This Privacy Policy ("Privacy Policy") sets out the terms and conditions under which BIG CRUNCH DIGITAL PTE. LTD. and our subsidiary BIG CRUNCH DIGITAL (PH) PTE. LTD. (jointly and severally, “our Company”, ‘we’, ‘our’, or ‘us’) collects information when you visit our website(s) (depending on which domain you visit) located at www.wiltoplay.com and/or www.wiltoplay.ph (collectively and individually, “Website”) when you download, access and/or howsoever use our mobile game app known as “Wil To Play” (“App”), mobile games playable on Pera Perya (which  together with all patches, updates, versions and variations, related or associated applications, social media channels, forums, media, video and audio files relating to the aforegoing as well as our Website and App shall hereinafter be collectively referred to as the “Site”),  and any other services and products provided by our Company whether by itself or in conjunction with our business partners (collectively “ Site Services”).  As such, this Privacy Policy applies to any person (hereinafter referred to as “you” or “user”) who accesses, downloads, reads, participates in, or uses our Site, any of our discussion forums, the App (including any variations, updates, support patches or successors thereto), any game, any other applications, any of our Site Services and content on our Site (collectively, “Site Content”), any person who submits information to us (whether online or offline, for registration of an account, or otherwise), as well as to any person who receives our updates, promotions, contest results, game rankings, prizes, newsletters, EDMs, marketing materials, promotional updates, support patches, technical updates, support services, new version terms and conditions, releases, messages (via any channels), or other emails (collectively, "Updates").  “Site Content” and “Updates” collectively shall be referred to as “Content”, all references herein this Privacy Policy to “game(s)” refers to mobile games playable on Pera Perya, the term “media content” as used herein this Privacy Policy will include a reference to games, and references to “related entity” or “affiliate” of our Company shall mean companies who have the same parent or ultimate parent company as our Company or is constituted with the same majority shareholders of our Company.

 

In order to serve you better and provide you with the appropriate customer service or product requested for or subscribed to, we require information from you, some of which may be considered as Personal Data (defined in Clause 1.2 below).  We understand the importance of the privacy and security of your information, and we have therefore set out in detail below how we collect and use your information.  Kindly review the terms and conditions of our Privacy Policy as follows so that you may be reassured that we take data protection seriously:-

 

A. Please note that your access and use of our Website, other parts of our Site and/or App is subject to our Website’s Terms of Use (“Terms of Use”), the terms and conditions as set out herein this Privacy Policy, our App’s T&Cs, any other terms of service, rules and guidelines (individually and collectively, “Service T&Cs”) that may be applicable to your use of our Website, any other part of our Site, Site Content, App, any games, Updates and/or Site Services as may be imposed by us in our sole discretion from time to time - all such terms and conditions shall hereinafter be collectively referred to as the “Agreement”.  For the avoidance of doubt, if you use or access our App and/or play any games thereto, your use of our App is also subject to our user licence agreement (“App’s T&Cs”) which is to be read in conjunction with the provisions of this Privacy Policy.  Accordingly, by accessing our Website, App, participating in any games, contests, events, promotions, discussions or forums, or otherwise howsoever providing us with your Personal Data, you are agreeing to our collection of your information pursuant to this Privacy Policy.  Should you disagree with any clause in our Terms of Use, this Privacy Policy, App’s T&Cs, and/or any other Service T&Cs, please immediately cease your access and use of our Website and App.

 

B. In order for you to maximise the utility of our Website, Site Content and Site Services (including the App and any games), access our services, products, media content, request information from us, participate in our online or forum discussions, take-part in our contests, events, competitions, promotions (whether notified to you or made available online or offline, via the telephone, road shows or other means), receive our marketing materials, newsletters, support services, technical support for any applications, updates to our App, updates of available media content (including games), or updates regarding other information and/or promotion regarding our services, our products, our subscription plans, and other related matters (all of which constitute part of our “Updates”), your Personal Data (as defined in clause 1.2 below) has to be provided to us, and we will need to keep and use your Personal Data in order to fulfil the purpose for which you have contacted us, downloaded our App, played any games, participated in any events, accessed our Website, Updates and/or other services. 

