Decisions: If you believe an automated action was incorrect, you may request a human review by emailing support@wagr.co within 10 days of notification. We do not make decisions based solely on automated processing that produce legal effects or significantly impact users without human intervention.

AI & Machine Learning in Our Services

We use AI-driven algorithms to enhance gameplay, detect fraud, and personalize user experiences.

  • Gameplay Monitoring: AI monitors gameplay behavior to detect cheating, unauthorized bots, and suspicious activity.
  • Skill Analysis: AI analyzes player skill levels to improve matchmaking fairness.
  • Content Moderation: AI moderates chat and content to enforce community guidelines.
  • Human Review: If you believe an AI-driven decision was incorrect, you may request human review by contacting support@wagr.co.

Biometric Data Usage & Protection

If you provide biometric data (e.g., facial recognition for identity verification), we will:

  • Consent: Obtain explicit consent before collecting or processing biometric data.
  • Data Security: Store biometric data in encrypted form and delete it within 12 months after verification is complete.
  • Third-Party Sharing: Not share biometric data with third parties unless required by law.

You can withdraw consent and request deletion of biometric data by emailing support@wagr.co.

E. Cookies

We also rely on your consent when we use cookies or similar technologies. Please see our Cookie Policy for more information about how we use them. Insofar as cookies collect Personal Data, we will process it only based on your explicit consent, in anonymized form, or under a pseudonym.

F. Do Not Track

While you may disable the usage of cookies through your browser settings, we do not currently respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to the lack of industry standard on how to interpret that signal.

G. Prizes and Payments

We collect information to process prize winnings, administer payments, comply with the law (including requiring W9 tax forms when necessary), and maintain records of prizes, which may include your email, full name, mailing address, Social Security or Taxpayer ID number, and other information necessary to complete a 1099-MISC tax reporting form, and other relevant tax documentation.

H. Feedback

We collect and maintain records of customer service and other communications with users including survey responses, questions or comments sent to us (including the nature of the nature of the request, name and contact information), or other similar activities. This information may be used to enhance the Services or to market to you or others.

I. Custom Conetent

We may use the information we collect automatically to tailor features and content to you, to market to you, to provide you with offers or promotions, to run analytics and better understand user interaction with the Services

J. Outside Source

We may obtain information about you from outside sources. Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices.

3. ACCOUNT INFORMATION

If you would like to review or change the information in your account or terminate your account, you can log into your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements. Data Retention Policy.

We retain personal data for as long as necessary to provide our Services and comply with legal obligations. Retention periods vary based on data type:

Data Retention Policies

  • Account and Profile Data: Retained for the duration of your account and up to 12 months after account deletion unless legally required otherwise.
  • Gameplay History: Retained for 12 months to enhance user experience and maintain game integrity.
  • Financial Transactions: Retained for seven years to comply with tax and regulatory obligations.
  • Customer Support Records: Retained for two years for training and dispute resolution.

Users may request deletion of their personal data, subject to these retention policies, by emailing support@wagr.co.

4. PARTIES WE MAY SHARE YOUR INFORMATION WITH

We will not share any Personal Data that we have collected from or about you except as described below:

Your Choices Regarding Data Sharing

  • Opt-Out of Third-Party Advertising: You can opt out of targeted advertising by adjusting your app settings or visiting [opt-out link].
  • Restrict Marketing Communications: To stop receiving promotional emails, click "unsubscribe" in the email or update your preferences in-app.
  • Limit Data Sharing with Analytics Providers: Users can disable tracking via device settings (iOS: "Limit Ad Tracking"; Android: "Opt out of Ads Personalization").
  • Full Data Deletion: To request deletion of shared data, contact support@wagr.co.

Information Shared with Our Service Providers

We engage external Service Providers to work with us to administer and provide the Services. As part of that they will process your Personal Data on our behalf. These external Service Providers have access to your Personal Data only for the purpose of performing services on our behalf, in compliance with this Privacy Policy, and we make sure each one is contractually obliged not to disclose or use your Personal Data for any other purpose.

