Last updated: September 27, 2022
1. Who we are
1.1 We are UPWAKE.ME LTD located at 15 Dimitriou Karatasou, ANASTASIO BUILDING, 6th Floor, Room/Office 601, Strovolos, 2024, Nicosia, Cyprus.
2.1 By making available the Services we, acting reasonably and in good faith, believe that you:
(a) have all necessary rights to register on and use the Services;
(b) provide true information about yourself to the extent necessary for use of the Services;
(c) understand that by the posting your personal information you have manifestly made this information public, and this information may become available to other Site users and internet users, be copied and disseminated by them;
(d) understand that some types of information transferred by you to other Service users cannot be deleted by you or us;
2.2 We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you.
3. Information we collect about you
3.2 We set out in more detail the information we collect when you use our Services, why we collect and process it and the legal bases below.
3.3 Our legitimate interests include (1) maintaining and administrating the Services; (2) providing the Services to you; (3) improving the content of the Services and web pages; (4) processing of the data that was manifestly made public by you; (5) ensuring your account is adequately protected; and (6) compliance with any contractual, legal or regulatory obligations under any applicable law.
3.5 Your personal information may also be
processed if it is required by a law enforcement or regulatory authority, body
or agency or in the defence or exercise of legal claims.
We will not delete personal information if it is relevant to an investigation or a dispute.
It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.
3.6 Please note, if you do not want us to
process sensitive and special categories of data about you (including data
relating to your health, racial or ethnic origin, political opinion, religious
or philosophical beliefs, sex life, and your sexual orientation) you should
take care not to post this information or share this data when using the
Once you have provided this data it will be accessible by other Service users and it becomes difficult for us to remove this data.
3.7 Please note, if you withdraw your consent to processing or you do not provide the data that we require in order to maintain and administer the Services, you may not be able to access the Services.
4. Data sharing
4.1 Your nickname, other information depending on the place of posting (chat room or forum), can be available to all of the Service users. We take technical and organizational measures to ensure that your data is safe. Please note that by the posting your personal information you have manifestly made this information public, and this may become available to other Service users and internet users and be copied and/ or disseminated by such users. Once this data is transferred by you to other users you will not be able to delete this data.
4.2 We may share your data other our affiliates. Sometimes we may also need to share your data with a third party in order to provide our Services to you or to administer the Services, for example if you choose to share your data across social media platforms.
4.3 UPWAKE.ME LTD, other our affiliates or our selected third party partners with our permission, using their own ad servers, can show advertisements to you. Our ad management and recommendation system is designed so that generally your information will not be shared directly with our third party advertisers. An advertiser or maker of a recommendation can only choose to target advertisements to groups of users falling within criteria such as gender, general region information (such as country or city), or other, or to target communities according to their types. If you fall within one of the target groups, you will receive an advertisement or recommendation of such third party partners or our affiliates. However, such third party advertisers or our affiliates may gather some of your information in case you interact in any way with the ads provided by such advertisers.
4.4 An advertiser or maker of recommendations may also choose to upload a list of identifiers (e.g., emails, phone numbers) to our systems so that we (but not the adviser or maker of recommendations) can check for user matches. They will see the number of matches but not the matches themselves.
4.5 If you participate in public tournaments we may have the obligation to disclose your personal information to tax authorities. We also may publish your data as part of the tournament score tables on our and third parties web sites.
4.6 Integrated advertising and analytics. We may share your personal information with analytical systems for the purposes of performance measurement of our Website and our Services, and we may also provide such information to third parties such as advertisement networks. By using our Services you agree that we may transfer your data to such third parties and accept that your data will be processed in accordance with privacy terms of such third parties. The current list of integrated third-party systems used by us is provided here.
4.7. Apple and Google offer the owners of devices that use their operating systems, iOS and Android, options for limiting tracking and targeting in relation to ads. We do not control yours device level opt-out processes and we are not responsible for any choices user make through such mechanism or for the continued availability, accuracy, effectiveness, or location of that mechanism. Using a device level opt-out mechanism you may opt-out of all third-party personalized advertisements. If you use other operating systems (other than iOS and Android) and such operating systems do not provide a device level opt-out mechanism, you shall contact us in order to opt-out of all third-party personalized advertisements
5. Privacy Settings
5.1 The Services may contain links to sites operated by third parties. We are not responsible for your data privacy when you access these links or engage with third party services and you should ensure you review the relevant third party's privacy statement which will govern your data privacy rights.
5.2 We bear no liability for the actions of third parties which, as the result of your use of the internet or the Services, obtain access to your information in accordance with the confidentiality level selected by you.
5.3 We bear no liability for the consequences of use of the information which, due to the Services nature, is available to any internet user. We ask you to take a responsible approach to the scope of their information posted on the Site.
6. International Transfers
6.1 We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including in USA, Japan, CIS.
6.2 The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.
7. Retention Periods
7.1 We will retain your personal information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.
7.2 You may request to remove your account and personal data on our Services by contacting the Service support (see Section 12 for details) and/or using relevant functionality of the Services. Within thirty (30) calendar days we will remove your account and/or data on our Services and you will not be able to restore your account and/or data on our Services. Within the indicated period you may cancel your account and personal data removal request.
7.3 We may remove your account, or the information you post as provided by the Terms.
8. Your Rights
8.1 You have the following rights, in certain circumstances, in relation to your personal information:
(a) Right to access your personal information.
(b) Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.
