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PRIVACY POLICY WBTBRIDGE.COM

Date of issue: May 12, 2024

1 PRIVACY POLICY

Thank you for joining our fair play bridge community offered on the WBTBRIDGE.COM platform by World Bridge Holding CY Limited (WBH)!


This Privacy Notice explains who we are, how we collect, share, use, and in any way process personal information about you, and how you can exercise your rights in accordance with the European General Data Protection Regulation (“GDPR”).


This Privacy Notice applies to personal information that we collect through our website, www.wbtbridge.com, our applications on the Apple and Android platforms, and our Facebook page, when you sign up for membership, play bridge with friends, join tournaments, communicate with other members, contribute with your own content, or contact us. In this privacy policy you will find information about the processing of your personal data and what rights you have in relation to the processing of your data.


If you do not accept the content of this Privacy Notice, please let us know and do not sign up for membership or use our Service.

2 How to contact us

World Bridge Holding CY Limited is the controller for the processing of your personal data. Our contact information is:

Address
E-mail
Organisation number
195 Arch. Makarios III Avenue Neocleous House
 3030 Limassol
 Cyprus
HE 342924
If you have any questions concerning the processing of your personal data, or your privacy, please e-mail us, and we will do our best to resolve the issue as soon as possible.

3 How do we process your personal data and why

The personal data we process is collected from you when you sign up for membership, communicate or connect with us via other channels like our Facebook page, from your device when you visit our website and from using our mobile application.


When you play games of bridge on the WBTBRIDGE.COM platform we store the games played and use historical game-data for statistical purposes and for detecting irregularities. We also collect data about you and your game history from our partners in the international bridge community.


We also monitor and keep logs of all other activity on the Platform. When you are signed in as a member, the activity will be related to your user profile.

3.1 Signing up for membership

When you sign up for membership in our community website, this table explain how and why we process your personal data:

Purpose
Description
Our legal basis
Identifying you and being able to set up your account, and to communicate with you.
Name, nationality, IP-address and user agent, login information including username, password and unique user ID, and e-mail address.
Contractual obligation: the processing is necessary for us to sign you up as a member and provide a user profile.
Customize and optimize our payment options and being able to transfer prizemoney
Credit card-number, bank account number
Contractual obligation: the processing is necessary for us to provide payment options and to transfer prize-money to you.
Customizing your membership if requested by you
Picture, gender, age and address
Consent

3.2 Members

When you are signed in as a member, play social games, join tournaments, and otherwise use our Service, this table explain how and why we process your personal data:

Purpose
Description
Our legal basis
Administer your membership, provide access to tournaments and being able to communicate with you.
Name, nationality, IP-address and user agent, login information including username, password and unique user ID, and e-mail address, membership status, ranking score, tournament participation history, results and technical data (e.g. bridge moves during play) and behavioural data.
Contractual obligation: Necessary for us to administer the membership according to the Terms of Use.
Customize and optimize our payment options and being able to transfer prize-money
Credit card-number Bank account number Billing address
Contractual obligation: The processing is necessary for us to provide payment options and transfer prize money to you. Credit card-number is only stored by our Payment Service Provider.
Matchmaking services
IP-address, ranking score, tournament participation history, results and technical data (e.g. bridge moves during play), behavioural data, membership- status.
Contractual obligation: Necessary to provide matchmaking as a service to you and other members in accordance with our Terms of Use.
Manage and customize your membership if requested by you.
Picture, gender and age.
Consent
Collecting activity-data to develop statistics and maintain the monitoring of fair play and being able to detect irregularities through WBH’s fair play software tool.
Behavioural data: Game history, tournament history, ranking score, result history, technical data (e.g. bridge moves during play, IP- address and browser/system information including user agent).
Legitimate interest of pursuing WBH values by providing a game platform where fair play is our main ambition.
Streaming and broadcasting tournaments.
Name, nationality, information about how you play) will be available for other players and spectators.
Contractual obligation: Necessary to provide our services according to the Terms of Use or to the terms and conditions related to the specific event to be broadcasted.

3.3 Visiting our website

When you visit the WBTBRIDGE.COM website, cookies are stored on your device (e.g. computer or phone) and the internet connection is transferred to us. Information capsules or “cookies” are small text files that are stored locally on your device and make it possible to collect data about the use of our website. The information collected through visits to our websites does not usually contain information that can identify you or other users of the device directly. You will be informed about cookies on our website in accordance with our cookie banner.