  • Platform and Software Management: Run, operate, and maintain our Services through third-party platform and software tools.
  • Content and Analytics: Perform content moderation, crash analytics, game, app, and marketing analytics.
  • Messaging and Marketing: Run email and mobile messaging campaigns.
  • Advertising Services: Provide measurement services and target ads (you can opt out at AbouTads and YourOnlineChoice).
  • Contests and Promotions: Administer live Contests, competitions, and promotions, including registering players, managing check-in and attendance, verifying eligibility, and prize fulfillment.
  • Payment and Support Services: Provide payment attribution, process payments for Contests or other purchases, and offer technical and customer support.

Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) as a Third-Party Service in accordance with their own privacy policy. Such external Third-Party Service does not share your financial information, like credit card number, with us, but it may share limited information with us related to your purchase, like your zip or postal code.

Payment Processing & Financial Data

We partner with third-party payment processors (e.g., PayPal, Stripe, Apple Pay) to handle transactions securely. We do not store your full payment details (e.g., credit card numbers).

  • Secure Processing: Payment providers process transactions in accordance with PCI DSS (Payment Card Industry Data Security Standards).
  • Fraud Prevention: If you suspect fraud or unauthorized payments, please contact your payment provider directly.
  • Dispute Resolution: For payment-related disputes, users should refer to the terms of service of the payment provider.

For any additional questions or concerns, please contact support@wagr.co.

Information Shared with Other Players or Users

When you use our Services, play our App, use social features within the App, or take part in live Contests, we will share certain Personal Data with other players or users.

  • Profile Information: Shared data includes your in-game or in-app profile, such as username, avatar, online status, and team.
  • Gameplay Data: We share your in-game or in-app actions, achievements, real-world locations associated with gameplay, and interactions with gameplay resources.
  • Communication: Your in-game messages and related content shared with other players or users may be visible to them.
  • Third-Party Sharing: Some games or apps link to third-party sharing features on your device that you can use to disclose Personal Data to others outside the Services.

Please note that we do not control and are not responsible for the practices of these third-party sharing features. If you have concerns about data sharing, please contact support@wagr.co.

Information Shared Publicly.

Please note that we do not control and are not responsible for the practices of these third-party sharing features. If you have concerns about data sharing, please contact support@wagr.co.

Information Shared with Third Parties.

We share Anonymous Data with third parties for industry and market analysis. We may share Personal Data with our third-party publishing partners for their direct marketing purposes only if we have your express permission. We do not share Personal Data with any other third parties for their direct marketing purposes.

Information Disclosed for Our Protection and the Protection of Others

We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We only share information about you to government or law enforcement officials or private parties when we reasonably believe necessary or appropriate: (a) to respond to claims, legal process (including subpoenas and warrants); (b) to protect our property, rights, and safety and the property, rights, and safety of a third party or the public in general; or (c) to investigate and stop any activity that we consider illegal, unethical, or legally actionable.

Information Disclosed in Connection with Business Transactions

Information that we collect from our users, including Personal Data, is a business asset. If we are acquired by a third party as a result of a transaction such as as a merger, acquisition, or asset sale, or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, will be disclosed or transferred to a third-party acquirer in connection with the transaction.

In certain circumstances, the Company may share your information with third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include:

  • With vendors or other service providers, such as cloud storage providers, security vendors, data analytics vendors, banks and payment processors;
  • With our affiliates or otherwise within our corporate group;
  • With third parties for marketing purposes, including the sponsors of any Contests;
  • When you request that we share certain information with third parties, such as through your use of social media widgets, login integrations, or interactions with other users of the Services;
  • To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries
  • In connection with an asset sale, merger, bankruptcy, or other business transaction;
  • To ensure the safety and security of the Company and/or its users;
  • When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations; or
  • With professional advisors, such as auditors, law firms, or accounting firms.

5. COOKIES AND OTHER TRACKING TECHNOLOGIES

Cookies Policy   (Effective as of March 28, 2025)

Our Services use cookies, which are small text files that are placed on your computer or device by a web server when you access our Services. We may place and access cookies and similar technologies on your computer or device, which are known as “first party cookies.” Cookies may also be placed and accessed by third parties, which are known as “third party cookies” and are described below.

We use cookies and local storage to monitor aggregate usage and web traffic of our Services, customize and improve our Services, help you navigate our Services, deliver content specific to your interests and deliver advertisements to you.

