Privacy Policy

1. Introduction

Alpha Wolf Gaming OÜ (“Winerz”, “we”, “our”, “us”) operates the Winerz mobile application and related services (“Service”).

We are committed to protecting your privacy and handling your personal data in compliance with the General Data Protection Regulation (EU 2016/679 – “GDPR”) and other applicable laws.

This Privacy Policy explains what data we collect, how we use it, your rights, and how you can contact us.

2. Data Controller

The data controller responsible for your personal data is:

3. What Data We Collect

We may collect the following categories of data:

• Identity & contact data: name, email, phone number.
• Account data: username, password, profile information, tournament participation.
• Payment data: processed securely via Apple, Google, or third-party payment providers.
• KYC data: ID documents, selfies/biometric verification, proof of address – processed by our trusted partner Veriff.
• Gameplay & usage data: scores, results, interactions with the app.
• Device & technical data: IP address, device type, operating system, app version, advertising identifiers.
• Marketing & communications data: preferences, opt-ins to newsletters, referral activity.

4. Legal Basis for Processing

• Contract: to provide our app, tournaments, subscriptions, and support.
• Consent: for optional marketing communications, push notifications, cookies/tracking.
• Legitimate interests: to prevent fraud, ensure security, improve user experience.
• Legal obligations: to comply with tax, accounting, and regulatory requirements.

5. How We Use Your Data

• To create and manage your account.
• To enable participation in tournaments and process subscriptions.
• To handle payments and withdrawals.
• To provide customer support.
• To send important service updates.
• To deliver marketing messages (if you have consented).
• To improve the app and develop new features.
• To ensure fair play, detect fraud, and maintain security.

6. Data Sharing

• App stores & payment processors: Apple, Google, RevenueCat, Stripe.
• Analytics & crash reporting: Firebase, Branch.
• Advertising partners: Google AdMob, Meta Ads, TikTok Ads.
• Communication services: OneSignal for push notifications, email service providers.

All third-party processors are bound by data protection agreements.

7. International Transfers

Where personal data is transferred internationally, we ensure appropriate safeguards via EU Commission adequacy decisions or Standard Contractual Clauses (SCCs).

8. Data Retention

• Account data: kept for the duration of your account + 24 months after closure.
• Payment/financial records: kept for 7 years.
• Gameplay data: kept for 24 months.
• Marketing data: kept until you withdraw consent.

9. Your Rights (GDPR)

• Right of access, rectification, erasure (“right to be forgotten”).
• Right to restriction of processing.
• Right to object and data portability.
• Right to withdraw consent and lodge a complaint with your DPA.

Contact: support@winerz.com

10. Cookies & Tracking

• Analytics: Firebase, Branch.
• Advertising: Google AdMob, Meta Ads, TikTok Ads.
• Essential cookies: required for app functionality.

11. Children’s Privacy

Winerz is not intended for individuals under the age of 18. We do not knowingly collect data from children.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The latest version will always be available at winerz.com/privacy-policy.