New players: use code WINNLY for 50 Pink + 50 Blue CoinsNew players: use code WINNLY for 50 Pink + 50 Blue CoinsNew players: use code WINNLY for 50 Pink + 50 Blue CoinsNew players: use code WINNLY for 50 Pink + 50 Blue CoinsNew players: use code WINNLY for 50 Pink + 50 Blue CoinsNew players: use code WINNLY for 50 Pink + 50 Blue Coins
Back to home
Winnly

Privacy Policy

Last updated: 17th November 2025

Preamble

We take your privacy very seriously. The following Privacy Policy describes how V2 Labs Limited, Apelli 14, 1080 Nicosia, Cyprus (hereinafter referred to as "V2 Labs Limited" or "we", "us", "our") and third-party marketing and advertising partners collect, use, process and share your personal Data (hereinafter referred to as "Data") about you. Personal Data is any Data that can be used to personally identify you.

This Privacy Policy applies to all processing of personal Data carried out by us, for example, as part of the provision of our services, on our websites (in particular https://playwinnly.com) as part of external online presences, such as our social media profiles, and for all of our games, whether played in our App (hereinafter collectively referred to as "Online Services" or "Services").

When you download, access and/or play our Online Services or interact with our websites and other Services, you consent to the collection and use of your information in accordance with this Privacy Policy. This includes consenting to the use of your information by V2 Labs Limited and our advertising partners for targeted advertising purposes. If you have concerns about allowing us to use Data in accordance with this Privacy Policy, you should not use our Online Services.

The terms used are not gender specific.

If you have any questions or comments about our privacy practices, please feel free to contact us at hello@playwinnly.com.

Controller

V2 Labs Limited Apelli 14 1080 Nicosia Cyprus

Authorized Representative: Viktor Holter

E-Mail-Address: hello@playwinnly.com

Legal Notice: https://playwinnly.com/

Collection of your Data

The types of personal Data we collect depend on the one hand on the requirements of applicable law. On the other hand, the collection of the Data depends on how you interact with us and our Services.

We collect information that you provide to us, information that we receive automatically when you use our Services, and information from other sources such as third-party services.

The Data listed below is used to fully provide our Services. We cannot fully provide our Services without this Data.

When you use our services

We may automatically collect the following Data when you use our Services, in particular the game:

  • Game Data such as game score, game time, use of game features and Data related to bugs and malfunctions.
  • Settings within the game
  • Meta/communication and process Data (e.g. device information, IP addresses, time information, identification numbers, consent status).

This Data is collected by us to enable you to use our Services and to make both your scores and settings accessible to you and to improve the security of our Services.

When third-party service providers provide us with your Data

You may choose to share personal data with or interact with third party websites and/or applications, and to allow such third-party websites and/or applications to transfer your data to us, for example, when you link third party accounts to our Online Services; this includes but is not limited to external digital wallet extensions. Once your personal data has been shared with a third-party website or application, it is also subject to that third-party's privacy policy. We encourage you to carefully read the privacy policy of any third-party website or application before sharing your personal data or otherwise interacting with them. Please note that we have no control over third party websites or third-party applications and are not responsible for the processing of your personal data that you submit to third parties.

We use such data to provide and establish functionality for you to connect with the third parties.

In addition to the information about the collection of your Data set forth here, you can find more detailed information about the collection of your Data in the paragraphs below.

Use of Cookies

Cookies are small text files or other data records that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the contents accessed or the functions used. Cookies can also be used for various purposes, e.g. for purposes of functionality, security and convenience of online offers as well as the creation of analyses of visitor flows.

Information on consent: We use cookies in accordance with the statutory provisions. Therefore, we obtain prior consent from users, except when it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is strictly necessary in order to provide an information society service explicitly requested by the subscriber or user. Essential cookies usually include cookies with functions related to the display and operability of the online service, load balancing, security, storage of users' preferences and choices or similar purposes related to the provision of the main and secondary functions of the online service requested by users. The revocable consent will be clearly communicated to the user and will contain the information on the respective cookie use.

