Last updated: December 5, 2023

Thank you for visiting our Website!

For the purposes of this Privacy Policy (hereinafter referred to as the “Policy”), “WePlay”, “we,” “us,” and “our” refer to WePlay Esports Media, Inc.

WePlay is a multi-brand holding company that brings together innovative businesses in the entertainment, esports, gaming, and technology industries. You can find more about our business on this page: https://weplayholding.com/about-us/.

The Policy describes our practices for collecting and processing personal information. It is addressed to the Data Subjects with whom we interact through the Website or in other courses of our business (hereinafter referred to as “you” or “your”).

This Policy applies to the information we collect:

- through the Website https://weplayholding.com/ or any of our web sources that link to the Policy

- through email, text, and other electronic messages between you and this Website

- when you use our services

- when you take part in any of our events

- when you interact with us in any other way

It does not apply to information collected by any third party (including our affiliates and subsidiaries), including through any content (including advertising) that may link to or be accessible from or through the Website.

The Policy relates only to the collection of the information described herein and should be viewed as a supplement to any other notices or contractual terms provided to Consumers.

All the terms and provisions should be considered together with the Terms of Use, available at the link: https://weplayholding.com/terms-of-use/ (hereinafter referred to as the “Terms”).

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website.

By accessing or using this Website, you confirm that you have read and accepted the Policy.

If you have any questions about the Policy or our privacy practices, please contact us using the details below.

Company name: WePlay Esports Media, Inc.

Contact address: 5425 Grosvenor Blvd, Los Angeles, CA 90066

Email: privacy@weplay.tv

Capitalized words, both singular and plural, have the following meanings in this Policy:

the Applicable Legislation refers to the legislation in the field of protection and processing of personal data, which applies to the activities of WePlay, in particular the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation, or“GDPR”) and other laws, under the scope of regulation of which the activities and/or separate instances of processing of data by WePlay may fall.

the Business Client is a person who acts in the course of their business and orders products and/or services (such as developing, producing, and hosting events, esports tournaments, gaming shows, content creation, etc.) from WePlay.

the Consumer is the Data Subject who places orders and purchases WePlay’s services both on their own behalf or on behalf of a Business Client. In case of ordering on behalf of a Business Client, for the purpose of processing Personal Data, all representatives of the company (in particular, those who are acting as an employee, owner, director, officer, or contractor of the Business Client, etc.) shall be considered as the Consumer.

the Cookies are small pieces of data stored on your Device when you visit the Website.

the Data Subject is a natural person whose Personal Data is processed.

the Device means any physical object, such as a computer, mobile phone, or tablet, that is capable of connecting to the Internet or to another device and can access the Website, directly or indirectly.

the IP Address is the internet protocol (IP) address that is a unique number, similar to your mailing address, associated with your Internet activity.

the Personal Data is the information about a natural person who is identified or can be specifically identified, including by any unique identifier.

the Technical Data is the information that is collected by the Website when you visit it (for example, the IP address (web protocol) of the Device you use, data about the web browser you use, your operating system, etc.).

the Visitor is the Data Subject who visits the Website.

the Website is WePlay’s website available at the domain: https://weplayholding.com/.

the Personnel are employees, owners, directors, officers, or independent contractors of WePlay.

Any capitalized definitions not otherwise defined in the Policy shall have the definitions set forth in the Terms and Applicable Legislation.

Except as described otherwise, the definition of “Controller” includes “Business”; that of “Processor” includes “Service Provider”; “Data Subject” includes “Consumer”; “Personal data” includes “Personal Information”; in each case, as defined under the CCPA (as amended by CPRA).

We collect data directly from you in the following cases:

- when you contact us by email, telephone, or our mailing address

- when you contact us through the contact forms on the Website

- when you place an order for our services through the Website, by phone, or by any other means

- during the conclusion and execution of an agreement (payments proceeding, support, etc.)

- during online and offline meetings, presentations, events, etc.

