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INFORMATION ON PRIVACY AND TERMS OF USE

Introduction

WhatWapp Entertainment Srl develops and publishes games for the main mobile devices and for the Web. "WhatWapp Entertainment", "we" or "us" refers to WhatWapp Entertainment Srl, to other legal entities of WhatWapp Entertainemnt and/or any of their agents, consultants, employees, officers and administrators.

This Privacy Policy applies whenever the user uses our games or otherwise accesses our products, services, content, at www.whatwapp.com and/or other domains provided by WhatWapp Entertainment, collectively referred to as "Services" ". This privacy statement describes:

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Types of collected data and collection methods

User information obtained from social networks (such as Facebook and Google Plus)

If you use WhatWapp games or access any of our other services on a social network such as Facebook, we will automatically receive certain data on your account from the social network. The data we receive depends on the game the user plays, on the social network , on their privacy settings and on those of his friends on that social network.

For example, WhatWapp Entertainment may collect and store some or all of the following information provided by the social network:

In case of access to our Services from a social network, it is recommended to read the terms of service and the privacy policy of the specific social network.

In case of any doubt about the types of data that a social network shares with us, the user is requested to visit the site of the social networks on which he uses our games to learn more about their privacy settings.

Cookies and automatic data collection We and the service providers that act on our behalf, such as Google Analytics, store log files and use tracking technologies such as:

We and our service providers use these log files, tags and tracking technologies to collect and analyze certain types of technical information, including:

In some cases, we will associate this information with the user ID on the social network or the WhatWapp user ID.

Please note that companies that broadcast advertisements on our Services may also make use of cookies or other technologies as described below in Third Party Advertising including targeted advertisements and analytical tools and that these practices are subject to the respective information of these companies.

More information from the mobile device

If you use WhatWapp Entertainment games on your mobile device, in addition to the device identification codes, we may also collect:

To change the privacy preferences on your mobile device, see the How to access, update, and manage data.

User data shared directly with us

While using our Services (via a social network or directly via WhatWapp), you may provide us with direct data (for example during the configuration of your account) and we will store it on our systems and use it for the purposes described in this Privacy Policy.

Some games or parts of our Services may use a more traditional registration or configuration process that requires the user to send us some or all of the following information:

We could also allow the user to create a profile of the player different from their profile on the social network (for example, his profile on Facebook) visible to other WhatWapp players. The player profile may include information such as:

Certain information on the player's WhatWapp profile will be of public access on WhatWapp websites that offer direct access to WhatWapp games, including the following:

Information on the user's contacts

We may give the user the ability to import contacts from their address book or enter them manually so that they can find their contacts on WhatWapp Entertainment and invite them to participate to play our games or other aspects of our services. You are responsible for obtaining consent from your contacts when you choose to provide us with their contact information.

We may also obtain information about the user from other WhatWapp users who import or insert their contacts. We use and may retain this information to help you and your contacts connect through our Services. If you wish to remove your archived contacts from us, you must follow the instructions provided in the game to request that we remove such data from our systems. If the user needs to enter a password to allow us to access his address book, that password will not be stored on our systems.

Data generated using our communication functions

You may participate in certain activities on our Service that enable you to communicate or share data not only with WhatWapp, but also with other players in our games. These data include:

The user explicitly acknowledges and agrees that we can access in real time, record and/or keep archives of such communications, comments, photos and drawings on WhatWapp servers to protect the safety and well-being of our players and the rights and property in relation to the Services of WhatWapp Entertainment Srl; conduct research; manage, improve, customize and optimize our Services and the experiences of our players, also through the use of the analysis; and manage and provide contextual advertising.

Payment details

If you purchase a license to use virtual gaming currency or virtual items in a game that you use on whatwapp.com, our third party payment processing partner will collect the billing and financial information needed for processing the charges charged to the user. This data may include the user's postal address, email address and financial data. WhatWapp Entertainment Srl does not collect or store the user's financial data, for example credit card numbers. However, WhatWapp payment processing partners may share with us non-financial data relating to your purchases, such as your name, billing address, and items purchased for order fulfillment. WhatWapp could also obtain the billing and payment information provided by the user when his purchase is processed by another person (such as Facebook, Apple or Google), for example when the user purchases something in a game that he uses on a social network and that he has downloaded on his mobile device. Our Terms of Service describe our information and terms relating to our charges, billing procedures, third party credits and virtual coins. Please also bear in mind that the purchase of third party credits or coins may also be subject to the information of these parties.