Information on legal bases under data protection law: The legal basis under data protection law on which we process users' personal data with the use of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in a business operation of our online services and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. For which purposes the cookies are processed by us, we do clarify in the course of this privacy policy or in the context of our consent and processing procedures.

Retention period: With regard to the retention period, a distinction is drawn between the following types of cookies:

Temporary cookies (also known as "session cookies"): Temporary cookies are deleted at the latest after a user has left an online service and closed his or her end device (i.e. browser or mobile application).

Permanent cookies: Permanent cookies remain stored even after the terminal device is closed. For example, the login status can be saved, or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.

General information on revocation and objection (so-called "Opt-Out"): Users can revoke the consents they have given at any time and object to the processing in accordance with legal requirements. Users can restrict the use of cookies in their browser settings, among other options (although this may also limit the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be made through the websites https://optout.aboutads.info and https://www.youronlinechoices.com.

Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Consent (Article 6 (1) (a) GDPR.

Processing Cookie Data on the Basis of Consent

We use a cookie management solution in which users' consent to the use of cookies, or the procedures and providers mentioned in the cookie management solution, can be obtained, managed and revoked by the users. The declaration of consent is stored so that it does not have to be retrieved again and the consent can be proven in accordance with the legal obligation. Storage can take place server-sided and/or in a cookie (so-called opt-out cookie or with the aid of comparable technologies) in order to be able to assign the consent to a user and/or his/her device. Subject to individual details of the providers of cookie management services, the following information applies: The duration of the storage of the consent can be up to two years. In this case, a pseudonymous user identifier is formed and stored with the date/time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and used end device.

Legal Basis: Consent (Article 6 (1) (a) GDPR).

Provision of Online Services and Web Hosting

We process user data in order to be able to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to transmit the content and functions of our online services to the user's browser or terminal device.

Processed data types: Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status); Content data (e.g. text input, photographs, videos).

Data subjects: Users (e.g. website visitors, users of online services); Business and contractual partners; Customers.

Purposes of Processing: Provision of our online services and usability; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.); Security measures; Provision of contractual services and fulfillment of contractual obligations.

Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Provision of online offer on rented hosting space

For the provision of our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a "web hoster").

Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Collection of Access Data and Log Files

The access to our online services is logged in the form of so-called "server log files". Server log files may include the address and name of the web pages and files accessed, the date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a general rule, IP addresses and the requesting provider.

The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the stability and optimal load balancing of the servers.

Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR.

Retention period: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.

Special Notes on Applications (Apps)

We process the data of the users of our application to the extent necessary to provide the users with the application and its functionalities, to monitor its security and to develop it further. Furthermore, we may contact users in compliance with the statutory provisions if communication is necessary for the purposes of administration or use of the application. In addition, we refer to the data protection information in this privacy policy with regard to the processing of user data.

Legal basis: The processing of data necessary for the provision of the functionalities of the application serves to fulfil contractual obligations. This also applies if the provision of the functions requires user authorization (e.g. release of device functions). If the processing of data is not necessary for the provision of the functionalities of the application, but serves the security of the application or our business interests (e.g. collection of data for the purpose of optimizing the application or security purposes), it is carried out on the basis of our legitimate interests. If users are expressly requested to give their consent to the processing of their data, the data covered by the consent is processed on the basis of the consent.

Information on the functions of the application

When linking your account to the respective wallet and using our services, the wallet ID is stored and processed by us for the creation of a profile. The wallet ID may originate from services such as Metamask, Coinbase, and any other wallet providers.

Processed data types: Inventory data (e.g. names, addresses); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status); Payment Data (e.g. bank details, invoices, payment history); Contract data (e.g. contract object, duration, customer category).

Data subjects: Users (e.g. website visitors, users of online services).

Purposes of Processing: Provision of contractual services and fulfillment of contractual obligations.

Legal Basis: Consent (Article 6 (1) (a) GDPR); Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR).