We also use “web beacons” (also known as web bugs, pixel tags, or clear GIFS) which are small graphics with a unique identifier that may be included on our Services, for example to deliver or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on a user’s hard drive or device, web beacons are typically embedded invisibly on web pages (or in an email).

Types of Cookies

We use the following types of cookies:

  • Strictly Necessary Cookies: These are cookies that are essential to enable you to use the Services, for example moving around our website and using its features (e.g. cookies that enable you to log into the Services).
  • Performance Cookies: These are cookies which collect information about how and when you and other visitors interact with our Services (e.g. pages viewed most often) and the information collected by these cookies is used to improve how our Services work.
  • Functionality Cookies: These are cookies that allow our Services to remember choices you have made (such as your login information) and provide you with content and features which are customized to you.For example, providing you with relevant content by using a cookie to remember which region you are in.
  • Advertising Cookies: These are cookies which are used to deliver advertisements to you which are more relevant to you and your interests.We may also share this type of information with third parties for these purposes.

The types of cookies described above may be "session cookies" or "persistent cookies." Session cookies are only stored on your device while you are using the Services and are deleted when you log off from the Services or close your browser. Persistent cookies remain on your device for a period of time after you log off from the Services or close your browser.

Third Party Cookies

Some cookies may be placed by third parties when you use the Services as some third-party service providers that we engage (including third party advertisers) may place their own cookies on your hard drive or device.These cookies may provide information to those third parties about your browsing habits or may be used for security. Some also help to serve you with advertisements which are more relevant to you.

Google:

For example, our websites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses non-operational cookies, which are text files placed on your computer or device to help the website or app analyze how visitors use the website or app. The information generated by the cookie about your use of the website or app (including your IP address) will be transmitted to and stored by Google on servers in the United States. At our request, Google will use this information for the purpose of evaluating how the website or app is used, compiling reports on website/app activity for operators and providing other services relating to website/app activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.

Facebook:

Similarly, we use the Facebook pixel service. The Facebook pixel is an analytics tool that allows us to measure the effectiveness of our advertising by understanding the actions you take on other websites or apps. We use it to make sure our advertising on Facebook is shown to the right people and is effective. When you visit our website or app and take an action, this triggers the pixel which reports this action to Facebook.

By using our Services, you consent to the processing of data about you by Google and Facebook in the manner and for the purposes set out above.

Cookie Settings

You may decline cookies that are not Strictly Necessary by clicking "Decline" in the cookie banner at the bottom of your screen. Additionally, although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. However, if you don't accept cookies, you may not be able to access all portions or features of the Services. If you continue to use the Services, you consent to our use of cookies as described in this Cookies Policy.

Do Not Track Signals

Your browser settings may allow you to transmit a "Do Not Track" signal when you visit various websites. Like many websites, our Website is not designed to respond to "Do Not Track" signals received from browsers. To learn more about "Do Not Track" signals, you can visit http://www.allaboutdnt.com/.

Cookies and Other Tracking Technologies

Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services to work incorrectly or not function at all.

Managing Your Cookie Preferences

We use cookies to improve user experience and for analytics/advertising. You can manage your preferences by:

  • Adjusting Browser Settings. Disable cookies via browser options.
  • Using Our Cookie Management Tool. Modify cookie preferences in the Privacy Settings section of our app/website.
  • Opting Out of Targeted Ads. Use YourAdChoices or Your Online Choices (EU) to manage interest-based advertising.

Note: Disabling cookies may impact gameplay and app functionality.

6. THIRD PARTY WEBSITES AND LINKS

We may provide links to third-party websites or other online platforms operated by third parties. If you follow these links to sites or interact with features (e.g., applications offered by third parties or social media widgets) not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions.

We do not guarantee and are not responsible for the privacy, security, accuracy, completeness, or reliability of information found on these third-party sites. Information you provide on public or semi-public venues, including third-party social networking platforms like Facebook or X (formerly Twitter), may be viewable by other users without limitation on its use by us or third parties.

Our inclusion of such links does not imply endorsement of the content, owners, or operators, except as disclosed. In using our Services, you may access Third-Party Services owned/operated by others. Any information provided to a Third-Party Service is subject to their privacy policy, not ours. We're not responsible for the content, privacy, or security practices of any Third-Party Service.

To protect your information, we recommend reviewing their policies.

