Data Protection / Privacy Policy

The purpose of this document is to provide customers and users with information on the data processing principles and practices of the website and the game at www.willwe.hu in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council ("General Data Protection Regulation" or “GDPR”), Act CXII of 2011 on the Right of Informational Self-determination and the Freedom of Information (“Information Act”) and Act V of 2013 on the Civil Code (“CC.”).

Definitions

Data processing: any operation performed on the data, irrespective of the procedure applied, e.g. collecting, recording, registering, classifying, storing, modifying, using, querying, transferring, disclosing, synchronizing or connecting, blocking, erasing and destructing data, as well as preventing the further use of the data, taking photos, making audio or visual recordings, as well as recording physical characteristics suitable for personal identification (fingerprints or palm prints, DNA samples, iris scan etc.).

Controller: the natural or legal person, or organization without legal personality, who/which determines the purpose and the means of data processing, makes and executes decisions concerning data processing (including the means used) or have those executed by a data processor.

Data processor: the natural or legal person, or organization without legal personality, who/which processes the data based on contract signed with the controller, including contracts concluded pursuant to legal regulations.

Cookies: short data files that are placed by the visited website on the user's computer or other device that allows using the service. The purpose of a cookie is to make the use of a given Internet service easier or more convenient. A session cookie is a cookie that is placed by the website on the user`s device only during a specific session (e.g. during the security authentication of an Internet banking session), while a persistent cookie (e.g. the language setting of a website) remains on the computer until the user deletes it or it expires. The use of cookies may be restricted by setting the browser and installed cookies may be uninstalled.

User or Customer: the natural or legal person, or organization without legal personality who/which orders the willwe game, including anyone who uses the services of the Website, and/or registers and provides his/her personal information on the Website.

Website services: the text, picture, video and audio content publicly available on the www.willwe.hu website with or without registration.

Game: the willwe game application available for download from Google Play or Apple App Store.

Player: the natural person who is a participant in the Game.

Special personal data: personal data revealing racial origin, nationality, political opinions or political party affiliation, religious or philosophical beliefs, trade-union membership, sexual life, health, pathological addictions and criminal record.

External provider: any provider independent from the controller that provides additional functions through services embedded in the website.

Personal data: data relating to any specific, identified or identifiable natural person, as well as conclusions drawn from the data regarding the data subject, such as for example: name, e-mail address, address information, the IP address of used devices, etc.

Policy: the present Privacy Policy.

Willwe:

I. Website services

Name of the Controller

Regarding the Website service, the Controller is Willwe Play Kft. (8313 Balatongyörök, Felső út 80.). Responsibility for data processing shall be borne by Adrienn Barczy, the managing director of the company. During the processing of personal data, the Controller shall not use external data processors.

Scope of personal data

Willwe processes the following personal data during registration:

name
e-mail address
mobile phone number
profile picture

Data processing is preconditioned on the User or the Customer having read and declared by checking the box that he/she understood and accepted the contents of this Policy.

Notwithstanding the above, providers technically connected to the operation of the Website services may carry out data processing activities on the Website without informing the Controller. Such an activity shall not constitute data processing by the Controller. The Controller will use its best endeavors to screen and prevent such data processing.

The Website does not collect, store or process data qualifying as Special personal data.

Technical data

Data technically recorded during the operation of the systems: the data of the computer or other device used to access the Internet, which are generated during the use of the Website and which are recorded by the system as the automatic result of technical processes. The automatically recorded data are automatically logged by the system during login or logout.

Purpose of data processing

Willwe processes the data in order to provide the following services:

online content services,

preparation of statistics and analyzes,

protecting the rights of the Users,

enforcing the legitimate interests of the Controller.

Legal basis of data processing

The legal basis of processing the data of the User and the Customer shall in all cases be express consent to the processing of data given following the receipt of information. The User and the Customer may revoke his/her consent at any time and request the erasure of his/her data. In this case, the services tied to the provision of data will not be available to him/her subsequently.