Commercial use

We process the data of the users of our application, registered and any test users (hereinafter uniformly referred to as "users") in order to provide them with our contractual services and on the basis of legitimate interests to ensure the security of our application and to develop it further. The required details are identified as such within the scope of the conclusion of a contract for the use of the application, the conclusion of an order, an order or a comparable contract and may include the details required for the provision of services and any invoicing as well as contact information in order to be able to hold any consultations.

Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Device authorizations for access to functions and data

The use of certain functions of our application may require access to the camera and the stored recordings of the users. By default, these authorizations must be granted by the user and can be revoked at any time in the settings of the respective devices. The exact procedure for controlling app permissions may depend on the user's device and software. Users can contact us if they require further explanation. We would like to point out that the refusal or revocation of the respective authorizations can affect the functionality of our application.

Unity Analytics & Game Data Information

When you play our games or access our services, we may automatically collect and process game state information. We use Unity Analytics to collect game and device data from our players. Data collected by Unity includes, but is not limited to, hardware specifications, usage data, custom event data, and player retention data (if applicable). Privacy Policy: https://unity3d.com/legal/privacy-policy. https://unity3d.com/legal/gdpr.

Crash data

We use Unity Developer Services to automatically collect information when you access or use our services. Unity Developer Services provides device information, including data that could be considered personal information (machine ID). The information is anonymized before it is stored. Log data may include your device specifications, country of installation, and crash data, including the action the game was attempting to complete when the crash occurred. Privacy Policy: https://unity3d.com/legal/privacy-policy. https://unity3d.com/legal/gdpr.

Download of Applications via App Stores

The download of our apps is done via special online platforms operated by other service providers (so-called "app stores"). In this context, the data protection notices of the respective app stores apply in addition to our data protection notices. This applies in particular with regard to the methods used on the platforms for web analytics and for interest-related marketing as well as possible costs.

Processed data types: Inventory data (e.g. names, addresses); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. e-mail, telephone numbers); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status); Content data (e.g. text input, photographs, videos).

Data subjects: Customers; Users (e.g. website visitors, users of online services).

Purposes of Processing: Provision of contractual services and fulfillment of contractual obligations; Marketing.

Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR.

Contact and Inquiry Management

When contacting us (e.g. via mail, contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).

Data subjects: Communication partner (Recipients of e-mails, letters, etc.).

Purposes of Processing: Contact requests and communication; Managing and responding to inquiries; Feedback (e.g. collecting feedback via online form); Provision of our online services and usability.

Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Performance of a contract and prior requests (Article 6 (1) (b) GDPR.

Contact form

When users contact us via our contact form, e-mail or other communication channels, we process the data provided to us in this context to process the communicated request.

Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Sweepstakes and Contests

We process personal data of participants in competitions, contests, raffles, prize-draws or sweepstakes (hereinafter referred to as "competitions") only in compliance with the relevant data protection regulations and if the processing is contractually necessary for the provision, execution and handling of the competition, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the competition or the protection of our interests against misuse by possible recording of IP addresses when submitting entries to the competition.

In the event that entries are published as part of the competitions (e.g. as part of a vote or presentation of the competition entries, or the winner or reporting on the competition), we would like to point out that the names of participants may also be published in this context. The participants can object to this at any time.

If the competitions take place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as "online platform"), the usage and data protection provisions of the respective online platforms also apply. In such cases, we would like to point out that we are responsible for the information provided by the participants as part of the competition and that we must be contacted with regard to the competitions.

The data of the participants will be deleted as soon as the competition has ended and the data is no longer required to inform the winners or because questions about the competition can be expected. In general, the data of the participants will be deleted at the latest 6 months after the end of the competition. Winners' data can be retained for a longer period of time, e.g. in order to answer questions about the prizes or to fulfil the prizes; in this case, the retention period depends on the type of prize and is up to three years for items or services, e.g. in order to be able to process warranty claims. Furthermore, the participants' data may be stored for longer, e.g. in the form of coverage of the competition in online and offline media.

