Privacy Policy

Last Updated: May 25, 2023

Wasabi LLC, a Florida limited liability company (“Wasabi” or “we” or “our” or “us”) recognizes the importance of the personal data you the User have entrusted to us for proper management, protection, and processing of your personal data through Gamecat platform. This Data Protection and Privacy Policy (“Privacy Policy”) explains what personal data we collect and why, how we handle, use, disclose and process personal data.

We only collect personal data that we reasonably necessary to provide our Services. We do not collect, manage, store, and process personal data that is unnecessary. If applicable personal data privacy laws allow us to collect, use and/or disclose your personal data without your consent, such permission applies to this Privacy Policy notwithstanding anything to the contrary stated herein.

1. Definitions

“Data” means any representation of information in any document and includes a personal identifier.

“Data processor” means a person who (i) processes personal data on behalf of another person; and (ii) does not process the data for any of the person’s own purposes.

“Personal data” means any data (i) relating directly or indirectly to a living individual; (ii) from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and (iii) which are in a form in which access to or processing of the data is practicable. Personal data can be factual (such as a name, address or date of birth) or it can be an opinion (such as a product review). It can include an e-mail address, particularly if used in conjunction with other identifiers. It is important that the information has the data subject as its focus and affects the individual’s privacy in some way.

“Processing” in relation to personal data, includes amending, augmenting, deleting or rearranging the data, whether by automated means or otherwise.

2. Types Of Personal Data We Collect

We collect information about you when you register a Gamecat account with us (“Account”) and use our website(s), website/IT portal(s)/mobile application(s), forms, surveys, and other channels and throughout other interactions, communications and services (“Services”) you have with us.

When Users share on Gamecat platform, personal data we may collect includes:

- your personal information such as your name, national identity card number, passport number, date of birth, marital status, gender;

- your contact information such as residential or postal addresses, email addresses, telephone, mobile phone and fax numbers;

- your location and thus we may require location permission to access certain features. If you do not wish to give such permission, you can still use our Services but certain features may not be available;

- communications between you and Gamecat. While we may send you Service-related emails (e.g., news, changes/updates to features of the Services), you may opt out of them;

- your past and present employment information such as organization name, organization type, industry sector, job function and responsibilities, designation, business telephone and fax numbers, business email addresses;

- for corporate users beneficial owner information, authorized signatory information, business telephone and fax numbers, business email address;

- billing and payment information, including name of the credit/debit cardholder, credit/debit card number, security code and expiry date; or

- proof of income and financial details, photographs, videos and/or audio recordings collected from us through online (websites, emails, apps, etc.) or offline platforms (events, surveys, phone calls, etc.).

When Users visit our website(s) or use our website(s)/IT portal(s)/mobile application(s), we may collect and store certain information automatically, such as:

- the internet protocol (IP) address used to connect your computer or device to the Internet;

connection information such as browser type and version;

- operating system and platform;

- a unique reference number linked to the data you enter on our system;

- login details;

- the full URL clickstream to, through and from the website(s) or website/IT portal(s)/mobile application(s) (including date and time);

- cookie identifier, and

- your activity on our website(s) or website/IT portal(s)/mobile application(s), including the pages you visited, the searches you made and, if relevant, the Services you purchase.

If you choose to link your profile on our website(s) or website/IT portal(s)/mobile application(s) with your profile on a third-party website or social media platform (such as Facebook, Instagram, or Twitter), we may receive information about you from that third party. This information may include your name, email address, profile picture, and other information that you have made public on the third-party platform.

If you the User provide us with the personal data of another person, you confirm that you have their permission to do so and that they have been informed about how their data will be used, as set out in herein.

In respect of personal data provided to us, we: will only use the personal data provided for the purposes stated in paragraph 5 of this Privacy Policy; will disregard any personal data provided that is irrelevant for the purposes stated in paragraph 5 of this Privacy Policy; and

will not use the personal data for any other purposes unless you have given your prescribed consent to the use for the relevant other purposes.

3. Cookies

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device. You can block or deactivate cookies in your browser settings. We use cookies to:

- identify you from other users on our website(s) or website/IT portal(s)/mobile application(s);

- remember your preferences on language, font size, color scheme, so that the look and feel of our website is kept for your future visits;

- analyze how you navigate our website and applications to help us optimize its design; and

- track your behavior and preferences so we can assess the kind of information and Services you may be interested in from us.