 

For expediency and for compliance with any changes in the law, we reserve the right to amend this Privacy Policy in our sole discretion at any time without prior notice to you, and you agree that your continued access to and/or use of our App, our Website, Site, Site Services, games, discussion forums, social media channels and/or other platforms, your continued desire to view our media content, play our games, receive our Updates, keep in contact with us via email, receive prizes, and/or take-part in our forum discussions, events, contests or promotions (whether notified to you or made available online or offline, via the telephone, road shows or other channels) constitutes your unconditional acceptance of our amended Privacy Policy, the date of the latest version that is in force being indicated by the “Latest Version” date shown at the start of the Privacy Policy.  You agree that it is your sole responsibility to keep yourself updated of any amendments by reviewing this Privacy Policy at our Website regularly.


 

  1. Types of Data Collected

 

1.1 When you visit, access or use our Site, Content, Site Services, App, any of our games, social media channels, forums and/or associated platforms, request for any information, request for any prizes, register for any services, download our App and/or any games, sign-up for an account, subscribe to our services, sign-up for any events, purchase a product from our Website, sign-up for any of our Updates, email us, call us, or take part in our contests, promotions, offline or online, we collect Personal Data and Anonymised Data.  

 

  1. “Personal Data” refers to information, whether true or otherwise, that can be used singly on its own or collectively with other available (or likely to be accessible) information to identify an individual, such as name, address, NRIC number, mobile number, email address, birthdate, gender, income range, residency status, bank account details, and credit card details.

 

1.3 "Anonymised Data" refers to information that is not associated with or linked to your Personal Data and cannot be used to identify individual persons. 


 

2. Collection of Anonymised Data

 

2.1 When you access our App, our Website, any of our games, and/or email us, we collect Anonymised Data about you via the application of generally acceptable web technologies including but not limited to "web beacons", "cookies", "clear GIFs", "widgets", "online evaluations", "surveys", “HTML5”, “dynamic device identifiers”, and third-party web analytics such as "Google analytics" (collectively, “Acceptable Technologies”).  This automatic collection of non-personal information includes (without limitation) collection of your IP Address, the web browser software that you used, the type of smart phone or tablet that you may be using, the operating software/platform of your device, your sign-up(s) for any games, Updates or information via our Website and/or Site Services, your general interest as indicated by the webpages, banners or advertisements that you click on, the specific pages of our Website viewed by you, the specific categories or features in our Website accessed by you, the games downloaded by you, the sharing of any information by you via our forum(s), any third party application used in conjunction with our Website or Site Services, your downloading of our App and games, and third party websites that you may have visited prior to our Website.  Our purpose for the aforesaid collection of information is for us to understand the preference of our visitors and users so as to enhance and facilitate the ease with which you are able to access or use our Website, our Site Services, and our games that may be of interest to you.

 

2.2 As part of the Anonymised Data that we collect, when you access our Website, any other part of our Site, our App, or any of our games via your mobile device or tablet, we will also collect information regarding the type of mobile device or tablet that you are utilising so that our Website, game and/or App can provide you with the version of our Website, game and/or App best suited for access on or usage with your mobile device or tablet.

 

2.3 If you do not consent to our collection of Anonymised Data, please adjust the settings on your User Device (as defined in Clause 2.4.1) to block or disable our use of the Acceptable Technologies.  In the event that you choose to access our Website or App without blocking or disabling or opting out of the Acceptable Technologies, such access by you will constitute your consent to our use of the Acceptable Technologies and our collection of information thereto.

2.4 To better assist you in understanding the generally Accepted Technologies used in our collection of Anonymised Data:-

 

2.4.1 “IP Address” refers to a number that is automatically assigned to your computer, mobile phone, table, or other smart device (individually and collectively, “User Device”) when you access the Internet. Under certain circumstances, your IP Address remains the same from browser session to browser session.  However, in the event that a consumer Internet access provider is utilised, your IP Address will likely vary from session to session. We track IP Addresses solely in conjunction with session cookies to analyse the flow of webpages on our Website.

 

2.4.2 “Cookies” refer to small pieces of data that a website sends to your User Device’s hard drive, external or internal storage while you are viewing the said website. Our Website utilises both session cookies (they expire the moment your Internet browser is closed) and persistent cookies (they will remain in your computer and your mobile device until you actively take steps to delete them) so as to provide you with a more personalised and interactive experience on our Website. By changing the options on your Internet browser and adjusting the settings in your User Device (subject to your version of operation system and your device’s features), you can control whether to accept or decline cookies.