Insofar as data was collected for other purposes as part of the competition, its processing and storage period shall be governed by the privacy information for this use (e.g. in the case of registration for a newsletter as part of a competition).

Processed data types: Inventory data (e.g. names, addresses); Content data (e.g. text input, photographs, videos); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).

Data subjects: Participants in sweepstakes and competitions.

Purposes of Processing: Conducting sweepstakes and contests.

Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Web Analysis, Monitoring and Optimization

Web analysis is used to evaluate the visitor traffic on our website and may include the behaviour, interests or demographic information of users, such as age or gender, as pseudonymous values. With the help of web analysis we can e.g. recognize, at which time our online services or their functions or contents are most frequently used or requested for repeatedly, as well as which areas require optimization.

In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our online services or their components.

Unless otherwise stated below, profiles, i.e. data aggregated for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.

The IP addresses of the users are also stored. However, we use any existing IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect the user. In general, within the framework of web analysis, A/B testing and optimisation, no user data (such as e-mail addresses or names) is stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.

Processed data types: Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).

Data subjects: Users (e.g. website visitors, users of online services).

Purposes of Processing: Remarketing; Affiliate Tracking; Web Analytics (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (Creating user profiles); Provision of our online services and usability; Targeting (e.g. profiling based on interests and behaviour, use of cookies).

Security measures: IP Masking (Pseudonymization of the IP address).

Legal Basis: Consent (Article 6 (1) (a) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR.

Firebase

Google Firebase is a platform for developers of apps for mobile devices and websites. Google Firebase offers a variety of features for testing apps, monitoring their functionality and optimizing them. The functions include the storage of apps including personal data of the application users, such as content created by them or information regarding their interaction with the apps (so-called "cloud computing"). Google Firebase also offers interfaces that allow interaction between the users of the app and other services, e.g. authentication using services such as Facebook, Twitter or an e-mail password combination.

Google Analytics (server-side use)

We use Google Analytics to perform measurement and analysis of the use of our online services by users. In this process, data of users is processed, but not directly transmitted from the end device of the users to Google. In particular, the IP address of the user is not transmitted to Google. Instead, the data is first transmitted to our server, where the user data records are assigned to our internal user identification number. The subsequent transmission only takes place in such a pseudonymized manner from our server to Google. The identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognize which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online services. Likewise, the time of use and its duration are stored, as well as the sources of users referring to our online services and technical aspects of their end devices and browsers. In this process, pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used.

Google Signals (Google Analytics function)

Google signals are session data from sites and apps that Google associates with users who have signed in to their Google accounts, and who have turned on Ads Personalization. This association of data with these signed-in users is used to enable cross-device reporting, cross-device remarketing, and cross-device conversion export to Ads.

Google Analytics Audiences

We use Google Analytics to display ads placed by Google and its partners only to users who have shown an interest in our online services or who have specific characteristics (e.g. interests in specific topics or products determined on the basis of the websites visited) that we transmit to Google (so-called "Remarketing Audiences" or "Google Analytics Audiences"). With the help of remarketing audiences, we also want to ensure that our ads match the potential interest of users.

Google Analytics in Consent Mode

In consent mode, personal data of users is processed by Google for measurement and advertising purposes depending on the consent of the users. The consent is obtained from the users as part of our online services. If the consent of the users is missing altogether, then the data is only processed on an aggregated (i.e. not assigned to individual users and summarized) level. If the consent only includes statistical measurement, then no personal data of the users will be processed for ad display or measurement of the success of advertisements (so-called "conversion").

Online Marketing

We process personal data for the purposes of online marketing, which may include in particular the marketing of advertising space or the display of advertising and other content (collectively referred to as "Content") based on the potential interests of users and the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedure is used by which the relevant user information for the display of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, communication partners and technical information such as the browser used, computer system used and information on usage times and used functions. If users have consented to the collection of their sideline data, these can also be processed.