3.4 Automated decision support tool

According to our Terms of Use we have an obligation to promote fair play on a platform where irregularities will be investigated to detect unfair behaviour. We have developed a software tool based on AI-technology which is able to notify our team of irregularities. The system is based on the gaming history of individual players and connection data. This means that our systems generate a profile of you as a player for the purpose of detecting irregularities in your playing history and behavioural patterns.


The processing of member’s activity and individual gaming records is necessary for us to provide our members the quality of product which is our most important business value.


If our investigating committees find reason to impose sanctions based on their findings you will be informed and given the opportunity to review the report.

4 HOW YOUR PERSONAL DATA IS SHARED WITH THIRD PARTIES

We do not share your personal information with third parties unless we have a legal basis for transferring such data. This may be that the transfer is necessary to fulfil our agreement with you, or because it is necessary to administer your membership and deliver our services to you, or a legal obligation prescribed by law. We never sell your information to third parties. We share personal information about our members with partners within the WBH structure.

4.1 Licensees

We may share the following personal data about you to their Licensees: Name and report stating potential reason for temporarily or permanently termination of membership.


The purpose of exchange of information to the Licensees is to ensure that only valid members can participate in the Licensee tournaments. The processing is necessary to meet the requirements set out in the Terms of Use.

4.2 Bridge Organisations

We cooperate with World Bridge Federation ("WBF") and National Bridge Organisations ("NBO") around the world to promote that bridge can be carried out without irregularities. For this purpose, we will share name(s) and report(s) with cooperating bridge organisations, stating potential reasons for temporarily or permanently terminating membership.


Sharing membership status and relevant reports with Bridge Organisations is necessary for us, and for the international bridge community, to pursue our joint legitimate interest to prevent irregularities and to promote fair game, according to WBH Policies and Terms of Use, and the joint fair play policies of international and national bridge organisations.


You have a right to object to processing of personal data based on a legitimate interest pursued by us or our cooperating parties. You will be notified prior to us transferring identifiable information as described in this section.


We will not share personal information or identifiable reports of members if the content of the information is under dispute. In such cases we only share Membership status and public play records, results etc.


If a cooperating bridge organisation is located outside the EU/EEA-area (‘third countries’) we will ensure that such transfer of personal information is in accordance with GDPR Art. 45, 46 or 49.


If GDPR Art. 45 or 46 is not a relevant basis for transfer, transfer will only occur when the data subject has explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers for the data subject due to the absence of an adequacy decision and appropriate safeguards, cf. GDPR art. 49 nr. 1 (a). You have the right to withdraw a given consent, if you want to do so, please contact us as outlined in section 2.

4.3 Facebook and other Social Media Platforms

When you visit our Facebook page, Meta Inc. share statistics with us, according to the Terms and conditions of Facebook and the privacy settings in your Facebook account.


WBH and Meta Inc. are joint controllers of the processing of personal data related to our Facebook page.


We receive Facebook-statistics about our followers, including information about the number of followers, names, interactions such as likes, comments and shares, as well as aggregated demographic information (where our followers come from, what age group they belong to, etc.)


The processing is necessary to administer our Facebook-page ("WBTBRIDGE.COM") for the purpose of communicating with our members and other interested persons regarding upcoming tournaments and outcome of tournaments. The processing is based on our legitimate interests to provide you with information on Facebook in line with your wishes.


More information about the content and scope of these statistics can be found in Facebook's privacy statement.

4.4 Processors

As our activities require expertise and resources from other companies, we use processors to administer the Service and to collect, store and analyse your personal data. A processor is a service provider which process personal information on our behalf according to our instructions.


We have entered into a data processor agreement with our processors to ensure that your rights are protected and that the processing of your personal data is compliant with GDPR and other relevant data protection laws. We use suppliers as described below, to perform certain activities:

Processor
Activity
Location
Traq AS
Administration of website functionality Consent management
Norway
Irya Solutions
Provide, administer and maintain the WBT Bridge app and its functionality.
Brazil
Vugraph and other streaming- and television broadcasters
Distribute or broadcast live tournaments
USA
Hammond Software Inc.
Administration of anti-cheating and fair play monitoring tools.
USA and Canada

5 TRANSFER TO THIRD COUNTRIES

5.1 Licensees

If a Licensee is located outside the EU/EEA-area we will ensure that such transferal is in accordance with GDPR Art. 45, 46 or 49.


