Privacy Policy
Last Updated April 15, 2024
General Information
Protecting your personal information is our priority. This privacy policy (“Policy”) describes the data practices of What Is This Studio Ltd. (collectively, “we”, “us,” “our,” or “Company”), covering the website “https://wits.academy/” (the “Website”), the game known as What Is This Sorcery (WITS) (the “Game”), and any other Company products, software applications, and other data processing activities (collectively “Services”). By using the Services, entering into agreements with Company, or otherwise communicating with Company, you are consenting to this Policy and the processing of your data in the manner set forth in this Policy. This Policy should be read in conjunction with the Company’s Terms of Service, as amended from time to time (the “Terms”), which are incorporated herein by reference. If you do not agree with the terms set forth in this Policy or the terms and conditions set forth in the Terms, please do not use the Services or submit any communications to Company.
THE SERVICES ARE NOT INTENDED FOR CHILDREN. IF YOU ARE NOT AT LEAST 13 YEARS OLD (OR 16 IN CERTAIN APPLICABLE JURISDICTIONS), THEN YOU MAY NOT USE OR ACCESS SERVICES IN ANY MANNER.
We reserve the right to change this Privacy Policy at any time in our sole discretion. We will provide you with notice of such a change. Notice of any changes to the Privacy Policy will be accomplished upon Company sending you an email to the address listed in your account notifying you of such changes and/or Company announcing such changes through the Services. Such changes will go into effect immediately upon your access of the Services after you are given notice, as described herein. Your continued use of the Services following the notice of any changes to this Privacy Policy constitutes your acceptance of such changes. Any information collected by the Services will be dealt with in accordance with the version of this Privacy Policy that was in place at the time of collection.
1. Information Collected
a. User Provided Information
To provide users (“Users”), with the best possible experience, we may collect personally identifiable information (“Personal Information”). Personal Information is any information that can be used to identify you or your household or to contact you online or offline and includes, but is not limited to, your name, address, email, and phone number. The Services may collect Personal Information when it is provided to us, such as when you use our Services or attempt to contact us.
b. Information that is Automatically Collected
Our hosting service providers may collect Personal Information such as your Internet Protocol (“IP”) address. Except for the IP addresses that our hosting service provides may collect as described above, we do not collect analytics data that contains Personal Information.
c. Categories of Personal Information We Collect
Category Number Category Examples
1 Identifiers Your name, username, and email address are collected when you create an Account with us.
2 Information that identifies, relates to, or can be associated with a particular individual Your name, email address, social media handles, and any identifiers or similar information contained in communications sent by you or in your accounts on the Third-Party Platforms and any information contained therein.
3 Commercial information
Records of personal property, products, or services purchased, or other purchasing histories or consuming tendencies.
4 Internet activity and electronic network information Our hosting providers may collect IP addresses.
d. Third-Party Application Account
By setting up an account (“Account”) on the Services via the Epic Games Store (“Third-Party Platforms”) you are choosing to share information between your Account and your account on the Third-Party Platform. Through this option, you may choose to have Personal Information and other content about you available from Third-Party Platforms transmitted and shared through the Services. Similarly, you may choose to have Personal Information and other content about you available from your Account transmitted to and shared through the Third-Party Platform.
By setting your Account to interact with Third-Party Platforms, including by accessing your Account through your Third-Party Platform account, you agree to share information (including Personal Information) between Company and such Third-Party Platform, for the purposes provided under this Policy.
The Third-Party Platform’s use of information, including Personal Information, made available by Company is governed by that Third-Party Platform’s privacy policy and controlled by that Third-Party Platform, not by this Policy nor Company.
When you connect to the Third-Party Platform account through the Services for the first time or otherwise make the Services interact with your Third-Party Platform, account, you may be asked by the Third-Party Platform to permit the Third-Party Platform to share your Personal Information stored on such Third-Party Platform with Company. We collect your Personal Information from your Third-Party Platform account only in accordance with the permissions granted by you. Such Personal Information may include your name, email address, list of friends, profile picture and other information available via the applicable Third-Party Platform. You understand and agree that the Services may access, make available and store such Personal Information so that it is available on and through your Account, until your Account is deleted.
Please note that certain Personal Information, which you have defined as private on your Third-Party Platform accounts may become public to other users through the Services once you have allowed the Third-Party Platform to share such information with Company.
e. Payment Processors
We may obtain certain information or Personal Information about you from third-party payment processors (“Payment Processors”) through which you purchase Company’s goods or Services including, without limitation, PayPal and Moonpay. You acknowledge and agree that disconnecting your Account from a Payment Processor may affect your use and complete enjoyment of the Services.
We may share your name, address, and other Personal Information with Payment Processors to process and distribute payments. For information on how PayPal and Moonpay use your Personal Information, you may consult PayPal and Moonpay’s privacy policies.
f. Unity
Unity may process certain information as contemplated by Unity’s terms of service and privacy policy.
2. Information From Children
We do not knowingly collect or maintain Personal Information from persons under 13 years of age (or 16 in certain applicable jurisdictions). If we learn that Personal Information of persons under 13 years of age (or 16 in certain applicable jurisdictions) has been collected on or through the Services, we will take the necessary and appropriate steps to delete the Personal Information.
3. How Company Uses Your Personal Information
We use the information we collect from our Services to provide, fulfill, maintain, protect, and improve our Services, to develop new Services and offerings, and to protect us and our users.