The IP addresses of the users are also stored. However, we use provided IP masking procedures (i.e. pseudonymisation by shortening the IP address) to ensure the protection of the user's by using a pseudonym. In general, within the framework of the online marketing process, no clear user data (such as e-mail addresses or names) is secured, but pseudonyms.

The information in the profiles is usually stored in the cookies or similar memorizing procedures. These cookies can later, generally also on other websites that use the same online marketing technology, be read and analyzed for purposes of content display, as well as supplemented with other data and stored on the server of the online marketing technology provider.

Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing technology we use and the network links the profiles of the users in the aforementioned data. Please note that users may enter into additional agreements with the social network providers or other service providers, e.g. by consenting as part of a registration process.

As a matter of principle, we only gain access to summarised information about the performance of our advertisements. However, within the framework of so-called conversion measurement, we can check which of our online marketing processes have led to a so-called conversion, i.e. to the conclusion of a contract with us. The conversion measurement is used alone for the performance analysis of our marketing activities.

Unless otherwise stated, we kindly ask you to consider that cookies used will be stored for a period of two years.

Processed data types: Content data; Usage data; Meta, communication and process data; Event Data (Facebook); Contact Information (Facebook).

Data subjects: Users (e.g. website visitors, users of online services).

Purposes of Processing: Web Analytics; Targeting; Conversion tracking; Affiliate Tracking; Marketing; Profiles with user-related information; Provision of our online services and usability; Remarketing; A/B Tests; Cross-Device Tracking.

Security measures: IP Masking (Pseudonymization of the IP address).

Legal Basis: Consent (Article 6 (1) (a) GDPR).

Opt-Out: We refer to the privacy policies of the respective service providers and the possibilities for objection (so-called "opt-out"). If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered collectively for each area:

Meta Pixel and Custom Audiences

With the help of the Meta-Pixel (or equivalent functions, to transfer Event-Data or Contact Information via interfaces or other software in apps), Meta is on the one hand able to determine the visitors of our online services as a target group for the presentation of ads (so-called "Meta ads"). Accordingly, we use Meta-Pixels to display Meta ads placed by us only to Meta users and within the services of partners cooperating with Meta who have shown an interest in our online services or who have certain characteristics that we transmit to Meta (so-called "custom audiences"). With the help of Meta-Pixels, we also want to ensure that our Meta ads correspond to the potential interest of users and do not appear annoying. The Meta-Pixel also enables us to track the effectiveness of Meta ads for statistical and market research purposes by showing whether users were referred to our website after clicking on a Meta ad (known as "conversion tracking").

  • Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland
  • Legal Basis: Consent (Article 6 (1) (a) GDPR)
  • Website: https://www.facebook.com
  • Privacy Policy: https://www.facebook.com/about/privacy
  • Basis for third country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses

Advanced matching for the Meta-Pixel

In addition to the processing of Event Data in the context of the use of the Meta-Pixel (or equivalent functions, e.g. in apps), Contact Information (data identifying individual persons, names, email addresses and telephone numbers) is also collected by Meta within our online offer or transmitted to Meta. The processing of contact information serves to form target groups (so-called "Custom Audiences") for the display of content and advertising information based on the presumed interests of users. The collection, or transmission and matching with data available on Meta is not in plain text, but as so-called "hash values", i.e. mathematical representations of the data. After the matching to create target groups, the Contact Information is deleted.

  • Legal Basis: Consent (Article 6 (1) (a) GDPR)
  • Privacy Policy: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland
  • Basis for third country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses

Facebook Ads

Placement of ads within the Facebook platform and analysis of ad results.

TikTok Pixel

Code that is loaded when a user visits our online offering and tracks the user's behavior and conversions, as well as stores it in a profile (possible use cases: measuring campaign performance, optimizing ad delivery, building custom and similar target groups).

TikTok Ads

Placement of ads within the TikTok platform and analysis of ad results.