(c) Right to restrict the use of your personal information.
(d) Right to request that your personal information is erased if:
- it is no longer required in relation to the purposes for which it was gathered or processed in another way;
- you withdraw your consent concerning processing subject to consent;
- you are justifiably opposed to the processing;
- it has been subject to illicit processing; or
- it is imposed by law.
(e) Right to object to processing of your personal information.
(f) Right to data portability (in certain specific circumstances).
(g) Right not to be subject to an automated decision.
(h) Right to lodge a complaint with a supervisory authority.
(j) You may have other rights under your legislation of your country of residence, including right to define the instructions relative to the outcome of your personal data after your death.
8.2 You also have a right to independently remove personal information on your account and make changes and corrections to your information, provided that such changes and corrections contain up-to-date and true information. You can also view an overview of the information we hold about you. If you reside in France you have the right to register on the list of opposition to telephone canvassing on www.bloctel.fr.
8.3 If you would like to exercise these rights, please contact Service support at email@example.com or send your request to us, in writing to 15 Dimitriou Karatasou, ANASTASIO BUILDING, 6th Floor, Room/Office 601, Strovolos, 2024, Nicosia, Cyprus. We will aim to respond to you within 30 days from receipt of request. We will need to verify your identity before we are able to disclose any personal data to you.
9. Your California Privacy Rights
9.2 If you are a California resident you have the following rights in relation to your personal information:
(a) Right to Access. If you are a California resident, you have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, and sell.
(b) Right to Delete. If you are a California resident, you have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.
(c) Process to Make a CCPA Request. To make an access or deletion request, please send your enquiries to Service support at firstname.lastname@example.org or send your request to us in writing to 15 Dimitriou Karatasou, ANASTASIO BUILDING, 6th Floor, Room/Office 601, Strovolos, 2024, Nicosia, Cyprus.
(d) Before completing your request, we may need to verify your identity or the identity of your authorized representative. We will then take action to verify your email address and may request additional documentation or information solely for the purpose of verifying your identity.
(f) Right to Non-Discrimination: You have the right not to receive discriminatory treatment for the exercise of your privacy rights conferred by the CCPA.
(g) Shine the Light Act. If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by us and our affiliates to third parties for the third parties’ direct marketing purposes. We are dedicated to treating your personal information with care and respect. For inquiries regarding our disclosure policy, you may send your enquiries to Service support at email@example.com or send your request to us in writing to 15 Dimitriou Karatasou, ANASTASIO BUILDING, 6th Floor, Room/Office 601, Strovolos, 2024, Nicosia, Cyprus.
(h) Authorized Agents. If you would like to designate an authorized agent to make a request on your behalf, please be sure the agent can (i) demonstrate you have provided written permission for the agent to submit the request on your behalf, and (ii) provide proof of his or her own identity. If the agent does not satisfy these requirements, we will deny the request.
(i) Privacy Rights for California Minors. If you are a California resident under the age of 18, California Business and Professions Code Section 22581 permits you to view, correct and request the removal of content or information you have posted to the Site, message boards, or forums. You may exercise this right you may send your enquiries to Service support at firstname.lastname@example.org or send your request to us in writing to 15 Dimitriou Karatasou, ANASTASIO BUILDING, 6th Floor, Room/Office 601, Strovolos, 2024, Nicosia, Cyprus. Note that any information posted to the message boards or forums is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive information.
Residual copies of content and/or information that have been deleted may remain on our backup servers. We do not have to remove posted content or information if it has been rendered anonymous. We may retain your information to resolve disputes, enforce our user agreements, or comply with legal requirements; in this case, your personal information will be blocked from use for any other purpose. Additionally, we do not have control over third parties (e.g., other users) who may have copied or reposted the content or information.
• The sources of personal information that we collected are: our users, directly, third party sites or platforms that you link with your registration account, analytics tools, social networks, advertising networks, and trusted sources who update or supplement information we hold about you.
• The business or commercial purposes of collecting personal information are described in the “INFORMATION WE COLLECT ABOUT YOU” Section of this Privacy.
• Although we do not sell personal information for monetary consideration, some of our partners may collect and process information when you interact with our Services, including IP addresses, digital identifiers, information about your web browsing and app usage, and how you interact with our advertising properties and ads in order to provide you with relevant ads across the Internet and for other analytics purposes, and such partners may “sell” that information to other businesses for advertising and other purposes under the definition of “sale” in the CCPA.
• As the term is defined by the CCPA, we “sold” the following categories of personal information in the last 12 months: IP addresses, Identifiers/Contact Information, Internet or other electronic network activity information, including information about your web browsing and app usage, and inferences drawn from the above. We “sold” each category to social networks (for the authorization purposes), advertising networks, data analytics providers and our infrastructure service providers.
• The business or commercial purposes of “selling” personal information is for third party companies to perform services on our behalf, like marketing, advertising, performance and audience measurement.
• We do not “sell” personal information of known minors under 16 years of age.
10. Security Measures
10.1 We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.
11. Changes to this Policy
12. Contact Us
12.2 All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.
12.3 The e-mail address of our DPO is email@example.com.
13. Privacy Notice for parents/legal guardians
13.1 We encourage parents to discuss with their children the importance of personal data protection.
13.2 We will not require a child to provide more information than is reasonably necessary in order to use the Services.
13.3 If children are under 13 years old and under applicable law a parental consent is required, use of the Services if forbidden.