7. CHILDREN'S PRIVACY

Children are not allowed to use the Services. We do not seek or knowingly collect any Personal Data from children. If we become aware that we have unknowingly collected information about a child, we will make commercially reasonable efforts to delete such information from our database.

We define children as follows:

  • Residents of the UK: anyone under 13 years old.
  • Residents of the EEA: anyone under 16 years old, or the age needed to consent to the processing of personal data in your country of residence.
  • Residents of the Republic of Korea: anyone under 14 years old.
  • Residents of other regions: anyone under 13 years old or the age needed to consent to the processing of personal data in that region.

If you are the parent or guardian of a child under 13 years of age who has provided us with their Personal Data, you may contact us using the below information to request that it be deleted.

Parental Controls & Child Safety

  • Our Services are not intended for children under 13 (or under 16 in the EEA).
  • Parents can use built-in parental controls on iOS/Android to restrict purchases and in-game communication.
  • If a minor creates an account without parental consent, we will delete the account upon request (email support@wagr.co).

8. DATA SECURITY

Please be aware that, despite our reasonable efforts to protect your information, no security measures are perfect or impenetrable, and we cannot guarantee "perfect security." Please further note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit.

We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us.

Data Breach Notification

While we take reasonable measures to protect your personal data, no system is entirely secure. In the event of a data breach that compromises your personal data, we will notify affected users within 72 hours via email and/or in-app notifications. Where legally required, we will also report breaches to regulatory authorities and provide guidance on protective measures you can take.

If you suspect unauthorized access to your account, please contact us immediately at support@wagr.co

9. SPECIFIC DISCLOSURES FOR CALIFORNIA RESIDENTS

California law requires that we make certain disclosures about your data. The following disclosures are made pursuant to the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 ("CCPA").

Collection and Use of Personal Data

In the preceding 12 months, we have collected the following categories of Personal Data: identifiers, commercial information, Internet or other electronic network activity information, geolocation data, and visual information. To learn more about the specific information we collect, the sources and purposes of such collection, please see Section 2 ("Our Collection and Use of Information").

Sale or Sharing of Personal Data

We do not sell or share your Personal Data as those terms are defined under the CCPA. We have no actual knowledge of selling or sharing the Personal Data of minors under 16 years of age.

Disclosure of Personal Data for a Business Purpose

In the preceding 12 months, we have disclosed for a business purpose the following categories of Personal Data: identifiers, commercial information, Internet or other electronic network activity information, geolocation data, and visual information. To learn more about the disclosure of your Personal Data, please see Section 4 ("Parties We May Share Your Information With").

Your CCPA Rights

Right to Know and Access Personal Data

You have the right to request the categories and specific pieces of Personal Data we have collected about you.

Right to Delete Personal Data

You have the right to request the deletion of your Personal Data, subject to certain exceptions.

Right to Correct Inaccurate Personal Data

You have the right to request the correction of any inaccurate Personal Data that we maintain about you.

Right to Limit Use and Disclosure of Sensitive Personal Data

We do not collect or process sensitive Personal Data for the purpose of inferring characteristics about you. We also do not disclose sensitive Personal Data for purposes other than those specified in Section 7027(m) of the California Privacy Rights Act regulations promulgated by the California Privacy Protection Agency. Therefore, we do not offer you the option to limit the use of your sensitive Personal Data.

Right to Opt Out of Sale or Sharing

Under California law, consumers have the right to opt out of the sale or sharing of their Personal Data. Because we do not sell or share data for this purpose, we do not offer this opt out.

Right of Non-Discrimination

You have the right to exercise the privacy rights conferred to you under the CCPA without receiving discriminatory treatment. We do not discriminate against you for exercising the privacy rights conferred to you under the CCPA.

10. YOUR CHOICES

We may send periodic informational emails to you. You may opt out of such communications by following the opt-out instructions contained in the email.

Note: If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about any Services you have requested or received from us.