  • Service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP
  • Legal Basis: Consent (Article 6 (1) (a) GDPR)
  • Website: https://ads.tiktok.com
  • Privacy Policy: https://www.tiktok.com/privacy-policy

Advanced Analytics

Analytics software that we use to measure usage and interaction with our services on or in connection with meta-platforms (by means of so-called events, such as viewing posts or clicking "Like" buttons) and to obtain demographic data about our users (e.g., age average, place of residence, language used). User data is processed by Meta for the purpose of displaying content and ads based on users' presumed interests based on user profiles. The data is only provided to us in aggregated, i.e. summarized form, so that we do not see the data of individual users. We use the results to design our content and services in a user-oriented manner.

  • Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland
  • Legal Basis: Consent (Article 6 (1) (a) GDPR)
  • Website: https://about.facebook.com/de/meta/
  • Basis for third country transfer: Standard Contractual Clauses

ironSource

Provision of features for displaying personalized advertising based on interest and behavior-based information, including demographic characteristics, interests, and browsing history of users, which are stored in user profiles.

AppLovin

Provision of features for displaying personalized advertising based on interest and behavior-based information, including demographic characteristics, interests, and browsing history of users, which are stored in user profiles.

Profiles in Social Networks (Social Media)

We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.

We would like to point out that user data may be processed outside the European Union. This may entail risks for users, e.g. by making it more difficult to enforce users' rights.

In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user's computer, in which the user's usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective networks or will become members later on).

For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data protection declarations and information provided by the providers of the respective networks.

Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.

Processed data types: Contact data; Content data; Usage data; Meta, communication and process data.

Data subjects: Users (e.g. website visitors, users of online services).

Purposes of Processing: Contact requests and communication; Feedback; Marketing.

Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR.

  • Instagram: Social network; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.
  • TikTok: Social network / video platform; Service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.tiktok.com; Privacy Policy: https://www.tiktok.com/privacy-policy.
  • X: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Privacy Policy: https://twitter.com/privacy, Settings: https://twitter.com/personalization.
  • Discord: Chat, audio and video broadcasting, instant messaging, and community management; Service provider: Discord, Inc., 444 De Haro St, Suite 200, San Francisco, California 94107, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://discordapp.com; Privacy Policy: https://discordapp.com/privacy.
  • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Privacy Policy: https://policies.google.com/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF); Opt-Out: https://myadcenter.google.com/personalizationoff.

Links to Third Party Websites

Insofar as we include links to third-party websites on our website, we would like to point out that we are not responsible for the processing of your personal data on the websites of the third parties within the meaning of Art. 4 no. 7 DS-GVO. In this respect, no data processing takes place by us in accordance with the DSGVO. We recommend that our users read the privacy policies of each website and application with which they interact.

Plugins and Embedded Functions and Content

Within our online services, we integrate functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may, for example, be graphics, videos or city maps (hereinafter uniformly referred to as "Content").

The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third parties may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources.

Processed data types: Usage data; Meta, communication and process data; Inventory data; Contact data; Content data.

Data subjects: Users (e.g. website visitors, users of online services).

Purposes of Processing: Provision of our online services and usability; Profiles with user-related information.

Legal Basis: Consent (Article 6 (1) (a) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR.

  • Google Fonts (from Google Server): Obtaining fonts (and symbols) for the purpose of a technically secure, maintenance-free and efficient use of fonts and symbols with regard to timeliness and loading times, their uniform presentation and consideration of possible restrictions under licensing law. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://fonts.google.com; Privacy Policy: https://policies.google.com/privacy.
  • Instagram plugins and contents: This can include content such as images, videos or text and buttons with which users can share content from this online service within Instagram. Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.
  • X plugins and contents: Plugins and buttons of the platform "X" — This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within X. Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://twitter.com; Privacy Policy: https://twitter.com/privacy.
  • Discord: Chat, audio and video broadcasting, instant messaging, and community management; Service provider: Discord, Inc., 444 De Haro St, Suite 200, San Francisco, California 94107, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://discordapp.com; Privacy Policy: https://discordapp.com/privacy.
  • YouTube videos: Video contents; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF).
  • TikTok plugins and contents: TikTok plugins and contents — This can include content such as images, videos or text and buttons; Service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.tiktok.com; Privacy Policy: https://www.tiktok.com/privacy-policy.