Correspondence with Customer Support

When you contact our Customer Support team for assistance, we will collect and store contact information sent to them (usually the name and email address), game information or activities on our services, as well as the player's WhatWapp ID and/or social network identification code. We will also store the communications exchanged with the Customer Service team and any information contained in such communications to provide assistance.

Other sources

We may collect or receive user data from other sources, for example third-party information providers. We use this data in conjunction with the data that the user sends us directly, for example to facilitate the connection between the user and his friends or to provide more targeted advertising to the user's interests.

To learn more about how we protect user data, see the section on Data Protection.

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How to use the collected data

The main purpose for collecting and archiving data is to provide a better gaming experience, but other uses are also foreseen. The purposes of collecting and archiving user data include:

Another important use of user data is for communication purposes. If you have provided WhatWapp with your email address, we will use it to respond to requests for customer support and to keep you informed on your game activity, including comments from your friends, messages on the state of the game, for example "the crops are ready", and to warn the user about gifts or requests from neighbors. Some messages, such as invitations to participate in a game by friends, may include the name and photo of the user's profile. We may also send promotional email messages and promotional SMS messages ("Promotional communications") directly or in collaboration with other subjects, depending on the user's marketing preferences. Each Promotional Communication will offer options on receiving additional messages.

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Data sharing mode
We may disclose or publish aggregate data (collective data relating to you and to other players, not intended to specifically identify you, for example: players aged 21 to 25 who reside in San Francisco) and others non-personal data relating to our players for purposes of sector analysis, demographic profiling, marketing, analytics and advertising and other commercial purposes.

In addition, we will share your data (including any personal data) with third parties (that are subjects other than WhatWapp Entertainment) or we will allow third parties to collect such data from our Services in the following circumstances:

The consent of the user

With your acception, we may share your data with third parties and allow them to collect such data from our Services in ways not specifically described in this Privacy Policy.

Friends and other players of our games
The Service supports and often encourages user interactions with other players. In most WhatWapp Entertainment games, if the user plays through a social network or registers through a social network (for example, Facebook Connect), the user's friends on the social network will be able to view his name, profile picture and descriptions of his game activity. Furthermore, in many WhatWapp games, other players, whether they are friends on social networks or not, will be able to view the descriptions of the user's game activity, communicate with the user himself through our Services and view his game profile , which could include the name or a "game name" and profile photo. For example, in Burraco: La Sfida, any other player could view the user's game profile, if present at the same table. In certain cases, the profile photo can reveal the user's identification code on the social network or the player's WhatWapp ID. Access to this data may allow others to view public information associated with their profile on the social network or on the WhatWapp account. Other players may also send game requests or even friend requests to the user via the relevant communication channels of the social network or WhatWapp.

Third party advertising including targeted advertising and analytical tools

The advertising that accompanies our Services allows us to continue to offer many of our services free of charge.

We do not actively share personal data with third-party advertisers to serve their direct marketing purposes, unless the user gives us their explicit consent.

When advertisers or advertisement networks post advertisements to our Services, they may collect or we may share the following types of data from within our Services:

The collected data can also be used to:
measure the effectiveness of advertising, to offer targeted advertising and personalize the user experience by showing advertising and services more in line with his interests (a practice known as behavioral advertising), and/or support the Web analytical tools (such as Google Analytics, which is used to analyze the traffic and activity of other players to improve their user experience).
Advertisers or advertisement networks may collect this data through the use of tracking technologies such as browser cookies and Web beacons and may use a single tracking technology or multiple tracking technologies at the same time.

The user is requested to note that, after clicking on a third-party advertising, it may no longer be on a site hosted by WhatWapp or on the social network through which it uses our games.

If you do not wish to receive targeted in-app advertisements from third parties, refer to the section on how to access, update and manage data.

Security, protection and compliance with the law

Your data and the contents of all online communications in our Services between you and WhatWapp may be consulted and monitored as necessary to provide our Service and may be disclosed:

when, in good faith, we believe we have an obligation to disclose data in response to a legal process (for example, a court order, search warrant or subpoena);
to comply with any applicable law or regulation;
where we are able to believe, in our discretion, that the Service is used in committing a crime and to report such criminal activity or to share information with other companies and organizations for fraud protection, credit risk reduction and other safety precautions;
when we believe, in good faith, that there is an emergency that could compromise the health and/or safety of the user, another person or the general public; is to protect the rights or property of WhatWapp and other third parties, including to apply our Terms of Service.

