Last updated: November 28, 2023
What Personal Data do we collect and how do we process it?
Personal Data is information that can be used to identify you as an individual or allow someone to contact you, as well as information attributed with such information. We collect different categories of Personal Data, including User-Provided Information and Site Usage Information. We are also able to read on-chain data and prepare a profile page for you displaying the on-chain data, which you may claim. You may also connect your wallet/s on our website or with any Services. We may also collect Personal Data from social networking and blogging.
We collect Personal Data such as:
Identity Data. This may include your full name, (where applicable) your user name, title and date of birth.
Contact Data. This may include your email address, delivery address, home address.
Financial Data. This may include your bank account and card payment details.
Profile Data. If you decide to create a profile when using services of ours where this is recommended, we may ask you to provide Personal Data, information about your interests, career and work interests, location, hobbies, and similar.
Service Usage Data. If you decide to use our services, we may collect information about how you used them, and responses and requests given as part of projects.
Marketing, communications data, and social media data. If you choose to sign up for marketing communications from us and any collaboration partners of ours, for example through our newsletter, we collect your data to be able to communicate directly with you and record your preferences.
Social Media Data. This includes your social media profile handles and information obtained from your social media profiles and/or personal/ group's websites. If you decide to create a user profile on our Service, you may choose to display your handle for the following social media platforms: Discord, Twitter, Instagram, LinkedIn.
Transaction data. This includes details about your payments to and from you.
Technical data. This includes IP addresses from which we may determine your location, your login data, browser type and version, time zone setting and location, language settings and other technologies on the devices you use to access the website.
Event Data. If you participate in an event organised by us, we may photograp and film the event. Such footage may be used for promotional purposes, marketing, publicity, and on social media platforms. By attending our events, we will ask you to consent to the use of your image by WoW.
We will endeavour to keep Personal Data we store about the Data Subject reasonably accurate and up to date by enabling Data Subjects to correct it by themselves or contact us to request a correction, or any other action to their personal data that they have the legal right to take (see below for additional detail on these rights). In such Services that we provide where you have created an account, you may yourself at any time update or remove your data. In situations where you would like to contact us, you may do so by contacting us using the details set out below.
What is the purpose of collecting Personal Data?
We will use the Personal Data held about the Data Subject for the following purposes:
- To fulfil a contract, or take steps linked to a contract: this is relevant where you make a purchase from us or sign up to our Services. This includes:
- verifying your identify and taking payments from you if you purchase anything on our Services; and
- communicating with you, including providing customer services in relation to any purchases.
- As required by WoW to conduct our business and pursue our legitimate interests, in particular:
- enabling you to use our Site, Services and all its applicable features;
- developing new features, offerings and personalising our Site and Services for you;
- administering our Services and any account you may create with us;
- responding to your requests, questions and concerns;
- undertaking market research to promote a better understanding of our audience; and
- protecting our rights and property including intellectual property.
- Where you give us consent:
- we will send you direct marketing in relation to our Services;
- we place cookies and use similar technologies; and
- on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
- For purposes which are required by law
- where we are required to hold or collect Personal Data to meet legal requirements on us;
- where we need parental consent to provide Services to children under 13. [We note that most of our Services are not designed for children under 13]; and
- where in response to requests by government or law enforcement authorities conducting an investigation.
We will only process Personal Data under the lawful bases set out above.
There are instances where we have a legitimate interest to use your Data. Our legitimate interest will vary depending on what we are using your Personal Data for. Where we process Personal Data on the basis of a legitimate interest, then - as required by data protection law - we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals' interests outweigh our interests in the processing taking place.
We do not anticipate that WoW will make any decisions with respect to Data Subjects' Personal Data using fully automated means. We will notify you in writing if this position changes.
Personal Data Retention
We will endeavor not to keep Personal Data in a form that allows a Data Subject to be identified, unless this is the purpose of providing the data for example to create an account and associated profile in a Service provided by us, for any longer than is reasonably necessary for achieving the permitted purposes or until you ask us to stop processing your Personal Data. At the end of the applicable retention period, we may destroy, erase from our systems, or anonymize Personal Data as part of such efforts. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Storage & Transfer of Personal Data
Information will be shared with third party service providers, who will process it on our behalf for certain of the purposes identified above. In particular, we use such third parties for data hosting, connecting your wallet to our Services, debugging, error reporting and usage analytics.
If we are sold or integrated with another business, certain of your details may be disclosed to our advisers and any prospective purchaser's adviser and will be passed to the new owners of the business.
We may share information with professional advisors such as insurers, lawyers and other professional advisors for insurance claims, audits and/or the receipt of advisory services. These entities' privacy notices will provide more detail on this processing.
We may also be required to share Personal Data with governments competent authorities, police, courts, public entities, and other regulatory authorities (including similar regulatory authorities outside the EU, EEA member countries, or the UK).
Personal Data that we collect from you may be transferred to and stored at a destination outside the UK/EEA, in particular, to the US. Where these locations do not provide an adequate level of data protection, we ensure appropriate safeguards are in place to protect the transfer of your Personal Data to these third countries. These may include the use of standard contractual clauses as approved under applicable law or applicable Processor Binding Corporate Rules.
Third parties we may share Personal Data with
- If you sign up to receive direct marketing communications from us, we will share your Personal Data with a third party service provider to send our direct marketing related communications using the means of communication you have consented to. We mostly send out our direct marketing communication using email through the third party service provider Mailchimp. With Mailchimp we mainly share Personal Data such as Personal Data such as email address, and may include first and last name.
- For our events, such as the WoW Gala we collaborate with Tokenproof to offer enhanced services, such as ticketing solutions. When you interact with these services, you may need to agree to their terms and conditions and privacy policies. Moreover, as part of this collaboration, we may collect additional information from you as required by this service provider. This could include unique identifiers, social media information, or other data necessary to fulfil the service requirements. In some cases, the service provider may facilitate transactions, which involves collecting payment information through third-party payment processors.
Rights in relation to Personal Data
You have certain rights in relation to your Personal Data, including
- the right to request access to the Personal Data we hold about them;
- the right to have inaccurate information about them amended or updated;
- the right to object to processing of Personal Data about them;
- the right to withdraw consent at any time (where relevant);
- the right to have Personal Data about them erased or to restrict processing in certain limited situations;
- the right to data portability and to request the transmission of Personal Data about them to another organization;
- the right to object to automated decision making that materially impacts them, direct marketing, and processing for research or statistical purposes; and
- the right to lodge complaints with applicable data supervisory authorities.
These rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.
If you wish to exercise any of these rights, please contact us at the contact details set out below.
Wherever we rely on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. We may however have other legal grounds for processing your data for other purposes, such as those set out above.
In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
Updates to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your Personal Data.
Cookies and analytics
When you access our website, we ask for your consent to allow us to store the following cookies on your device:
- Google Analytics - We use Google Analytics to collect information about how users behave on our website. We use the information to compile reports and to help us improve the site. These cookies collect the number of visitors to the website, where visitors have come to the website from and the pages they visited.
- Mixpanel - We use Mixpanel to understand how users interact with web and mobile applications. The data we collect is used to build custom reports and measure user engagement and retention.
- HotJar - We use Hotjar as a tool to provide feedback through tools such as heatmaps, session recordings, and surveys. HotJar works with web analytics tools such as Google Analytics to offer an insight into how you are navigating websites, so we can understand how we can improve your experience.
If you have questions about this privacy notice or wish to contact us for any reason in relation to our processing, please contact us at firstname.lastname@example.org.