Legal Bases for the Processing

In the following, you will find an overview of the legal basis of the GDPR on which we base the processing of personal data. Please note that in addition to the provisions of the GDPR, national data protection provisions of your or our country of residence or domicile may apply. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Article 6 (1) (a) GDPR) — The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Performance of a contract and prior requests (Article 6 (1) (b) GDPR) — Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Compliance with a legal obligation (Article 6 (1) (c) GDPR) — Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate Interests (Article 6 (1) (f) GDPR) — Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If, in addition, more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.

Security Precautions

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing and separation of the data. In addition, we can ensure that data subjects' rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.

TLS/SSL encryption (https): To protect the data of users transmitted via our online services, we use TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology for securing internet connections by encrypting the data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) is displayed in the URL when a website is secured by an SSL/TLS certificate.

Transmission of Personal Data

In the context of our processing of personal data, it may happen that the data is transferred to other places, companies or persons or that it is disclosed to them. Recipients of this Data may include, but are not limited to, the following parties:

  • Service providers involved in the provision of the Services. Service providers use your data to assist us in providing our Services. This includes, for example, service providers who provide us with IT support, hosting, customer service or other services related to our business.
  • Advertising partners to provide personalized advertising or personalized content.
  • Administrative and judicial authorities, where they are entitled to access under applicable law.

In cases of transfer of personal data, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

Data Processing in Third Countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third party services or disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.

If the data protection level in the third country has been recognized by an adequacy decision (Article 45 GDPR), this serves as the basis for data transfer. Otherwise, data transfers only occur if the data protection level is otherwise ensured, especially through standard contractual clauses (Article 46 (2)(c) GDPR), explicit consent, or in cases of contractual or legally required transfers (Article 49 (1) GDPR). Furthermore, we provide you with the basis of third-country transfers from individual third-country providers, with adequacy decisions primarily serving as the foundation. Information regarding third-country transfers and existing adequacy decisions can be obtained from the information provided by the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en.

EU-US Trans-Atlantic Data Privacy Framework: Within the context of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the data protection level for certain companies from the USA as secure within the adequacy decision of 10th July 2023. The list of certified companies as well as additional information about the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov. We will inform you which of our service providers are certified under the Data Privacy Framework as part of our data protection notices.

Storage Period

Unless a more specific storage period has been stated within this privacy policy, your personal data will remain with us until the purpose for processing the data no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the data will be deleted once these reasons no longer apply.

Information, Deletion and Correction

Within the framework of the applicable legal provisions, you have the right at any time to receive information free of charge about your stored personal data, its origin and recipients and the purpose of data processing and, if applicable, the right to have this data corrected or deleted. For this purpose, as well as for further questions on the subject of personal data, you can contact us at any time.

User Restrictions / Underage

The use of our services is only permitted to natural persons of unrestricted legal capacity who do not reside in countries where playing our skill-based games could be prohibited or considered an offer of a security. In particular, minors may not register to use our services.

We do not knowingly collect, solicit or collect personal data from children. If you do not have full legal capacity, we ask that you do not send us any personal data about yourself (e.g., email address, name). If we become aware that we are collecting personal data from minors, we will delete this data as soon as possible. If you think that we have data of a minor, we would like you to contact us.

Rights of Data Subjects

As data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:

  • Right to Object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data which is based on letter (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right of withdrawal for consents: You have the right to revoke consents at any time.
  • Right of access: You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
  • Right to rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
  • Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions, you have the right to demand that the relevant data be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
  • Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
  • Complaint to the supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Changes and Updates to the Privacy Policy

We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, we ask you to note that addresses may change over time and to verify the information before contacting us.

The current version of the privacy policy is always available at: https://playwinnly.com/privacy