Privacy Policy – Winerz Mobile App

Last updated: 04/01/2025

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:

Alpha Wolf Gaming OÜ
Harju maakond, Tallinn, Kesklinna linnaosa, Veskiposti tn 2-1002, 10138
Email: support@winerz.com

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 (Know Your Customer) data: ID documents, selfies/biometric verification, proof of address, verification outcomes – processed by our trusted partner Veriff for fraud prevention and legal compliance.
  
  
• 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

We process your personal data only where we have a lawful basis under GDPR:

• 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, and analyze app performance (where your rights are not overridden).
  
  
• 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

We share personal data only with trusted service providers acting on our behalf, including:

• 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 and act only on our instructions.

We may also share data if required by law or to protect our rights and users.

7. International Transfers

Some of our service providers are located outside the European Economic Area (EEA).
Where personal data is transferred internationally, we ensure appropriate safeguards are in place, such as:

• EU Commission adequacy decisions, or
  
  
• Standard Contractual Clauses (SCCs).
  
  

8. Data Retention

We keep personal data only as long as necessary for the purposes described:

• Account data: kept for the duration of your account + 24 months after closure.
  
  
• Payment/financial records: kept for 7 years to comply with tax/accounting.
  
  
• Gameplay data: kept for 24 months for fair play and fraud prevention.
  
  
• Marketing data: kept until you withdraw consent.
  
  

When data is no longer needed, it will be securely deleted or anonymized.

9. Your Rights (GDPR)

As an EU resident, you have the following rights:

• Right of access (know what data we hold).
  
  
• Right to rectification (correct inaccurate data).
  
  
• Right to erasure (“right to be forgotten”).
  
  
• Right to restriction of processing.
  
  
• Right to object (to marketing or certain processing).
  
  
• Right to data portability (receive a copy in machine-readable format).
  
  
• Right to withdraw consent at any time.
  
  
• Right to lodge a complaint with your local Data Protection Authority.
  
  

To exercise these rights, contact us at support@winerz.com

 

10. Cookies & Tracking

We use cookies and SDKs for analytics, advertising, and personalization.

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

When required, we ask for your consent before placing cookies or using tracking technologies.

 

11. Children’s Privacy

Winerz is not intended for individuals under the age of 18.
We do not knowingly collect data from children.
If you believe a minor has provided data, please contact us so we can delete it.

 

12. Changes to This Policy

We may update this Privacy Policy from time to time.
If we make significant changes, we will notify you via email, in-app notification, or website notice.
The latest version will always be available at winerz.com/privacy-policy.

13. Contact Us

For any privacy questions, please contact:

Alpha Wolf Gaming OÜ
Harju maakond, Tallinn, Kesklinna linnaosa, Veskiposti tn 2-1002, 10138
Email: support@winerz.com