We use log-in cookies to remember you when you have logged in for a seamless experience. We use session cookies to track your movements from page to page and to store your selected inputs so you are not constantly asked for the same information. By continuing to use our website(s) or website/IT portal(s)/mobile application(s), you are agreeing to the use of cookies on the site as outlined above. Note that we have no control over the cookies used by third parties.

4. Rationale For Our Collection, Use, Or Disclosure Of Users’ Personal Data

We will/may collect, use, disclose and process your personal data for one or more of the following purposes:

- To consider and process your application to be our user and to process your Account with us;

- To facilitate, process, deal with and administer your Account with us;

- To supply of any goods and Services which we may offer to you or that you may request, obtain or purchase from us or through our website/IT portal(s)/mobile application(s);

- To notify you of new game releases or updates;

- To deal with, process and administer your use of the online Services at any of our website(s), website/IT portal(s)/mobile application(s) and through other digital or telecommunication channels;

- For identification and verification purposes in connection with any of the goods and Services that may be supplied to you by us or that you may request from us;

- To carry out your instructions, respond to any enquiry or deal with any feedback given by (or purported to be given by) you or on your behalf, including contacting you via phone/voice call, text message or fax, email and postal mail regarding your instructions, enquiries and feedback;

- To conduct research, analysis and development activities (including but not limited to data analytics, surveys, focus groups and/or profiling) to improve our Services and facilities for your benefit, or to improve any of our marketing programs or events;

- To deal with, process and administer marketing campaigns conducted by us or on our behalf which you have consented to participate in;

- To contact you or communicate with you via various modes of communication such as email or via your Account for the purposes of administering, dealing with and/or managing your Account with us. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;

- To carry out due diligence or other screening activities (including security and background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;

- To prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with and investigating complaints;

- To comply with or as required by any applicable law, governmental or regulatory requirements of any jurisdiction applicable to us or our associated companies, including meeting the requirements to make disclosure under the requirements of any law binding on us or our associated companies, or for the purposes of any guidelines issued by regulatory or other authorities of competent jurisdiction, with which we or our affiliates/associated companies are expected to comply;

- To comply with or as required by any request or direction of any governmental authority;

- For direct marketing (see below);

- To facilitate and deal with payment for goods and Services provided by us or our subsidiaries, and a third party on our behalf including verification of credit card details with third parties and additionally, using the personal data you provide to conduct matching procedures against databases of known fraudulent transactions (maintained by us or third parties);

- To deal with, handle and conduct disciplinary, security and quality assurance processes, matters and arrangements;

- To perform internal administrative, operational and technology tasks to facilitate, administer or manage your Account with us;

- To produce statistics and research for internal and/or statutory reporting or record-keeping requirements and performing our policy/process reviews;

- To disclose to a third party to comply with any law, legal requirements, orders, directions or requests from any court, authority or government body of any competent jurisdiction;

- To help us improve our Services to you;

- If necessary, to process or receive payments from or to you; or

- To store, host, back up (whether for disaster recovery or otherwise) of your personal data including in a jurisdiction other than your location, (collectively, referred to as the “Purposes”).

Disclosure

We may need to disclose your personal data to third parties, including to banks, payment service providers, other payment gateways or data processors, including to third parties in jurisdictions other than your location, for one or more of the above Purposes, as such third parties would be processing or using your personal data in connection with one or more of the above Purposes. You hereby acknowledge, agree and consent that we are permitted to disclose your personal data to such third parties (including to third parties in jurisdictions other than your location) for one or more of the above Purposes and for the said third parties to subsequently collect, use, disclose or process your personal data for one or more of the above Purposes. Such third parties include:

- our associated companies;

- any of our suppliers, collaborative partners, agents, contractors or third party service providers including;

- IT service and software suppliers;

- payment processors and facilitators;

- cloud platform service providers;

- cloud storage providers;

- data analytics providers;

- research partners;

- marketing and advertising agencies who create our advertisements and promotions;

- background check and identity verification providers; and

- vendors that assist us to enhance the safety and security of our website and Services; and

- our lawyers, accountants, auditors, insurers, bankers, and other similar professionals.

We may also collect from sources other than yourself, personal data about you, for one or more of the above Purposes, and thereafter using, disclosing and/or processing such personal data for one or more of the above Purposes. We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the Purposes set out herein.

