Privacy Policy


INTRODUCTION

We at Wasder AB, a Swedish corporation with registered offices at Norrtullsgatan 57, 113 45 Stockholm, Sweden (“Wasder”) respect your privacy and therefore provide you with this Privacy Policy to inform you about what data we collect and how it is used. In addition to this Privacy Policy, you may access further information in our Terms of Service and our Cookie Policy. If anything in the Privacy Policy, Terms of Service or Cookie Policy contradict one another regarding personal data, the version which is more protective of your personal data shall prevail.

Regarding Personal Data collected and processed under this Privacy Policy, Wasder is the controller. The purpose of this Privacy Policy is to explain how we collect, store, use, transfer or disclose your Personal Data. Personal Data means any information that can identify you, directly or indirectly, such as for example your name, location data or online identifiers.

This Privacy Policy applies to the website and platform service www.wasder.gg which we at Wasder provide you with, as well as to any related services such as the Wasder mobile app, (all services related to the website and platform service provided to you hereafter the “Properties”). On the Properties we display and/or link to games, advertisements, livestreams, etc. from a variety of sources not related to us. We at Wasder cannot control or be held liable for these third parties’ privacy practices and content. If you click on any link or advertisement provided by another company or which links to a service outside the Properties, please understand that you are then leaving the Properties and any Personal Data you provide will not be covered by this Policy.

Wasder reserves the right to change this Privacy Policy at any time by posting an updated version online at www.wasder.gg. Therefore, please review the Privacy Policy frequently to ensure you are aware of any changes. If we make a substantial change to the Privacy Policy, we will provide you with a notice through the Properties or by email.

This Privacy Policy was last updated on May 31,  2021.   


YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

The EU’s General Data Protection Regulation (“GDPR”), gives you certain rights to your Personal Data. These rights can be found (mainly) in chapter 3 of the GDPR and include:


Accordingly, we offer transparency and access controls to help users take advantage of those rights, as limited and expected under applicable law: 

If you have any questions about your privacy, your rights, or how to exercise them, please contact us using the information provided to you in the “HOW TO CONTACT US” section of this Privacy Policy. 


THE DATA WE COLLECT AND USE

In this privacy policy we have elected to explain our collection and processing of your Personal Data in the form of categories, as opposed to our cookie policy, which employs a more granular approach. This is because we believe that this way of displaying information to you strikes the most appropriate balance between transparency and user accessibility. If you would like more information what data we collect and how, please feel free to contact us at privacy@wasder.gg

 

Technical data

Technical data consists of data from the device you are using. This is things like your IP-adress, your operating system, your screen resolution, what browser you’re using, location data, etc. Any data that your device has, has the potential to be in this category, so while the most important types of data which we collect are – in our view – the ones listed above, there are some other data points included in this category. We collect technical for a few different reasons, but in all cases the primary reason is the improvement of the Properties and the service we provide for you. Location data helps us improve latency/ping, and helps us detect when global servers are being over-loaded, as an example. Device data helps us improve the Properties for your device, and helps us bugfix and detect faulty interactions with specific device models or types. This processing is done on the basis of our legitimate interests, in accordance with Article 6(1)(f) of the GDPR – please note that you have the right to object to our claim of legitimate interest.


Data which you provide us directly

There is some Personal Data which you give us directly – as an example, when you create an account you provide us with your email address, your name, or you might choose to connect your account with another, third party social media-account. We process this information on two separate grounds: The information which you provide when creating an account we process, firstly, on the basis that it is necessary Personal Data for the completion of the contract between you and us, in accordance with Article 6(1)(b). We could not provide you with the services if you did not provide us with that data. Secondly, when you volunteer Personal Data to us (either when creating an account, or when opting into certain data disclosure, such as connecting your account with a third party social media page) we consider this disclosure to imply consent. Please note that this applies primarily to the processing of Personal Data which is voluntary to disclose, and not to Personal Data which you do not provide yourself or is mandatory.


Data which you provide by use

When you use the Properties, we automatically collect data in two ways: Firstly, we use cookies. How we use cookies is detailed in our Cookie Policy, please read it for more information. Secondly, we process data on how you use and interact with the Properties. This includes what links you press, which streams you watch, what communities you interact with, the amount of time you spend on certain activities, etc. It also includes analysis on how and why you interact with our Properties, meaning for example that we correlate certain ways of presenting material with certain outcomes, and draw conclusions from what we find. This data is most valuable to us when it is in the aggregate, and we rarely look at individual, identifiable users. We process this data on the basis of our legitimate interests: This data is necessary for us to be able to improve the Properties, which serves the dual purpose of on the one hand greatly improving your experience, and on the other helping us keep and grow the userbase, which in turn provides a more lively community for you.