We may also collect some information automatically, as described below:

We process Technical Data. Some of this data is collected automatically, for example, through your web browser (such as Google Chrome, Safari, Mozilla Firefox, Opera, Microsoft Edge) when you use the Website.

This includes the following data:

IP address, browser data, including Device and browser type, browser version, screen resolution, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the Devices you use to access this Website, data on the Visitor’s interaction with the Website.

ID of the session that includes your interaction with the Website; if you came to the Website through a link from another website — the address of such website (traffic source); the functions of the Website you use; pages visited; date and time of visit; length of stay on web pages; way of visiting our Website; and other diagnostic data.

We may collect location information based on your IP address, such as your city, country, and continent. You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your location setting on your Device.

Usually, Technical Data does not give us a real possibility to identify a specific natural person, directly or indirectly, and is therefore not considered Personal Data. We will only use this type of data in an aggregated and anonymized manner. For example, we may use this data to calculate the percentage of Visitors who access a particular feature of the Website, the number of Visitors from different geographical regions, etc.

However, if we combine or link such data with other Personal Data so that it can directly or indirectly identify the Data Subject, we treat the combined data as Personal Data that will be used in accordance with this Policy.

We may receive information about you from some of our service providers (as specified in Section 8 below) who assist us in our business purposes.

Some data, such as your preferred language and country setting, may be collected through Cookies and similar technologies. You can learn more about Cookies and how we use them in Section 10 hereof.

Automated processing of Personal Data, including profiling, is not performed.

All personal information you provide must be true, complete, and accurate, and you must notify us of any changes to such personal information. You may send us an email at privacy@weplay.tv to request access to, correct, or delete any personal information you have provided to us.

When WePlay processes the Personal data of our prospects, Consumers, or Visitors, we act as the controller of such Personal Data.

Upon receipt of Personal Data, we process it in accordance with the following:

After the expiration of the data retention period, aggregated and/or deidentified data may continue to be stored for archival and statistical purposes or in accordance with the requirements of the Applicable Legislation.

The right to object

You may opt out of receiving any communications from WePlay and of processing activities that we perform under your consent.

You may also object to our use of your data when processing is performed based on legitimate interest, as specified in the table above.

To do this, please follow the instructions provided in the notification emails on major changes in our services (in the email footer), change your Cookie Settings (see Cookie Policy for more details), or contact us (see Section 2 of the Policy for our contact details).

Protection of Children

We do not knowingly collect personal information from persons under the age of 18 (hereinafter referred to as “Child” or “Children”). If you are the parent or legal guardian of a Child and become aware that the Child has provided us with Personal data, please contact us (see Section 2 of the Policy for our contact details). If we become aware of the fact of collecting Children’s Personal Data, we take measures to delete this information.

WePlay may accumulate Personal Data, inter alia, by including this data in a personal database. The Personal Data and databases are stored in our office: 5425 Grosvenor Blvd, Los Angeles, CA 90066.

We also use the data centers of service providers. You can get more detailed information in Section 8. Processors of Personal Data hereof.

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your Personal Data to those of our Personnel and contractors who have a business need to know it. They will only process your Personal Data on our instructions and are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We understand the value of Personal Data and make efforts to keep it private and secure.

We do not transfer Personal Data to third parties, except when such transfer is:

- required by Applicable Legislation and only (if necessary) in the interests of national security, economic well-being, and human rights

- at the request of the Data Subject (regarding Personal Data of such Data Subject)

- to our Processors, as specified in Section 8 of this Policy, for a business purpose

- to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of WePlay’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by WePlay about our Website users is among the assets transferred

- with your consent

We may also disclose your Personal Data:

- To comply with any court order, law, or legal process, including to respond to any government or regulatory request

- To enforce or apply our Terms and other agreements, including for billing and collection purposes

- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of WePlay, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection or preventing other crimes.

Anonymous or pseudonymized information

When the information collected from or about you is not defined as Personal Data under applicable law, we may share such de-identified information or aggregated information with third parties at our discretion.