Duration of data processing

Willwe processes the data until

the services for which the User or the Customer has provided the data are available, or

the User or the Customer revokes his/her consent.

Method of data processing

The Controller chooses the devices, services and providers used for service provision by ensuring the highest security level possible for the data. Willwe continuously monitors such devices, services and providers and carries out the necessary maintenance and updates to ensure that security is maintained at all times. Willwe uses such organizational and technical procedures that make sure that the processed personal data are only accessible by authorized persons.

The data may not be transferred to or made accessible by third parties, except in cases specified by law.

An exception to the above rule is granted to the use of data in a statistically combined form, which may not contain in any form data suitable for identification, and therefore does not constitute data processing or data transfer.

The User and the Customer are responsible for the authenticity and accuracy of the provided data.

Personal data may only be used for the purpose they were originally provided for. They may only be used for other purposes with the express consent of the User or the Customer.

External providers

Web analytics and ad serving external providers

Google Analytics

Hosting provider

XP Systems Kft.

Other external providers

YouTube

Please note that Willwe is not familiar with the content of data transferred by external providers and how they are used by XP Systems Kft., Google and YouTube. For further information, please see the Privacy Policies of XP Systems Kft., YouTube and Google.

Cookies

In connection with the use of the Website services, small data blocks, so-called "cookies" are placed on the computer or other devices used for accessing the Internet. Cookies are used to ensure the high quality, customizability and development of the service. Cookies are placed subject to the User's permission. By refusing to grant permission, the User acknowledges that the available service will not be of full value.

Cookies are small data files that the website places on the user’s computer or other Internet-enabled device using the site. These files handle e.g. login information, improve website functions, provide customization services and can measure the effectiveness of online advertising connected to the site. Cookies are suitable for analyzing the customs of the users of the site, thereby improving the quality of the site.

Session cookie

Session cookies are essential for navigating the website, operating the key functions of the website and for accessing content that is only available after identification. These cookies store the information necessary to complete the forms and occasionally the language selected by the user. They do not collect information suitable for identifying the user, or usable for marketing purposes, or that record other websites visited by the user. After closing the website, these cookies are automatically deleted and the session is terminated.

Statistical cookie

The website uses Google Inc.’s („Google”) Google Analytics for analyzing its site traffic. Google Analytics places cookies on the user's IT device and uses them to analyze the traffic of the website, thereby helping the development of the website in order to enhance user experience and improve the site's functionality.

The data relevant to website hits that are recorded in the cookie (including the time of the visit and the IP address of the device) are transferred to and stored on Google's servers in the USA and Ireland. Google uses this information to evaluate the website visit habits of the user, to prepare reports thereon for the controller and to provide other services relating to the use of the website and the Internet.

Users who do not wish Google Analytics to report on their visits can install the Google Chrome Analytics opt-out browser extension. This extension instructs the scripts of Google Analytics JavaScript (ga.js, analytics.js, and dc.js) not to send visit information to Google. Moreover, users who have installed the opt-out browser extension will not participate in content experiments.

Users who wish to disable Analytics’ web activity can install the out-out extension for their browser by visiting the Google Analytics out-out page (http://tools.google.com/dlpage/gaoptout). For more information on installing and uninstalling the extension, please see the help menu point of the browser in question.

Marketing cookie

Marketing cookies can track the movement of visitors on the website and between websites. They help advertisers and visitors to display the ads that are the most valuable for them relative to the website. To do this, they can collect information related to the devices used by the users, their geographical location and other pages visited.

Third-party cookie

Occasionally the website displays contents by using external web services, which may result in storing cookies that are not monitored by the controller, thus the controller has no control over the data that these websites or external domains collect regarding the user’s use of such embedded contents.

The following third-party cookies may be stored on the user's computer:

XP Systems Kft.

Google Analytics

YouTube.com

DoubleClick

Rights and obligations related to data

The User and the Client may, at any time, request information on his/her personal data processed.