 

2.4.3 “Clear GIFs” refer to clear electronic images that are used to track your opening of webpages on our Website and your pattern of browsing our webpages, for the purpose of allowing us to assess the attractiveness of the content on our Website, and the flow of webpages and layouts that appeal to you.  Clear GIFs are also commonly known as "web beacons" and may be included on our Website, and generally works in conjunction with cookies to identify users and user behaviour.  Some of our HTML based emails also utilise Clear GIFs in order for us to assess what are the emails we sent that have been opened and acted upon. Clear GIFs collect only limited data, such as a cookie number, the time and date of when a particular webpage on our Website is accessed, and a description of the webpage on our Website in which the clear GIF resides. Such collected Anonymised Data helps us to determine the effectiveness of the way our webpages are arranged on our Website, our modes of communications and promotional campaigns.

 

2.4.4 "Third-party web analytics" refer to services provided by third party service providers for the assessment, analysis, measurement and reporting of the behaviour of visitors to a website in order to assess and improve the effectiveness of the website.  One of the most well-known third-party analytics service is "Google Analytics".

 

2.4.5 “HTML5 local storage” refer to caching services utilizing primarily a cache manifest file, which allows for storage of your preferences offline which will then be updated and synchronized when you go online.

 

2.4.6 “Dynamic device identifiers” refer to “identifier for advertising” (“IDFA”) and “Google Advertising ID” (“AAID”), which is a random, anonymous number assigned to an end-user of the User Device and is temporary, allowing it to be blocked like a cookie.  When an end-user views an application or browses the internet, the end-user’s presence generates a call for an advertisement as the publisher’s site that the end-user is viewing will pass the IDFA or AAID to the ad server and the advertiser is then able to serve the end-user with an advertisement relevant to the topic being viewed.  IDFA and AAID can also be used to identify whether the advertisements resulted in end-users downloading applications or purchasing products that were advertised.  The IDFA and AAID does not identify the end-user personally, it provides an aggregated audience data that advertisers can target with advertisements.  IDFA and AAID can be opted out of via the settings in the end-user’s User Device (by default, the IDFA or AAID is enabled), subject to the availability of such options in the version of your operating system and the features of your User Device.


 

3. Your Consent to our Collection, Retention and Use of Personal Data 

 

3.1 In order for our Company to provide you with our services and products, you agree and consent to our Company collecting, using and retaining your Personal Data as follows:- 

 

(i) When you sign up for our Updates, or you email or call us with any queries, you will be required to provide us with your Personal Data in order for us to add you to our mailing list, or to revert to your queries.  

 

(ii) When you sign up for any Updates, register for any accounts (whether in relation to Pera Perya or any associated discussion forum), subscribe to our services, sign up to use and/or download our App, any of our games, upload any posts or participate in chats on our forum(s), purchase any credits, participate in any testing of our App or any game, enroll for any membership or loyalty programme, utilise any of our platforms, enter into a subscription plan, or participate in contests and/or promotions (offline and online) that we (or our other business partners) provide, we will require your Personal Data in order to keep a record of and provide you with the benefits that accompany your registration, subscription plan, credit purchase, user account log, user status, participation in contests, events,  membership programme and/or promotional campaigns (whether online or offline).  Unless you terminate your user account, cancel your access to our App and all games, cancel your credits, terminate your subscription plan, cancel your participation in and cease all use of our forum(s), withdraw from our contests, events, membership programme or promotional campaigns or our relevant promotional campaign ends, we will keep your Personal Data for as long as you are still a user of any of our App, holder of credits, a participant of a subscription plan, our membership programme and/or promotional campaigns (whichever is the later) so that we can provide you with the relevant benefits.  Accordingly, we will retain your Personal Data for as long as we are of the reasonable opinion that you may still be interested in our App or any of our games (and/or any related content thereto), products and/or services so that our Company can be expeditious in the provision of our services or products whenever you should seek a subscription to our services, a delivery of any of our products or our assistance.

 

(iii) When you click on any of our Company’s Google ads or other internet based advertisements for more information regarding our App or any game, available media content, services or Website, we collect the Personal Data that you provide in order to follow up with you pertaining to your interest in our App, game(s), media content, products, services and/or our Website. 