Disclosure through Third-Party Cookies

We use Cookies after obtaining your consent through our cookie banner (except for Necessary Cookies). To learn more about how WePlay uses the Cookies, please see our Cookie Policy.

Information that is automatically collected (as more specifically described in Article 4 of the Policy) when you use the Website and accept Cookies may be disclosed to the following categories of third parties:

- Online services, social media, analytics providers, and other services integrated into the Website to make viewing content and online interactions with you more convenient. For example, we embed YouTube player code to make some of our videos on YouTube available for watching through the Website.

The providers of such services may recognize their cookies during your visit to the Website and use other digital advertising tools (such as pixels, web beacons, clear GIFs, or other similar technologies) to track you across the Devices and online services you use outside our Website. Therefore, they may learn about your behavior on the web and display online advertisements they think are relevant to you after you leave the Website.

We limit our liability regarding third-party resources and services, as specified in Section 11 hereof.

Right to opt out of disclosure through Third-Party Cookies

Such disclosure may constitute a sale under certain state laws and, in California, may also constitute “sharing” (a term used to describe the sharing of information for advertising purposes).

To the extent that WePlay’s use constitutes a sale or sharing of your personal information, you have the right to opt out of using Cookies by sending us an opt-out request through the opt-out form or by sending us an email to privacy@weplay.tv

We may engage third parties and/or individuals to facilitate the processing of Personal Data on our behalf, provide services such as data storage, assist in analyzing how our Website is used, improve Website usability, and other services necessary for Website operation and achieving the goals of our activities (hereinafter referred to as “Processors”).

In particular, our Processors are:

1) Partners whose data centers and hosting we use:

Amazon Web Services EMEA SARL (AWS), Address: 38 Avenue John F. Kennedy, L-1855, Luxembourg. We use the data center of AWS located in Germany. You may find out more about the servers of AWS or its affiliates at https://aws.amazon.com/legal/marketingentities/; Privacy Policy: https://aws.amazon.com/privacy/.

2) Banks and other payment service providers

3) Partners who provide us with technical support, IT services, data analysis, auditing services, and other business services

4) Partners who provide us with support services associated with Website management and compliance, such as Objectis Ltd. (CookieScript service), address: Laisves st. 60, LT-05120 Vilnius, Lithuania; Privacy Policy: https://cookie-script.com/legal/privacy-policy

5) Our Personnel who support and develop WePlay’s services

6) Our affiliates and subsidiaries when they act like our service providers or contractors

7) Other service providers and contractors whose services we use to achieve our business activity’s goal(s)

The Processors have access to your Personal Data only to perform tasks within the scope and purposes of Personal Data processing in accordance with the Policy.

Your data may be used, stored, and processed in other countries where our Processors are located. These locations may be outside of your country of residence or outside of your state/province and may have different data protection standards than your country/state/province.

Personal Data transfer to foreign entities is carried out under the condition that the state in question ensures adequate Personal Data protection.

The data transfer takes place with appropriate safeguards and is based on Applicable Legislation’s standard provisions. For example, if we transfer personal data from the EU/EEA to countries with insufficient data protection, we rely on Data Processing Agreements (DPAs) and Standard Contractual Clauses (SCCs) approved by the European Commission or other provisions as required or permitted by Articles 46 and 49 GDPR.

We use Cookies to improve the functionality of the Website, personalize your experience, and analyze information about your activities for a better understanding of how our Website is used.

For example, the choice of your preferred language or the region you are in is saved thanks to Cookies. Thus, you will not have to re-enter data or choose settings again when visiting the Website. With the help of a Cookie, we receive the Technical Data specified in the Policy.

You can allow or deny all Cookies or personalize your settings through the cookie banner on the Website. You can also block or delete Cookies at any time.

You can see more details about how we use Cookies in our Cookie Policy: https://weplayholding.com/cookie-policy/.