11. YOUR RIGHTS UNDER THE GDPR

In addition to the other disclosures in this Policy, we make the following express disclosures in accordance with the GDPR and hereby notify you of your rights:

RightDescription
Right to AccessThe right to be provided with a copy of your Personal Data (the right of access)
Right to RectificationThe right to require us to correct any mistakes in your Personal Data
Right to be ForgottenThe right to require us to delete your Personal Data—in certain situations
Right to Restriction of ProcessingThe right to require us to restrict processing of your Personal Data—in certain circumstances, e.g. if you contest the accuracy of the data
Right to Data PortabilityThe right to receive the Personal Data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to ObjectThe right to object: —at any time to your Personal Data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your Personal Data, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-MakingThe right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.

Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format (e.g., JSON, CSV). To request a copy of your data, email support@wagr.co with the subject "Data Portability Request." We will process your request within 30 days.

12. TRANSFERRING YOUR PERSONAL DATA

We operate our Services throughout the world. Your Personal Data will likely be transferred and stored in a country outside of your home country, including in the USA, for the purposes outlined in this Privacy Policy to the extent permitted by applicable laws. The data protection laws in these countries may not be the same as in your home country.

If we transfer your Personal Data from the UK or the EEA to other countries, including the USA, we ensure that a similar degree of protection is provided to your Personal Data as within the UK or the EEA, as applicable, by ensuring that at least one of the following safeguards is implemented:

  • The country that your Personal Data is transferred to is a country that the European Commission (or the UK Government, if you are based in the UK) has deemed to provide an adequate level of protection for Personal Data as the UK or the EEA, as applicable.
  • We use specific contracts approved by the European Commission (or the UK Information Commissioner's Office, if you are based in the UK), which give Personal Data the same protection as it has in the UK or the EEA, as applicable, when we engage with service providers.

International Data Transfers & Legal Safeguards

  • If you are in the EEA, UK, or Switzerland, we rely on Standard Contractual Clauses (SCCs) to protect your data.
  • Users in California, Canada, and Australia have similar protections based on applicable laws.
  • You can request a copy of our data transfer agreements by emailing support@wagr.co

13. CALIFORNIA PRIVACY RIGHTS ADDENDUM

A. California Privacy Notice

This CALIFORNIA PRIVACY NOTICE ("Notice") supplements our Privacy Policy. We have adopted this Notice to comply with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 ("CCPA").

B. Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("Personal Data"). The table below indicates whether we have collected certain types of Personal Data in the preceding 12 months:

CategoryExamplesCollected?
IdentifiersA real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.YES
Personal Data categories listed in the California Customer Records statuteIncluding but not limited to name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Data included in this category may overlap with other categoriesYES
Protected classification characteristics under California or federal law.Age (40 years or older), national origin, citizenship, marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic informationNO
Commercial InformationRecords of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.YES
Biometric DataAn individual's physiological, biological or behavioral characteristics that can be used singly or in combination with each other or with other identifying data, to establish individual identity. . Facial recognition technology collects information from your image capture, including biometric data, and shares this information with us, which assists us to verify your ID.YES
Internet or other similar network activityBrowsing history, search history, information on a consumer's interaction with a website, application, or advertisement.YES
Geolocation DataPhysical location/movementsYES
Audio/visual dataAudio, electronic, visual, thermal, olfactory, or similar information.YES
Professional or employment related informationCurrent or past job history or performance evaluations.NO
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.NO
Inferences drawn from other Personal DataProfile reflecting a person's preferences, characteristics, predispositions, behavior, etc.YES

C. Personal Data Sources

We obtain the categories of Personal Data listed above from the following categories of sources:

1. Directly from our Users

For example, from when Users register for our Services.

2. Directly and indirectly from activity on our websites and applications

(a) Usage and log information: For example, service-related, diagnostic and performance information. This includes information about your activity on our websites and applications, log files, and reports.

(b) Device and connection information: We collect device-specific information such as hardware model, operating system information, browser information, IP address, etc.

3. From third parties that interact with us

We may work with third parties, for example, in order to understand, customize, support and market the services we provide and/or to comply with laws.

D. Use of Personal Data

We may use or disclose the Personal Data we collect for one or more of the following business purposes as disclosed in our Privacy Policy:

  • To provide and manage the services you request;
  • To improve customer service and our services;
  • To process payments;
  • To personalize user experience;
  • To contact you about our services;
  • To send important notices to you;
  • To comply with our legal and regulatory obligations;
  • To offer alternative dispute resolution services.