 

  1. In addition, we will retain your Personal Data where necessary and for such duration as may be required in order for our Company to comply with applicable laws and regulations, assist in any legal investigations, meet the demands from any regulatory or law enforcement bodies, for utilization in legal proceedings, minimizing fraud, collection of debts, repayment of loans, resolving disputes, identifying issues, enforcing contractual breaches and/or claiming for damages.


 

4. Disclosure of Personal Data 

 

4.1 We may need to disclose your Personal Data to:-

 

  1. third party service providers in order for us to facilitate your access to and use of our Website, our App, our games, download media content, participate in our promotions and contests, receive contest results, receive notices on eligibility for prizes, for us to contact you as you may have requested via our Website, App, email or telephone, for us to maintain and update your records to ensure that you receive our replies to your queries, for us to follow up on any delivery of prizes that you have won or products or services that you may have requested for, and to provide you with any other updates and perks accompanying your registration to use our App  (including without limitation technical support, patches, updates, new releases and versions), games, credit purchase, participation in our subscription plan, membership programme, contests, campaigns and/or promotional campaigns.  The aforesaid third party service providers have a contract with us to perform the services necessary for you to use our Website, our App, games, participate in our contests and/or promotions, receive Updates and/or our services or products that you might have ordered, and such third party service providers therefore include but are not limited to event organizers, event management companies, cloud solutions providers, payment gateways, platform maintenance providers, game hosts, game developers, game licensors, credit bureaus, payment solutions companies, credit card associations, financial institutions, telecommunications services providers, webhost companies, website maintenance companies, database storage companies, membership programme service providers, app stores, app maintenance providers, companies that assist to perform mass mailing on our behalf, courier and logistics companies, etc.;

 

  1. our third party business partners such as media content (including without limitation games) providers, online forum hosts, online bulletin board platforms, telecommunications companies, and/or payment solutions providers in order to facilitate your usage of our App, games, payment for media content, subscription fee payment, invoicing, and internet access in order for you to download media content (including games) and/or share your views via our Site; 

 

  1. our book-keepers, accounting firms, audit firms, law firms and/or other professional advisory firms who are maintaining our records in accordance with legal requirements;

 

  1. governmental, regulatory or law enforcement bodies who have a legal right to demand for your Personal Data; 

 

  1. credit bureaus, credit rating agencies and fraud preventing companies for the purpose of minimizing fraudulent activities via your Personal Data; and

 

  1. our affiliated or related entities and/or third parties to whom we may sell, divest, transfer, assign, share or otherwise engage in a transaction that involves, some or all of our Company’s assets (which may include your Personal Data), in the course of a corporate divestiture, corporate restructuring, merger, acquisition, joint venture, bankruptcy, dissolution, reorganisation, or any other similar transaction or proceeding.

 

Except as provided above, we do not sell, rent, licence or otherwise disclose your Personal Data to third parties or our affiliated companies.  We are careful in our selection of third party service providers, and all such third party service providers as well as our abovementioned affiliated companies are bound by obligations of data protection (pursuant to contracts and/or applicable laws) similar to the obligations herein this Privacy Policy.  In general, the third party service providers engaged by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.


 

5. Transferring Personal Data out of Singapore

 

5.1 Pursuant to the purposes and activities as set out in sections 3 and 4 above, it may be necessary for us to transfer your Personal Data out of Singapore and/or your country of domicile.  You hereby agree and consent to the aforesaid transfer, on the understanding that the recipients of such Personal Data are also subject to applicable laws or contractual obligations similar to the obligations as set out in the Personal Data Protection Act 2012 (and any other data protection laws that may be applicable).


 

6. Accurate and Complete Personal Data 

 

6.1 In order for us to provide you with access to our Website, our App, games, media content, and all their respective associated functions, our Content, our events, our contests, our promotions, our services and our products, and to perform the activities as set out in sections 3, 4 and 5 above, you warrant that the Personal Data that you provide to us is accurate, and that all Personal Data as may be relevant for that particular purpose/circumstance has been provided.  In the event of any changes or updates to your Personal Data, you undertake to promptly inform us in writing of such changes, failing which we shall not be responsible for any consequences thereto (including but not limited to your non-receipt of communications sent by us, your inability to access our App, and of our games, drop in game rankings, and/or non-delivery of any prizes that you may become eligible to receive).