The Website may contain links to third-party resources posted for informational purposes. If you link to other resources, this Policy will not apply to such resources. For example, our Website contains links to the websites of our partners or well-known awards.

Our Website may also integrate online services, social media, analytics providers, and other services to make viewing content and online interactions with you more convenient. For example, we use video streaming services offered by YouTube.

Please be aware that we do not control the content or privacy practices of such streaming and other services. You should be aware that such third-party functionality may be subject to the privacy statements of such parties.

We are not responsible for the policies and practices of other companies. Any information you provide to such companies is subject to their privacy policy or another document that regulates the processing of Personal Data.

If you leave the Website via a third-party web link, we recommend that you review the privacy policy of each website or service before submitting any Personal Data and carefully review their terms of use.

WePlay cannot guarantee the security of your Personal Data when using the services of third parties, nor can it be responsible for their work, as it is not the owner of these resources.

You have certain rights under applicable data protection laws in some regions (like the EU/EEA, the U.S., etc.).

Based on the applicable laws of your country, you may have the right to request access to the Personal Data we collect from you, change that information, or delete it.

To review, update, or delete your Personal data, please send us a request, with the subject stating “Personal Data,” to the email address privacy@weplay.tv, or make an inquiry through our contact form: https://weplayholding.com/contact/, or submit your request in writing to us on the mailing address listed in Section 2. Our contact details of this Policy.

Please note that we may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests at a reasonable time and within 1 (one) month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests, or we are authorized by Applicable Legislation to consider your request for longer than this period. In this case, we will notify you and keep you updated.

If your request cannot be satisfied for legal reasons, you will receive a notification from us accordingly.

We will not charge you a fee for making a request unless your request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

12.1. If you are located in the European Union (EU) and/or European Economic Area (EEA) or the UK, you have the following rights:

- the right to access, update, or delete the information we have on you.

- the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

- the right to object. You have the right to object to our processing of your Personal data.

- the right of restriction. You have the right to request that we restrict the processing of your Personal data.

- the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable, and commonly used format.

- the right to withdraw consent. You have the right to withdraw your consent at any time when we rely on your consent to process your Personal data.

If you believe we are unlawfully processing your Personal data, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en

12.2. Your State Privacy Rights (for the U.S.)

California Privacy Rights

For additional information for residents of the State of California, click here.

“Shine The Light” law requirements

WePlay does not share your personal information with any third party for the purpose of direct marketing.

We also ask for your consent (opting in) for using Cookies (except for the necessary ones), as more specifically described in our Cookie Policy.

However, some providers of integrated services used on the Website, such as embedded YouTube video streaming service, may recognize their cookies during your visit to the Website and use other digital advertising tools (such as pixels, web beacons, clear GIFs, or other similar technologies) to track you across the Devices and online services you use outside our Website.

Such disclosure may constitute “sharing” under CCPA (as amended by CPRA), a term used to address the sharing of information for advertising purposes.

To the extent that WePlay’s use constitutes a sale or sharing of your personal information, you have the right to opt out of it through the opt-out form or by writing to us by email: privacy@weplay.tv.

Our policy on “Do-Not-Track” Signals

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized at this stage. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

Other States

For additional information for Colorado, Connecticut, Virginia, and Utah residents, click here.

WePlay may update this Policy at its sole discretion from time to time. The updated version will state the date of the last update and will be effective as soon as it is accessible.

The publication of the new version of the Policy on the Website will be considered as the notification of Policy change. We encourage you to review this Policy frequently to be informed about how we use your Personal Data.

If we make material changes to this Policy, we may notify you by prominently posting a notice of such changes or by directly sending you a notification (in pop-up windows on the Website, sending non-marketing emails, or by other available reasonable means).

When you interact with the Website, you confirm that you have read the current terms of the Policy.

In the event that any part of this Policy is declared invalid, the other parts will remain in effect.

If the Policy is published in different languages, the English version will prevail.