5. Security

We take steps to protect your personal data from loss, misuse, unauthorized access, disclosure, alteration, or destruction. We use the same safeguards to protect your data as we use to protect our own proprietary information. All information you provide to us is stored on secure servers and any payment transactions are encrypted using SSL technology.

If we have given you, or if you have chosen, a password that allows you to access certain parts of our website(s) or website/IT portal(s)/mobile application(s), you are responsible for keeping it confidential. We ask that you do not share your password with anyone.

We will delete your personal data as soon as it is no longer needed for the purpose for which it was collected. We will also delete your personal data if we are no longer required to keep it for legal or business reasons. If we share your personal data with third-party service providers, we will use contracts and other means to ensure that they comply with this Privacy Policy. We take steps to protect your personal data, but we cannot guarantee its security when it is transmitted over the internet. Any transmission is at your own risk.

6. Data Retention

We will keep your personal data for as long as your Account registered with us is being accessed. If you do not use your account for 12 months, we will close it and keep your personal data for 2 years. We may keep your data for longer if we need to comply with the law or if you have given us permission. After 2 years, we will delete your personal data, app-related data, and account information. We will also shred or destroy any physical documents that contain your personal data.

We will require the companies we share your personal data with only keep it for as long as they need it. They will delete it if it is no longer needed, unless they are legally required to keep it or it is in the public interest.

7. Data Access, Correction, Deletion

You have the right to see and correct any personal information we have about you. If you would like to request a copy of your personal information, or to update or correct it, please email us. We may need some information from you to verify your identity and the nature of your request. We may charge a reasonable fee for processing your request. We will aim to provide you with your personal information within 40 days of receiving your request. If we cannot provide it to you within 40 days, we will let you know when we expect to be able to provide it.

If we cannot provide you with your personal information due to certain circumstances under applicable privacy laws, we will inform you in writing and provide reasons within 40 days of receiving your request.

For a request to correct personal information, we will correct it within 40 days once we have sufficient information from you to process the request. If we are unable to do so within 40 days, we will inform you of the soonest practicable time when we can make the correction. We may refuse to correct your personal information under certain circumstances, such as when we believe the information is accurate or the proposed correction is inaccurate. If we do refuse to correct your information, we will inform you in writing of the refusal and the reasons for it.

You can delete your Gamecat account or your Gamecat account information at any time. To do this, go to the account settings page and click on the “Delete Account” button. If you delete your account, we will delete or anonymize your personal data so that it no longer identifies you. We may need to keep some of your data for legal reasons, but we will not use it for any other purpose. Once your account is deleted, it cannot be restored.

8. Link To Other Websites

Our website, website/IT portal, mobile application, and other digital and telecommunication channels may contain links to other websites that are operated by third-party companies. These third-party companies may have different privacy practices than us. We recommend that you read the privacy statements of these other websites before providing them with any personal information.

We do not control the personal information that you submit to or receive from these third-party websites. We are not responsible for the content or activities of these third-party websites or their products and services.

9. Direct Marketing

We may use your personal information to send you marketing materials about our products and services, or the products and services of our business partners or third-party merchants. You can opt out of receiving marketing materials at any time by clicking on the "unsubscribe" link at the bottom of any marketing email.

The type of personal data we use for direct marketing purposes is your email address. The direct marketing activities we conduct using your personal data are:

- newsletters and our blog updates

- promotions of our website, Services or applications

- competitions or contests held by us

- updates in respect our website, Services or applications

- surveys in respect of our website, Services or applications

- event invitations

- festive greetings, and/or

- advertisements of our website, Services or applications.

You may request us to cease using your personal data for direct marketing purposes at any time by emailing us, or if applicable using the unsubscribe facility contained in the marketing message.

10. Changes To Our Privacy Policy

We may update our Privacy Policy from time to time. Any changes will be effective immediately after we post the updated Privacy Policy on our website. If we make any changes to the Privacy Policy that affect the purposes for which we collect your personal data, who we may share your personal data with, or how we may use your personal data, we will notify you in advance of such changes through our website, applications, or by email, and we will request your consent. If you revoke your consent to our amendment under this paragraph, stop using our Services entirely.

11. Complaints

If you have concerns about how we handle your personal data or how we comply with privacy laws, please contact us at [email protected], and indicate in the subject line that it is a privacy complaint. This will help us to quickly route your complaint to the appropriate staff member for handling. We will strive to address your complaint promptly and fairly.