Personal Information is primarily used to provide you the Services or for legitimate business purposes, such as for sending you occasional communications and updates, responding to inquiries, logins, and providing and maintaining the Services. When you contact us, we may keep a record of your communication as well as the other information to help solve any issues you might be facing. We may use your email address to inform you about our Services, such as letting you know about changes or improvements. For more information on how we use your Personal Information, see Section 1.
4. How Company Shares Information with Third Parties
WE DO NOT SELL OR LEASE YOUR PERSONAL INFORMATION OR SHARE YOUR PERSONAL INFORMATION FOR THE PURPOSE OF CROSS-CONTEXTUAL BEHAVIORAL ADVERTISING. FURTHER, WE DO NOT USE YOUR INFORMATION TO CREATE PROFILES INCLUDING PROFILES FOR THE PURPOSE OF AUTOMATED DECISION MAKING.
However, there are certain circumstances in which we may transfer your Personal Information to third parties, without further notice to you.
We share Personal Information with companies, outside organizations, and individuals for the limited reasons, outlined below:
a. With your consent - We will share Personal Information with companies, outside organizations or individuals if we have your consent to do so.
b. For external processing - We provide Personal Information to our affiliates, service providers, processors, or other trusted businesses or persons to process it for us, based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures. We may share Personal Information with companies that provide services to us, including companies that assist us with hosting, payment processing, providing data process services, providing analytics services, account management, technical support, marketing, measurement, and similar services.
c. For legal reasons - We will use and/or share Personal Information with companies, outside organizations, or individuals if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process or enforceable governmental request, detect, prevent, or otherwise address fraud, security or technical issues, or protect against harm to the rights, property, or safety of our users or the public as required or permitted by law.
d. In case of a sale or asset transfer - If we become involved in a merger, acquisition or other transaction involving the sale of some or all our assets, user information, including Personal Information collected from you through your use of our Services, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you, either through email and/or a prominent notice on the Services.
e. To send you updates regarding our Services.
f. We may disclose your Personal Information to our owners, employees, and third-party contractors for the purpose of understanding user behavior and using such information to improve the Services.
g. We may disclose your Personal Information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (i) conform to the edicts of the law or comply with legal process served on Company; (ii) protect and defend the rights or property of Company; and/or (iii) act under exigent circumstances to protect the personal or economic safety of users, or the general public.
h. Notwithstanding the foregoing, we may disclose your Personal Information to other third parties with your consent and direction to do so. When you broadcast information to third-party services, such information is no longer under our control and is subject to the terms of use and privacy policies of such third parties.
In the past 12 months, we have shared the following Personal Information for the purposes described herein:
Category 1: Identifiers
Category 2: Information that identifies or can be associated with a particular individual
Category 3: Commercial information
Category 4: Internet or electronic network activity information
5. More on Third Parties
While we strive to work with reputable companies with good privacy practices, this Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed or linked to you on the Services. We also do not control the privacy policies and your privacy settings with third parties, including social networks and ad networks. We encourage you to be aware when you leave the Services and to read the privacy statements of any other site or application that collects Personal Information.
6. Security of your Personal Information and Data Transfer
We will take reasonable and appropriate security measures to protect your Personal Information from unauthorized access, disclosure, alteration, or destruction. Unfortunately, no data transmission over the Internet or any mobile or wireless network is 100% secure. As a result, while we strive to protect your Personal Information, you agree and acknowledge that: (i) there are security and privacy limitations inherent to the Internet and wireless and mobile networks which are beyond our control; and (ii) security, integrity, and privacy of all information and data exchanged between you and Company cannot be guaranteed. We recommend that you do your part in protecting your Personal Information. This includes guarding against unauthorized access to your email and social media accounts including via 2-factor authentication, if applicable, by ensuring no one else uses your device or computer when you are logged in, by logging off from the Services when they are not in use, by keeping your password and other Personal Information confidential, and by taking precautionary steps to guard the physical safety and security of your device or computer.
Our Services are located in the United States and your Personal Information may be transferred or stored in the United States. The data protection laws and rules in the United States may be different than those where you live. We rely on various legal mechanisms to help lawfully support transfers of information outside the country of collection where appropriate. To the maximum extent permitted by applicable law, you hereby authorize Company to process your information in the United States or any other locations where we operate.
7. How Long Will Your Information Be Stored
We generally store Personal Information for as long as we need it to accomplish the business purpose for which such Personal Information is processed. Notwithstanding the foregoing, we may retain your Personal Information where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8. Email Communications
From time to time, we may contact you via email for the purpose of providing updates, announcements, alerts, confirmations, surveys, and/or other general communication regarding the Services. To improve the Services, we may receive a notification when you open an email from Company or click on a link therein.
You may opt out of the receipt of these communications at any time by following instructions in each email, by clicking on the UNSUBSCRIBE button, and/or by emailing us at privacy@wits.academy.
9. Merger or Sale
The information collected pursuant to this Policy, including Personal Information, is considered an asset of Company. In the event Company or some or all of the assets related to the Services are acquired by another entity through a sale, merger, or some other change of ownership transaction, Company reserves the right to transfer or assign the information, collected pursuant to this Privacy Policy.
10. Contact Information
We welcome your questions or comments regarding this Privacy Policy. If you believe that we have not adhered to this Privacy Policy, or if you have any other questions or concerns regarding this Privacy Policy please contact privacy@wits.academy.