E. Other Personal Data

We will not collect additional categories of Personal Data or use the Personal Data we collect for materially different, unrelated, or incompatible purposes without providing you notice.

F. Sharing Personal Data

We may disclose your Personal Data to a third party for business purposes. When we disclose Personal Data for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except for performing the contract.

We disclose your Personal Data for a business purpose to the following categories of third parties:

  • Our affiliates;
  • Service providers;
  • Third parties that interact with us in connection with the services we perform.

We do not sell your Personal Data.

G. Specific Rights

You have the right to access the Personal Data we've collected about you during the past 12 months and information about our data collection practices. You also have the right to request that we delete the Personal Data we have collected from you.

H. Exercising Access and Deletion Rights

To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by contacting us as set forth below. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Data.

If you decide to use an authorized agent, please also include written permission that you have designated that agent to make this request, or proof of the agent's power of attorney. We may follow up with you to verify your identity before processing your authorized agent's request. You may also make a verifiable consumer request on behalf of your minor child.

In order for your consumer request to be verifiable, you must provide sufficient information that allows us to reasonably verify whether you are the person about whom we collected Personal Data or an authorized representative. You will need to provide:

  1. Full name
  2. Date of birth
  3. Address
  4. Email address
  5. Whether you are a California consumer pursuant to CCPA
  6. If you would like to know the specific pieces of Personal Data that we have collected about you, or to delete your Personal Data
  7. Identification that clearly shows your name, date of birth and address (for example, passport or other photo identification)
  8. Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it

Authorized Agents

If you decide to use an authorized agent, please include written permission or proof of power of attorney. We may follow up to verify your identity before processing the request.

Accessing & Downloading Your Data

If you are a California resident, you may request a copy of the data we hold about you, including gameplay history, account details, and transaction records.

  • Requests can be submitted via support@wagr.co or through the in-app "Privacy Settings."
  • Data will be provided in JSON or CSV format within 45 days of request verification.

I. Verifiable Consumer Request

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Making a verifiable consumer request does not require you to create an account with us.

J. Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

  • If you have an account, we will deliver our response to that account.
  • If you don't have an account, we will deliver our response by mail or electronically, at your option.
  • Disclosures will cover the 12-month period preceding the request.
  • Data will be provided in a readily useable format for easy transmission.

We do not charge a fee unless the request is excessive, repetitive, or manifestly unfounded.

If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request

K. No Discrimination Policy

We will not discriminate against you for exercising any of your CCPA rights.

L. Updates to Notice

This Notice may be updated from time to time to reflect changes in the Services or how the Services are regulated. We will notify you of changes by posting changes here, or by other appropriate means.

Any Personal Data we collect is covered by the Privacy Policy in effect at the time the data is collected. You will be given reasonable notice of any material change.

14. YOUR RIGHTS, CHOICES, AND HOW TO CONTACT US

You may exercise your rights under this Privacy Policy by reviewing the list of options below.

Should you have any questions about our privacy practices or this Privacy Policy, please email us at support@wagr.co or contact us at [ADDRESS] and/or [TELEPHONE NUMBER].

To exercise your rights regarding your Personal Data, you can:

  • Request access to the Personal Data we hold on you by emailing support@wagr.co
  • Delete or correct your Personal Data. The easiest way to update your account information is via your in-app settings. You can also submit a customer support request through our support website here or email us at support@wagr.co
  • Ask us to stop processing your Personal Data, including for direct marketing and promotional purposes such as tailored rewards, promotions, and other offers, by emailing support@wagr.co. But be aware that sometimes we need to use your Personal Data in order to provide the Services to you.
  • Complain to a regulator. We'd appreciate the chance to deal with your concerns directly so we'd prefer you to contact us first. However, if you're based in the UK or the EEA and believe that we have not complied with data protection laws, you can complain to your local supervisory authority.
  • If you're based in the EEA, you can also contact our EU Representative, EDPO. EDPO can be contacted:

The law provides exceptions to these rights in certain circumstances. Where you cannot exercise one of these rights due to such an exception, we will explain to you why.

We offer you choices regarding the collection, use, and sharing of your Personal Data and we'll respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.

After you contact us, you may receive an email in order to verify your request. We aim to provide the information or complete the outcome you request within 30 days, or such shorter time period as provided by laws of your jurisdiction.