 

7. Do-Not-Call ("DNC") Provisions and Registries

 

7.1 We respect your selections in relation to the channels via which you wish to receive our Updates.  Therefore, if you have registered your telephone and/or fax number with the Do-Not-Call Registry in your country of domicile in relation to telephone calls, text or fax messages, we will not send you any Updates via the channels that you have opted out of by registering with the Do-Not-Call Registry in your country of domicile.  However, if you have previously consented to our sending you Updates via your telephone number (calls or text messages) and/or facsimile number, we will continue doing so until you withdraw your consent by contacting our Data Protection Officer at [insert email address].


 

8. Withdrawal of Consent

 

8.1 You may at any time withdraw your consent to our use, retention, disclosure or transfer of your Personal Data pursuant to this Privacy Policy by emailing our Data Protection Officer at [insert email address].  However, please note that any such withdrawal of consent may result in us being unable to continue providing our services or fulfilling our contractual obligations with you, including but not limited to termination of your access to our Website, App, games, contests, events, and other Site Services, cancellation of any user account, subscription plan, purchased credits, prize eligibility, and thereby all deliverables that would have been provided thereunder, termination of membership programme benefits that would otherwise have been available to you, cessation of your access to our App, games, contests, events, promotions, and all media content as well as other features thereto, inability to provide you with the opportunity to participate in promotions, contests and events, inability to fulfil any request for information that you may have submitted to our Company, inability to fulfill any purchase orders, inability to deliver any prizes that you may become eligible for, and potential inability of third parties to provide you with their services or products that you might have contracted with them for through our Website, other parts of our Site, App, games, contests, forums or other platforms, regardless of whether you have made payment for such subscriptions, services or products.  Accordingly, your withdrawal of consent may also lead to the termination of any contract(s) that you may have with our Company, as well as termination of any contracts with any third parties engaged through our Website, App, games, contests, forums or other platforms for which our Company expressly reserves its rights and remedies thereto.  Our Data Protection Officer will further advise you on the legal consequences that may ensue should you contact him to withdraw your consent.

 

8.2 Should you wish to unsubscribe to our email updates, please click the "unsubscribe" option made available in our emails to you.  Please note however that this may result in our being unable to make available to you updates on our products and services, contest results, prizes that you may become eligible for, latest games available, your benefits under our membership programme or subscription plans, and any ongoing promotions.

 

8.3 Should you wish to unsubscribe to any of our applications (including but not limited to the App “Wil To Play”), please utilise the “unsubscribe” or “termination” option that may be available on the application itself.  If such option is not available, kindly email us at support@wiltoplay.com.


 

9. Access and Correction of Personal Data 

 

9.1 Should you wish to access, update or make corrections to your Personal Data held with us, or if you wish to receive further clarifications on your Personal Data held with us, please email our Data Protection Officer at [insert email address].

 

9.2 There will be no administrative fees or other charges levied for any request to correct or update your Personal Data.  However, for all other requests such as accessing your Personal Data held with us, obtaining a record of when you accessed our Website, App, any game, contests, promotions, events, and/or discussion forums, the date of your prior requests for information, etc., a reasonable administrative fee may be levied depending on your request as time and resources will be spent in accommodating your requests.

 

9.3 Should you have any queries or complaints pertaining to this Privacy Policy,  our Terms of Use, our App’s T&Cs, any other Service T&Cs, your Personal Data as registered with us, or in relation to our Company’s use, retention, disclosure or transfer of your Personal Data, or should you desire to learn more about our data protection policies and security measures, please email our Data Protection Officer at [insert email address].

 

9.4 In the event that you are a citizen or resident of the European Union, please refer to section 14 “Citizens of and Residents in Members of the European Union” below for more information.


 

10. Minors

 

10.1 Our Website, our App, our games, our contests, our games, our events, our forums, our Updates, our services and products are not meant for persons who may be defined as minors under applicable law.  As such, if you are below 18, please terminate all transactions attempted via our Site immediately.  We reserve the right (but not the obligation) to demand at any time evidence for our review to verify that you are above 18 years of age.  In the event that you are under 18 years of age, or we reasonably suspect that you are under 18 years of age and you are unable to prove otherwise, at our option in our sole discretion; (i) all your purchase transactions, account registrations, subscription plans, contest involvement, promotions’ participations, purchased credits, and all other registrations with us (if any) may be immediately terminated without any liability on our part and no refunds of any kind shall be provided to you; or (ii) hold your parent (or legal guardian, as the case may be) fully liable for and enforce against your parent (or legal guardian, as the case may be) all transactions (including without limitation all payments due thereto) performed by you . 