Offers Notice Board
The WhatWapp games or their purchase pages may display an "Office Notice Board" hosted by a special provider. The Offering Notice Board allows third party advertisers to provide virtual currency in exchange for interacting with an advertisement or completing a marketing offer that may require an account to be registered with one of these advertisers. These offers could be shown to the user based on certain technical information, such as geographic location or anonymized demographic data. After clicking on one of these offers, you will no longer be on a site hosted by WhatWapp or on the social network through which you can enjoy WhatWapp games. To properly credit player accounts and to prevent fraud cases, a unique identifying code, in some cases the user's identification code on the social network or the player's WhatWapp ID, will be shared with the provider of the Offer Notice Board.

Third party service provider

We will share your data with third-party companies to perform services on our behalf, such as payment processing, data analysis, game optimization, email delivery, service hosting, customer service and to assist us in our marketing initiatives, including management and delivery of contextual and targeted advertising. These third-party service providers have a contractual obligation to maintain the confidentiality of the data we share with them and impose on them a prohibition to use the user's data for purposes other than providing services on our behalf.

Sale or merger
If WhatWapp is subjected to a commercial transformation operation, for example a merger, acquisition by another company or the sale of all or part of its activities (such as the sale of a game), we may transfer all data user, including personal data, to the organization taking over the operation. We will use reasonable endeavors to notify you and other players (as described in the Changes to our Privacy Statement) about the operation of the business transaction before transferring your personal data.

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How to access, update and manage your data
Data that we receive from the user's mobile device or from a social network on which the user uses our games. To manage the data that WhatWapp receives about the user from a social network like Facebook, the user will have to follow the instructions on that site to update their data and changing their privacy settings. The privacy management tools for Facebook applications can be found here. To review and update the data associated with your WhatWapp profile in certain games, visit the "settings" page in that game. It is also possible to manage some aspects of data collection and use by visiting the "settings" page of your mobile device and consulting the permissions of each application or "app".
When WhatWapp receives user data from a social network or its mobile device, such data is stored and used by WhatWapp in accordance with this Privacy Policy. The user has the right to access and update the data as described below.

Access and update of data held by WhatWapp

If you wish to review, delete or modify the data held by WhatWapp, or if you have any further questions, you can send an email to info@whatwapp.com. We will answer to all requests within thirty days.

Interruption of data usage

If you no longer want WhatWapp to actively use your data, you can send an email to info@whatwapp.com. Enter "Delete my account" in the subject and include your name, surname, email address and social network identification code from which you access our Services (if applicable) in the body of the email (for example , the user identification code on Facebook). We will respond to all requests within thirty days. Please note that certain data, for example relating to payments or requests for customer service assistance, will be kept in the archives for legal and accounting purposes. You may not be able to delete content posted or posted to the Service.

Exclusion from geolocation

If the user has previously allowed access to their geolocation data, he can choose not to make geolocation available by visiting the settings of the mobile device or the "settings" page of the game in question.
Excluding the ongoing collection of non-WhatWapp app information on the device

In the event that one of our games is collecting information on non-WhatWapp apps on your device, the game will provide you with an option to stop the availability of that information on the related "Settings" page.

Exclusion from WhatWapp promotional emails

If you no longer wish to receive emails from WhatWapp, you must click on the "unsubscribe" link in any WhatWapp promotional email or visit the email preferences page. Please note that once the request is received, additional time may be required before the exclusion becomes effective. The request for cancellation of the registration or modification of your email preferences will be processed in a timely manner, in any case no later than ten working days.


Exclusion from other communications

The user can choose not to receive more SMS messages by sending an SMS with STOP written to the number that we use for that particular SMS message program. In some cases, a preferences management page will be available. When we receive a user exclusion message for SMS messages, we may send a message confirming receipt of the exclusion request.
When the user installs our apps on their mobile device, he can choose to receive push notifications, which are messages that an app sends to the mobile device even when the app is not active. You can deactivate notifications by visiting the "settings" page of the device.
Please note that in the event of exclusion from our promotional communications or other forms of communication, we may still send emails or communicate with you from time to time if we need to send information about the Service or request information regarding a transaction initiated by the user or for other legitimate non-marketing reasons, for example, if we update this Privacy Statement or our Terms of Service.


