Privacy Policy
Last updated: TODO: publish date · Effective date: TODOThis is a generic international template. It is a starting point only and must be reviewed by qualified counsel for your jurisdiction (in particular: GDPR, UK GDPR, CCPA/CPRA, PIPEDA, LGPD, and any local gambling / skill-game data rules) before it is published as the operative privacy notice.
1. Who we are
This Privacy Policy explains how WePay ("WePay", "we", "us", or "our") collects, uses, shares, and protects information about you when you visit our website, use our games, or otherwise interact with our services (collectively, the "Service"). The data controller is TODO: legal entity, registered address, contact email. Reach our privacy team at privacy@prosoft.ge.
2. Information we collect
2.1 Information you provide
- Account information: email, username/handle, password (hashed), date of birth, country of residence.
- Identity verification (KYC): for users who win and request payout — full legal name, government-issued ID, proof of address, selfie or liveness video, tax identifiers where required by law.
- Payment information: payout method details. Card data, if any, is handled by our PCI-compliant payment partners and is not stored on our servers.
- Communications: messages via the support form, email, or in-app channels.
2.2 Information collected automatically
- Device & technical data: IP, device identifiers, OS, browser, screen resolution, language, timezone.
- Usage data: games played, matches and outcomes, entries earned, giveaways entered, in-app actions, timestamps.
- Anti-fraud signals: behavioural patterns, device fingerprints, account-linking signals — core to keeping giveaways fair.
- Cookies & similar technologies: see section 8.
2.3 Information from third parties
- Identity verification providers (KYC).
- Payment service providers.
- Fraud-prevention vendors.
- Authentication providers if you sign in with a third-party account (e.g. Google, Apple).
3. How we use information
- Operate the Service: issuing entries, running giveaways, paying out prizes.
- Verify your identity and eligibility (KYC, age, jurisdiction).
- Detect, investigate, and prevent fraud, multi-accounting, automation, and other prohibited behaviour.
- Provide customer support and respond to requests.
- Communicate about service updates, giveaways you've entered, and (with consent where required) marketing.
- Comply with legal obligations (AML, sanctions, tax).
- Improve and develop the Service, including analytics and product research.
4. Legal bases (EEA / UK users)
- Performance of a contract — to provide the Service, run giveaways, pay out prizes.
- Legal obligation — KYC, AML, sanctions, tax, regulatory reporting.
- Legitimate interests — fraud prevention, security, anti-cheat, analytics, product improvement.
- Consent — for marketing and non-essential cookies. Withdrawable at any time.
5. Sharing information
- Service providers under contract: hosting (TODO), KYC (TODO), payments (TODO), email (TODO), analytics (TODO), customer support.
- Authorities, when required by law or to protect rights, safety, or the integrity of the Service.
- Successors, in connection with a merger, acquisition, or sale of assets.
- Public, aggregated/anonymous form — leaderboards display handles only.
We do not sell personal information.
6. International transfers
Information may be transferred to and processed in countries other than the one you live in, including TODO: list of regions. Where required, transfers are protected by appropriate safeguards (e.g. EU Standard Contractual Clauses, UK IDTA, adequacy decisions).
7. Retention
- Account data — for the life of your account and a reasonable period after deletion for fraud-prevention and legal-defence purposes.
- KYC records — as required by AML law (commonly TODO: 5–7 years).
- Transaction records — as required by tax and financial law.
- Support communications — typically TODO: 24 months.
- Anti-fraud signals — for as long as needed to maintain the integrity of the Service.
8. Cookies and similar technologies
We use cookies and similar technologies to keep you signed in, remember preferences, detect fraud, and analyse usage. Manage non-essential cookies via the in-app banner and your browser settings. Full list at TODO: /cookies.
9. Your rights
- Access the personal information we hold about you.
- Correct inaccurate information.
- Delete information, subject to retention obligations.
- Restrict or object to certain processing.
- Receive a portable copy of your information.
- Withdraw consent at any time, where processing is based on consent.
- Lodge a complaint with your local data-protection authority.
To exercise any of these rights, contact privacy@prosoft.ge. We may need to verify your identity.
10. Children
The Service is not directed to anyone under TODO: 18 (or age of majority in their jurisdiction). We do not knowingly collect personal information from minors. If you believe a minor has provided us information, contact us and we will delete it.
11. Security
We use organisational and technical safeguards — including encryption in transit, hashed credentials, access controls, and regular reviews — to protect personal information. No system is perfectly secure; if you suspect a security incident affecting your account, contact us immediately.
12. Changes to this policy
We may update this Privacy Policy from time to time. We will post the updated version and, for material changes, notify you in-app or by email at least TODO: 14 days before the change takes effect.
13. Contact
Questions or requests? Contact our privacy team at privacy@prosoft.ge, or write to TODO: legal entity & registered address.
Read this together with our Terms of Service and Giveaway Rules.