 

10.2 We do not knowingly collect Personal Data from minors, however, through the internet, we are not able to ascertain on our end whether such individuals are minors.  It is thus the responsibility of parents or guardians to monitor and ensure that their minors do not access or perform any transactions on our Website, download or access our App or any of our games, participate in events, contests, competitions or forums, register an account with us, email us, or provide us with Personal Data without their parental/guardian's consent, failing which the parent or guardian shall be responsible as per Clause 10.1 above.  If a parent or guardian becomes aware that his or her minor has accessed our Website, App, any of our games, contests, events, forums or promotions, or provided us with Personal Data without his/her consent, he or she should contact our Data Protection Officer at [insert email address] promptly. If we become aware that a minor under 18 has provided us with Personal Data without their parent or guardian's consent, we may, without prejudice to our rights thereunder Clause 10.1 above, in our sole discretion delete such information from our records without any liability or reference to such minor and/or his/her parent/guardian.


 

11. Security Measures for Protection of Personal Data 

 

11.1 We ensure that our Website, Site, App, games, contests and forums are protected by reasonable security measures afforded by current technology, and that all our data hosts and servers are similarly protected by such security measures, including but not limited to firewalls.

 

11.2 Your Personal Data is kept securely and protected against unauthorized access and disclosure.  We utilise security means such as (without limitation) password protection, encryption, locked and restricted access.  We have strict policies in place restricting access to Personal Data to only our authorized personnel on a need-to-know basis.

 

11.3 We will take practical steps to ensure that your Personal Data will not be kept longer than as set out herein this Privacy Policy, or for as long as is necessary for fulfilling the purposes for which you have entrusted us with your Personal Data, or as may be required for legitimate business or legal purposes, whichever is the latest.


 

12. Third Party Sites, and Social Network Sites 

 

12.1 Our Website, App, Site, Site Services, Content, games, events, contests, Updates, emails and other promotional messages may contain hyperlinks to websites, portals or platforms operated by third parties.  However, such third party websites, portals or platforms are not governed by our Privacy Policy or Terms of Use. We are not responsible for the privacy policies or data security of such third party websites, portals or platforms even if they are co-branded with our Company name or logo, or our Website, Site, App, any games, events, contests, forums or promotional messages display products or services that originate from such third parties.  As such, we urge you to learn about the privacy policies of these third party websites, portals or platforms before accessing or using them, and to be careful about providing any Personal Data to such third party websites, portals or platforms.  We seek your understanding that we are not liable for any acts or omissions or any loss or damage that you may suffer due to your use or access of such third party websites, portals or platforms.

 

12.2 Our Company may utilise reputable social media/network sites such as, but not limited to Facebook, Twitter, Instagram, Pinterest and LinkedIn (collectively the "Social Media Sites") so as to connect to your social networks.  In order to generate interest in our Website, Site and App, games, contests, events, products and services amongst the contacts in your social networks, and to allow you to share your interest in our Website, Site, App, Site Services, Content, games, contests, events, media content list, and/or our products and services, we may provide access to our Website, Site, App, games, forums, contests and/or promotions to the third party Social Media Sites, and there may be links on our Website, Site, App, games and forums to such Social Media Sites. The aforesaid association with the Social Media Sites does not constitute any endorsement or recommendation of any of the Social Media Sites by our Company nor vice versa. As per clause 12.1 above, kindly review the terms of use and privacy policies of the Social Media Sites before you use or access such Social Media Sites in conjunction with our Website, Site, App, Site Services, Updates, Content, games, forums, events, contests, or any of our promotions and our products or services made available via any Social Media Sites.