Exclusion from targeted third party advertising

If you wish to learn more about targeted advertising and the options available to you to prevent third parties from broadcasting targeted advertising on the Internet and on your cellular network, you can visit the following websites:

Consumer exclusion page from advertising campaigns on the network or Exclusion page from the Digital Advertising Alliance for advertising in the United States;
the Your Online Choices UK, website for advertising in the EU.
These exclusion tools are provided by third parties, not by WhatWapp. WhatWapp does not control or manage these tools, nor the options advertisers and others make available through these tools.

In addition, if the user does not wish to receive targeted in-app advertisements from third parties in line with his interests in the app on his mobile device, he can opt for exclusion by modifying the advertising tracking settings on the device. It is also possible to reset the "Advertising identification code" (for example an IDFA) from the settings page of your mobile device, which will prevent prolonged use of the existing behavioral data linked to the previous "Advertising identification code". In addition to this, depending on the platform provider (eg Apple or Google), you can download apps, such as "AppChoices" by the Digital Advertising Alliance, which provides the user with control over the collection and use of data between various apps for targeted advertising. Like the exclusion tools mentioned above for the Web, these are also provided by third parties, not by WhatWapp. WhatWapp does not control or manage these tools, nor the options advertisers and others make available through these tools.

Please note that it is possible to continue receiving advertisements from third parties in the WhatWapp games, even if you choose to opt out of targeted advertising. However, these advertisements will not be based on specific user activity on unrelated websites or apps.

Exclusion from cookie monitoring

You can set the web browser to receive an alert when an attempt is made to insert cookies on your computer or limit the type of cookies allowed. Flash cookies work differently than browser cookies and the cookie management tools available in a web browser may not remove flash cookies. To learn more and to manage flash cookies, visit the Adobe website and make changes in the Global Privacy Settings panel.

If cookies are deactivated, it is possible that some of the features and functionality of our Services are lost, because WhatWapp cookies are necessary to monitor and optimize gaming activities.

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Information on the privacy of connected third-party services and advertisers
Our websites and games may contain advertisements from Third Party Services, that is, companies other than WhatWapp that may link to their websites, online services or mobile applications. We are not responsible for the privacy practices or the contents of these Third Party Services. If you have any questions about how these third-party services use your data, consult the relevant information and contact them directly.

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Information related to children protection
Our websites and games are not intended for children under the age of 13 and do not intentionally collect their personal information. Children under the age of 13 should not use our websites or games under any circumstances. In the event that we learn that we have inadvertently collected personal information from a child under the age of 13, we will take reasonable steps to delete such information from our records.

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Duration of data storage
The duration of the storage of user data on our part depends on the reasons for the collection and how to use it. We will not store personal data longer than necessary for our business purposes or to meet legal requirements. For example, we may retain some data for a few years after closing the user's account with us if this becomes necessary to fulfill our legal obligations or to exercise, defend or establish legal rights.

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Data protection
We take appropriate security measures to protect data security both online and offline and are committed to protecting our customers' data. We take reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.
If you have an account registered directly with WhatWapp, your profile information is protected by the password used to access the WhatWapp account. It is important to protect and maintain the security of your WhatWapp account and immediately report any unauthorized use of your account. If you forget the password for your WhatWapp account, the Service allows you to request instructions that explain how to reset your password. In case of access to our Services through a social network and if the user's account on the social network is compromised, it is possible that someone uses the WhatWapp games without his permission. Therefore, please keep the data security of your account on the social network, including the password of that account. We urge you to log out of the WhatWapp account and any social network account used to access our Services after such use.

When you log in to your WhatWapp account or enter payment information, we or our payment processing partner use a secure socket layer ("SSL") technology to encrypt the transmission of such data.

Although we take reasonable precautions against possible security breaches of our Services and our customers' databases and archives, no website or Internet transmission is 100% secure. Although we are committed to protecting your personal data, we can not guarantee that no unauthorized access, compromise or other violation will occur and we can not guarantee the security of data during transmission to our Service. Any transmission will take place at the risk of the user. If you have questions about the security of our websites, contact us at
info@whatwapp.com.

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Changes to our Privacy Statement
If we decide to make substantial changes to our Privacy Policy, we will notify you and our players by posting a notice on whatwapp.com or equivalent communication within the game, or by sending a notice to the address and email in our archives before the change comes into force. We could supplement this procedure by publishing notices on game blogs, social network pages and/or forums and on other WhatWapp websites. We recommend that you regularly visit http://www.whatwapp.com and review updates to this privacy statement.

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