 

Data which you provide to other users

The Properties gives you the opportunity to communicate with other users and express yourself in a multitude of ways, such as creating or interacting with different kinds of content. It must first be said that we cannot be held accountable for how other users may or may not use the data which you express in this way, so please be careful with what information you give away. We collect and process this data to better understand user interactions and to help us understand how to better grow our communities. This processing is done on the basis of consent, which you provide when you choose to express yourself in the above described way – please note that this is not mandatory and that you are electing to share this information voluntarily.


SHARING YOUR PERSONAL DATA

We share Aggregated Data with third-party partners and service providers. This Aggregated Data does not contain Personal Data and consists of statistics relating to usage of the Properties. We do this to better understand the experience of our users, and how to improve the Properties. We believe that doing so is within our legitimate interest, as set out in Article 6(1)(f) of the GDPR – a simplification of the reasoning for this is that processing of aggregated data does very little harm to users, but is highly valuable for the development and improvement of the services we provide.

We sell certain Personal Data such as Identity, Contact, Usage, preference, and Marketing and Communications data to third-party advertisers, to personalize the advertisements you receive, and to help us monetize the Properties. Such third-party advertisers may use that Personal Data for advertisements outside the Properties. Most Personal Data shared is collected via cookies – please visit our Cookie Policy for more information. We only work with actors whom we truly believe respects the security of your personal data and who treat it in accordance with the GDPR or the relevant applicable law. We rely on your consent as a legal basis for selling or otherwise sharing your Personal Data. To the extent we believe it justifiable and reasonable (as a general practice, and in terms of what you as a user can reasonably expect) we share some data on the basis of our legitimate interests. Our legitimate interest in this context consist of wanting to provide you with relevant ads and content which is more helpful to you, as well as the necessity of monetization.


TRANSFERS TO COUNTRIES OUTSIDE THE EU AND EEA

We transfer and share your information to third parties (including service providers operating on our behalf) which are located in countries outside the European Union (“EU”) and/or the European Economic Area (“EEA”) which may not have the same level of data protection laws as those in the country where you are located. Where your data is sent to a country outside the EU/EEA that is not subject to an adequacy decision by the EU Commission, the transfers will only occur if we have implemented what we believe to be appropriate safeguards in accordance with the GDPR, such as EU Commission approved standard contractual clauses, which are deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals. We do not transfer data outside the EU/EEA unless we judge that your Personal Data enjoys equivalent protection as if in the EU/EEA.


KEEPING YOUR DATA SAFE

We implement the appropriate technical and organizational measures to ensure that your Personal Data is collected, processed and stored as securely as possible.

We have implemented various policies including such as encryption, pseudonymization, access and retention policies to guard against unauthorized access and unnecessary retention of Personal Data.

 

DATA RETENTION AND DELETION

We will not retain or keep any Personal Data for longer periods than what is necessary for the purposes outlined in this Privacy Policy. We will delete your Personal Data which we process for the performance of a contract or on the basis of consent, if you terminate your contract with us, withdraw your consent or where you request us to delete your Personal Data in accordance with this Privacy Policy. However, we may still retain information where we have a legitimate interest to use your Personal Data. For example, to resolve disputes, enforce our user agreements such as our Terms of Service, or to comply with legal requirements.


CHILDREN

The Properties are not directed to children under the age of 13. We do not knowingly collect Personal Data from children under 13 years old in the Properties or in connection therewith. If you are under 13 years, please do not use or access the Properties.

We believe it is important to safeguard the privacy of children and encourage parents to regularly monitor their children’s use of online activities. If you are a parent and believe that your child under the age of 13 has accessed and/or used the Properties and provided Personal Data to us, please contact us through the mailing address at the end of this Privacy Policy and we will work to delete that account and any such personally identifiable information.

If we learn that we have collected and processed Personal Data of a child under the age of 13 years, we will take reasonable steps to ensure the erasure of the Personal Data from our systems. This may require us to delete the child’s account to the Properties.


HOW TO CONTACT US

If you have any questions, complaints or comments regarding how we process your Personal Data or our Privacy Policy, please contact us at:

Norrtullsgatan 57

113 45 Stockholm

Sweden 

privacy@wasder.gg 

Last Updated: May 31, 2021

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