 

12.3 The association of our Website, Site, App, Site Services, Content, games, contests, events, promotions and Updates with the Social Media Sites makes available certain features which when used by you, may result in information being made available from your accounts with the Social Media Sites to our Company.  Such information which we collect about you shall constitute public information that is available in the general domain because such information was made publicly available by the Social Media Sites.  Should you prefer that we do not collect your information from the Social Media Sites, please; (i) do not use the features or links that associates our Website, Site, Site Services, Content, Updates, games, events, contents, promotions, forums, and/or App with the Social Media Sites; and (ii) adjust the settings in your accounts with the Social Media Sites to prevent the sharing of your information with our Website and applications (including the App and games).  Please note that our Company cannot control nor is our Company howsoever responsible for the sharing of your information by the Social Media Sites with third parties.

 

12.4 One of the features which you may see available on our Website, Site, Site Services, Content, Updates, games, and/or App in association with the Social Media Sites, is the “like” feature by Facebook, and other similar functions provided by other Social Media Sites. When you “like” our Website, Site, App, Site Services, Content, Updates, games, forums, contests, events, any of our products or services, information about our Website, Site, Site Services, Content, Updates, games, forums, contests, events, or App, our products and services will be made known to your network within your Social Media Sites’ accounts via a variety of methods employed by the relevant Social Media Site. Your information may also be made known alongside with our promotions, products or services that you have liked pursuant to the methods/channels made available by Social Media Sites in relation to such features.  If you are not agreeable to the aforegoing, please instruct the relevant Social Media Site or adjust your account settings with the Social Media Site.  Please note however that we are not obliged to display on our Website or any other parts of our Site including without limitation forums, bulletin boards, or any related webpages (whether on Social Media Sites or otherwise) any of your information, including but not limited to your photo or name, even if you “like” our Website, Site, our App, any of our games, contests, events, promotions, our products or services. In the event that any of your information, product or service endorsements (including your liking of our Website, our Site, our App, any of our Company’s products or services, or third party products or services featured on our Website or App) appear on our Site or any related webpages (whether on Social Media Sites or otherwise), we shall have the right in our sole discretion to remove such information or product/service endorsements from our Site or any related webpages.


 

13. Governing Law and Jurisdiction 

 

13.1 The terms and conditions of this Privacy Policy are governed by the laws of Singapore. In the event of any disputes arising from this Privacy Policy and your use of our Website, Site, Site Services, Content, Updates, our App, and/or any of our games, contests, events, promotions, or forums, you must first contact our Data Protection Officer at [insert email address] regarding your concern and use your best endeavours to amicably settle any dispute in good faith.  We on our part will also use our best endeavours to amicably settle your concerns in good faith. However, if no amicable resolution is reached within 30 days, you agree to submit to the exclusive jurisdiction of the Courts of Singapore.


If you have any questions regarding this Privacy Policy or your Personal Data, please contact our Data Protection Officer at [insert email address].


 

14. Citizens of and Residents in Members of the European Union

 

14.1 This Section 14 of the Privacy Policy is applicable only if you are a citizen of, or resident in, any members of the European Union.  The clauses hereunder this Section 14 supplements the above provisions of this Privacy Policy which will still apply to you. 

 

14.2 Our collection, use, processing and retention of Personal Data is as described above.  Our legal basis for processing of Personal Data is dependent on the context in which the Personal Data was collected, which will therefore also determine the type of Personal Data collected.  Nonetheless, collection and processing of Personal Data is usually only performed where it is necessary for us to provide our Site, App, games, technical updates, patches, latest versions, media content, products, or services to you, and for us to comply with applicable legal requirements (as further described in Sections 3, 4 and 5 above), where necessary for our legitimate business or legal interests that are not superseded by your rights, and/or where you have consented.

 

14.3 In the event that your Personal Data has been collected based on our (or a relevant third party’s) legitimate interests, the said legitimate interest is generally for the operation of our Company and the provision of our services, managing our relationship with you such as updating your subscription status, account status, payment status, purchase status, game ranking, prize eligibility status, contest results, or event results, communicating with you in order to deliver your requested service, purchased products, and facilitate participation at any enrolled promotions, events, contests, games, forums, updates to our Site, Site Services, games, offers, and other legitimate business interest such as replying to your requests, sending you Updates, maintaining your registered account and/or subscription plan, notifying you on your game ranking, liaising with you on prize eligibility, communicating with you on effected (or attempted) transaction for product purchase, promotion or event enrolment, managing your media content (including game) downloads, developing our Site, our Site Services, our products, events, and our services, offering promotions, publicity, patches, technical or security enhancements, crime prevention and fraud detection.  Should we have other legitimate interests, we will where appropriate notify you of them clearly at the relevant time.  

