- Information We receive and how it is used
- Our Websites and other websites
- Cookies and other technologies
- Protection of Personal Information
- Accessing and changing your Personal Information
- Children and minors
- Rights to Your Personal Information
- Contacting Us
The terms “Personal data” and “Personal Information” refers to any data or information relating directly or indirectly to an individual, from which it is practicable for the identity of the individual to be directly or indirectly ascertained, and in a form in which access to or processing of the data is practicable. For the purposes of this Policy, the words “data” and “information” has the same meaning.
The terms “Us”, “Our”, “Ours” and “We”, as well as all other first-person pronouns, are used to refer to WEL, which owns, operates and maintains the Websites.
The terms “You”, “Your”, the “User”, as well as all other second-person pronouns, are used to refer to as the user and/or players of the Websites and/or services provided by Us.
2. Information We receive and how it is used
(a) Information We receive about You
The information that We receive includes sets of information: Your information and the information we receive about You.
Your information is the information entered when You fill out forms on Our Websites, when You register, i.e. It includes Your name, email address, birthday and gender.
The information We receive about You concerns
i. non-personal information:
- Data in relation to the use of the Websites, such as the date and time You visit the Websites, the web address or the URL You are on;
- Data in relation to the Websites services and activities, such as the game You play, the score You make in supported game, achievements You unlocked in supported games and Your game progress in supported games.;
ii. technical information, including:
- the IP address,
- the browser You use,
- the operating system You use;
(b) How We use the information We receive
Any information we receive regarding You is to enable Us to offer better services to You. We may use non-personal and technical information, to improve the design and content of Our Website, to personalize Our visitors’ experience or to offer products, programs and services.
We may also use information to ensure that Our Users are in compliance with our Terms. We do not retain any Personal Information beyond the time it is needed.
(c) Information we share
For external processing
For legal reason
We share Personal Information with companies, organizations or individuals, outside the Company, if We have a reasonable belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- meet any applicable law, regulation, legal process or enforceable governmental request (including legal requests from jurisdictions outside of Hong Kong)
- enforce applicable Terms of Service, including investigation of potential violations detect, prevent, or otherwise address fraud, security or technical issues; or
- protect against harm to the rights, property or safety of the Website, Our Users or the public as required or permitted by law.
(d) Where Your information is located
3. Our Websites and other websites
(a) About Our Websites
Our Websites use a single-login system that let You connect among the Websites, including games and social interaction. In this way, We can provide You with a personalized experience on the Websites.
You are reminded that the links contained or included in Our Websites and Services may direct You to third party websites and they are created and maintained by other businesses and developers who are not part of the Company, so it is important that You read their terms of service and privacy policies as this is Your responsibility.
(b) Privacy Practices of Third Parties
This privacy statement only addresses the use and disclosure of information by Us through Your interaction with Our Websites and Services. Other websites that may be accessible from Our Websites may have their own privacy statements and Personal Information collection, use and disclosure practices. For instance, and purely as an example, some websites require an over eighteen (18) years of age access.
4. Cookies and other technologies
Any information shared or known to Us will not and cannot be used to identify Your identity as they are non-specific. They are merely mathematical or analytical data about Our visitors and their use on Our Websites. The data does not give out any personal details. Cookies may be used to gather this general internet data. When used, cookies are downloaded to Your computer without prompting. The cookie file is stored on Your hard drive, where files are transferred to. This information helps Us improve Our Websites and services provided to You. If you want to disable cookies, please consult the relevant guidelines of the browser that You use and adjust the relevant browser settings. Please note that some features of the Websites may not be available once cookies are disabled.
Due to the communication standards on the Internet, when You visit the Website We automatically receive the URL of the site from which You came and the site to which You are going when You leave the Website. We also receive Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data.
We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve Our Service, and to gather demographic information about Our user base as a whole. We may use this information for marketing and advertising purposes. The link between Your IP address and Your personally identifiable information is not shared with third parties without Your permission.
5. Protection of Personal Information
We take the security of your Personal Information very seriously. We work hard to protect the Website and Our users from unauthorized access, alteration, disclosure or destruction of information within Our control.
- We encrypt many of Our services using Secure Sockets Layer (SSL)
- We review Our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
- We restrict access to Personal Information to the Company’s employees, contractors and agents who need to know that information in order to process it for Us, and who are subject to contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
Data you provide Us with will be stored on secure servers. We take all reasonable steps to ensure the safety of the data transfer in agreement with this Policy. Transmission of data via the Internet is never completely secure, thus a guarantee of data sent electronically or transmitted cannot be given. Information offered is therefore at Your own risk.
We use a reasonably secure method to destroy Personal Information.
6. Accessing and changing your Personal Information
You can access and change any Personal Information. For a complete set of copy of Personal Information we have about You, it will be provided, free of charge, within a reasonable period of time and in any event no later than 14 days after We received a written request from You. We might need to verify that You are in fact the data subject before We can proceed with such a request.
Sometimes We may not be able to process a request to change your Personal Information due to technical or other reasons. We will inform You when this is the case.
7. Children and minors
We understand the importance of taking extra precautions to protect the privacy and safety of children using Our Websites and Services. Children under the age of 13, or equivalent minimum age in the relevant jurisdiction, unless their parent or legal guardian provided verifiable consent.
If We learn that We have collected the Personal Information of a child under 13, or equivalent minimum age depending on jurisdiction, without his/her parent’s or legal guardian’s consent, We will take steps to delete the information as soon as possible.
If the User is a minor, i.e. under the age of 18, his/her parent or legal guardian can request access, change or delete of the Personal Information We have, or refuse to allow any further reception or use of the information by a written letter to Us at email@example.com
In order to protect the Users’ privacy and security, reasonable steps will be taken to verify the parent’s or legal guardian’s identity before granting access to the Personal Information. Therefore, it is very important to include, in Your letter, Your email address as well as a telephone number where we can reach you.
8. Rights to Your Personal Information
For all Users, since We adopt the laws of Hong Kong, the Personal Data (Privacy) Ordinance, Cap. 486, provides You with certain rights to Your Personal Information, such as the right to access, change and delete the data You provided to Us. If You change any of Your information, We may keep a copy of the information that You originally provided to Us in Our archives for uses documented in this Policy. Your information will be deleted upon Your request at any time by contacting Us.
- You are informed of all types of Personal Information We hold, the source of that information, who We share it with, what We do with it and how long We will keep it;
- We explained places where We keeps Personal Information and the ways data flows between them;
- We have provided a lawful basis to explain why We need to process Personal Information;
- We have appointed a Data Protection Officer (DPO) in which You can contact by sending an email to the address provided in the “Contacting Us” section;
- Our decision makers are fully aware of the GDPR guidelines;
- Our technical security is up to date;
- All of Our staff are aware of data protection;
- We will report Personal data breaches within 72 hours to the local authority;
- We have a contract with all data processors that We share the data with;
- You can easily access and update Your Personal Information;
- We automatically delete data that We no longer has any use for;
- You can easily request Us to delete or stop processing Your Personal Data;
- When children's Personal Data are involved, We take reasonable steps to verify their age and ask consent from their parent or legal guardian; and
- We regularly review policies for changes, effectiveness, changes in handling of data and changes to the state of affairs of other countries the data flows to.
9. Contacting Us
If You have any questions, queries, comments, or requests, We are happy to receive and answer them. Please feel free to contact Us by sending an email at firstname.lastname@example.org