If GDPR Art. 45 or 46 is not a relevant basis for transfer, the transfer will only occur when the data subject has explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers for the data subject due to the absence of an adequacy decision and appropriate safeguards, cf. GDPR art. 49 nr. 1 (a).


You have the right to withdraw a given consent, if you want to do so, please contact us as outlined in section 6.

5.2 Processors and Sub-processors

Hammond Software collect activity data from our website and playing database in order to monitor the activity and detect irregularities. Hammond Services is located in USA. Due to Hammond Software’s expertise, this transfer is necessary until we have implemented the same monitoring tool on our Platform. The transfer is based on Standard Contractual Clauses and additional safeguards. Please contact us if you want further information.


Our Processors depend on certain service-providers based in USA. The transfer of personal information is based on Standard Contractual Clauses and additional safeguards which can be found on their websites.

6 YOUR PRIVACY RIGHTS

When we process your personal data, you are given the status as a data subject. This gives you the right to:

Under certain circumstances you may also restrict our processing of your personal data. You may find more information about your rights here: What are my rights? | European Commission (europa.eu).


To exercise your rights, you may contact us by sending an e-mail to info@wbtbridge.com, or by using the details provided in section 2. We will answer your request as soon as possible, no later than 30 days.


You also have the right to complain to the Norwegian Data Protection Authority, Datatilsynet, if you believe our practice is not compliant with the GDPR or you have not been able to exercise your rights.


If you want to opt out of our e-mail marketing or unsubscribe from our marketing e-mail list, you may at any time click on the unsubscribe link in the emails we send, change your preferences in your profile settings through our website login or contact us using the details provided above. Also, you may opt out by sending an e-mail to hi@wbtbridge.com.


We are relying on your consent to process some of your personal data. You have the right to withdraw your consent at any time. Please note that the withdrawal will not affect the lawfulness of the processing before the withdrawal. You can withdraw your consent by changing your privacy settings in your Member profile or by sending an e-mail to hi@wbtbridge.com.


Upon a request to terminate your membership, we will deactivate or delete your profile and your personal data from our databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

7 HOW LONG DO WE KEEP YOUR PERSONAL DATA?

Your personal information will not be stored longer than is necessary to carry out the purpose of processing, as described in this Privacy Policy. We have established different deletion rules for different types of information, and the criteria we use to define the storage time are:


If you are an active member with us, data from your profile will be stored for 12 months after last activity. You will be notified before we delete information due to inactivity.


The type of information is in question when it comes to our storing of your personal data. If we process personal data based on your consent, we delete the information based on your request – by withdrawal of consent, we delete the information as soon as possible, normally within 24 hours.

8 KEEPING CHILDREN SAFE

There are social community Services available on the Platform, and thus we need to be cautious in order to keep our young Members safe online.


To become a Member, and create an account with us, you must therefore be 13 years of age. However, children under the age of 13 are welcome to join as a Member if a parent or legal guardian applies for Membership on behalf of the child by sending an e-mail to under13@wbtbridge.com. We will keep a copy of the parental consent confirmation mail for documentation purposes.


Certain Services may require further registration details or additional information. If you are under the age of 13, some Services may require renewed confirmation from the parent or the legal guardian in charge of your profile.

9 HOW DO WE KEEP YOUR DATA SECURE?

WBH use appropriate technical and organisational measures designed to protect the personal information we collect and process. The measures we use are designed to provide the level of security we find necessary based on the risk of infringing our members’ fundamental right to privacy. Our data are kept confidential and though we may process your personal information we will not give third parties access to personal information unless such sharing is necessary for us to fulfil our agreement with you or our partners in the bridge community.

10 UPDATES TO THIS PRIVACY POLICY

We will update this policy if our services change or if it is necessary to stay compliant with relevant data protection laws.


The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible.


If we make material changes to this privacy policy, we will notify you according to the Terms of Use and by posting a newsletter on the WBTBRIDGE.COM website.





Revision History


Version 1.0. February 23, 2023


Version 1.1 May 12, 2024

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