 

14.4 In the event that you are requested to provide your Personal Data in order to enter into a contract with us, or for compliance with a legal obligation, we will make it clear to you at the appropriate juncture and advise you accordingly as to whether the provision of your Personal Data is indispensable, together with the possible consequences that may ensue should you still choose not to provide your Personal Data under the circumstances.  To illustrate, in the event that you have subscribed to a plan for downloading and accessing our games via our App, in order for you to receive benefits such as discounts for your purchase of certain in-game items, access to special in-game features, credits, products, updates on new subscription plans (and their discounts thereto), and fully benefit from and utilize our services, products, App, available media content (including games), contests, promotions, and other events, your Personal Data would have to be provided to us and processed as per the above provisions of this Privacy Policy.

 

14.5 Your Personal Data will be retained and processed securely for as long as there is still ongoing legitimate commercial and/or legal need for such retention and processing.  Examples of legitimate commercial and legal needs would be to allow you to continue accessing our Website, downloading our games, accessing media content (including games) via our App, subscribing for access packages, participating in promotions or events via our Site, maintenance of your account, providing Updates, technical support, patches, and other services to you, investigating and defending any potential legal action or claim against us, and as may be required or permitted by applicable laws (including laws pertaining to taxation and keeping of accounting records).  As soon as there is no more legitimate business or legal needs for us to retain and process your Personal Data, your Personal Data will be deleted or anonymised (where possible), and in the event that it is not possible (such as storage of Personal Data in backup archives), we will ensure the security of your Personal Data that is being stored, segregate it so that no further processing will be carried out using your Personal Data, and will delete your Personal Data once possible. 

 

14.6 As we are a business based in Singapore, your Personal Data will be transferred to countries that are not members of the European Union, including countries such as Singapore and/or the Philippines which may not mandate the same obligations of data protection as the European Union.  Nonetheless, please be assured that we adopt appropriate measures to ensure that recipients (as described in Sections 4 and 5 above) of your Personal Data are bound to obligations of protection, security and confidentiality similar to the obligations hereunder this Privacy Policy, including but not limited to the use of contractual clauses in our contracts/terms and conditions with such recipients.  

 

14.7 As a citizen of, or resident in, any members of the European Union, you can exercise your following data protection rights at any time by contacting us via the details provided in Clause 14.8:- 

 

  • You have the right to request access to, correction of, updating or deleting of your Personal Data held with us;

  • You have the right to object to processing of your Personal Data based on our legitimate interests, and also the separate right to object to direct marketing activities and communications from us;

  • You have the right to request that in certain situations, to restrict processing of your Personal Data;

  • You have the right to request for your Personal Data in electronic format for portability; 

  • You are entitled at any time to opt-out of marketing communications. Please opt out by clicking on the “opt-out” or “unsubscribe” hyperlink in the marketing e-mails that you may receive.  To opt-out of other forms of marketing (such as letters via post, SMSes, Whatsapp, or telemarketing), please notify us using the contact details as set out in Clause 14.8.

  • You are entitled to withdraw your consent to our collection and processing of your Personal Data at any time.  However, there may be consequences (such as your inability to receive your purchased product, subscribed services, technical support, patches, Updates that you may have requested or paid for) arising from such withdrawal which we will inform you at the appropriate juncture.  For the avoidance of doubt, your withdrawal of consent will not render our prior processing of your Personal Data unlawful, nor will your consent withdrawal impede the processing of your Personal Data performed based on lawful processing grounds other than consent.

  • You may at any time submit a complain to a data protection regulatory authority about our collection and use of your Personal Data. Please check with your local data protection regulatory authority for more details in submitting such complaints.

  • We will respond to all requests we receive pertaining to the exercise of an individual’s data protection rights in accordance with applicable data protection laws.

In the event that you become aware of changes or inaccuracies in your Personal Data, please notify us promptly for the updating and correction of our records. 

 

14.8 Should you have any queries, concerns or requests pertaining to the legal basis pursuant to which we collect, use and process your Personal Data, your Personal Data held with us, this Privacy Policy or any other matters related to your privacy associated with our Company and our services, please contact our Data Protection Officer at privacy@wiltoplay.com.

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