The User and the Client are entitled to have his/her processed personal data rectified or modified.

The User and the Customer may request the erasure of his/her personal data processed, the restriction of the personal data, or object to the processing of his/her personal data, if he/she feels that his/her personal data are being processed without authorization.

The User and the Customer may, at any time, revoke his/her consent to the processing of personal data, this however, does not render the processing of data prior to the revocation unlawful.

If the revocation of the consent is accompanied by a request to erase personal data, then access to the services subject to the provision of data will also be terminated.

Questions regarding data processing can be sent to the [email protected] e-mail address.

II. Privacy provisions relevant to the Game

Name of the Controller

In terms of the Game, the Controller is the Customer ordering the Game. During the Game, full responsibility towards the Players for complying with the rules on data processing shall be borne by the Customer. In regard to the Game, Willwe Kft. cooperates as a data processor.

Scope of personal data

During the Game, the Controller processes the following personal data:

name
e-mail address
mobile phone number
profile picture

Playing the Game is preconditioned on the Player having read and declared by checking the box that he/she understood and accepted the contents of this Policy.

The Game does not collect, store or process any data that qualify as special personal data.

The data provided by the Players during the use of the Game and the data generated during the Game are available to the Customer organizing the given Game in the willwe application.

Purpose of data processing

During the game, the Controller processes the data for the following purposes:

organization and implementation of the Game,

preparation of statistics and analyzes,

billing, book-keeping, collection of claims,

enforcing the legitimate interests of the Controller.

Legal basis of data processing

The legal basis of the processing of the Players’ data shall in all cases be express consent to the data processing given following the receipt of information. The Player may revoke his/her consent at any time and request the erasure of his/her data. In this case, services tied to the provision of data will not be available to him/her subsequently.

Duration of data processing

The data are processed by the Controller until

the services for which the Player has provided the data are available,

it is necessary for the enforcement of his/her legitimate interests, or

the User or the Customer revokes his/her consent.

Method of data processing

The devices, services and providers used during the Game ensure the highest security level possible for the data. The Game uses such organizational and technical procedures that make sure that the processed personal data are only accessible by authorized persons.

Data provided by the Players during the Game are accessible by other players participating in the Game and the Customer organizing the Game. The Customer and the Players acknowledge that in case of a Player or Customer outside of the European Union, the data within the European Union may leave the territory of the European Union.

Data generated during the Game may not be transferred to or made accessible by third parties, except to other players participating in the Game and the Customer organizing the Game, as well as in cases specified by law.

The Player is responsible for the authenticity and accuracy of the data provided during the Game.

Personal data may only be used for the purpose they were originally provided for. They may only be used for other purposes with the express consent of the Player.

External Providers

Rights and obligations related to data

The Player may, at any time, request information from the Controller on his/her personal data processed.

The Player is entitled to have his/her processed personal data rectified or modified.

The Player may request the Controller to erase his/her personal data processed, the restriction of the personal data, or may object to the processing of his/her personal data, if he/she feels that his/her data are being processed without authorization.

The Player may, at any time, revoke his/her consent to the processing of personal data, this however, does not render the processing of data prior to the revocation unlawful.

If the revocation of the consent is accompanied by a request to erase personal data, then access to the services subject to the provision of data will also be terminated.

Questions regarding data processing can be sent to the e-mail address of the Controller.

Common final provisions

Complaints concerning data processing may also be made directly at the Hungarian National Authority for Data Protection and Freedom of Information (address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c.; phone: +361 391 1400; e-mail: [email protected]; website: www.naih.hu ).

In the event of a violation of his/her rights, the User, the Customer or the Player may seek judicial remedy. The regional court has jurisdiction to hear the case. The action may, at the option of the data subject, be brought before the regional court having jurisdiction for the permanent or temporary residence of the data subject.

This Policy is subject to change due to changes in legal regulations or the services of the website. The version in force from time to time can be found at willwe.com.

Policy updated: July, 2022