Privacy Policy

Last Modified: October 8th, 2020

Introduction

WillYouNtk.com is a website operated by NUTAKU ENTERTAINMENT LTD, a limited liability company organized under the laws of the Republic of Cyprus, having its head office at 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540 ("Nutaku"). Nutaku and its representatives, officers, shareholders, subsidiaries, affiliates, parents, employees, and agents (collectively "we", or "us" or "our")) provide content on the WillYouNtk.com website ("Website") and on its associated properties, games and platforms.

Please read this privacy policy carefully, as your access to and use of our Website signifies that you have read, understand and agree to all terms within this privacy policy. If you do not agree with any part of this privacy policy or our terms, please do not access or continue to use our Website or otherwise submit your personal data. We respect your privacy and are committed to protecting your personal data.

If you have any questions about our privacy practices, please see "Contact Information" below for information on how to contact us.

We collect, process and retain personal data to the extent it is necessary to provide users with our service. This privacy policy applies to information we collect:

on this Website,
in e-mail, text and other communications between you and this Website,
through mobile applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website, or
when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this privacy policy.

It does not apply to information collected by:

us offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries); or
any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified by ("Personal Information"). It does not include data that has been anonymized or pseudonymized.

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
Usage Data includes information about how you use our Website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share your data to produce and share aggregated insights that do not identify you. Aggregated data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Website feature. For example we may use your data to generate statistics about our users, to calculate the percentage of users accessing a specific Website feature, to calculate ad impressions served or clicked on, or to publish visitor demographics.

We do not collect special categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, information about your health and genetic and biometric data).

How is Your Personal Information Collected?

We use different methods to collect data from and about you including through:

Direct interactions. Information that you provide when carrying out search queries on our Website or by filling in forms on our Website, in particular at the time of registering to use our Website, subscribing to our service, posting material, taking part in surveys, entering a contest or promotion sponsored by us, when reporting a problem with our Website. or requesting further services.
Automated technologies or interactions. See "Third-party Use of Cookies and Other Tracking Technologies" for details of how we may automatically collect your personal data.
Third parties or publicly available sources. We may receive personal data about you from various third parties, for example, other websites controlled by us or members of our corporate group, our business partners or other third parties and public sources.

Information Collected Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including information such as your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information.

We also use these technologies to collect information about your online activities over time and across third-party websites or other online services ("interest-based advertising"). See "Choices About How We Collect, Use and Disclose Your Personal Information" below for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking. The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). Cookies are small text files that are stored in your web browser or downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie, and allow a website to recognize a user’s device. We currently use the following types of cookies:

Cookies that are strictly necessary: These are cookies that are required for the operation of our Website. These include, for example, cookies that enable a user to log in to our Website and to check if a user is allowed access to a particular service or content.
Analytical cookies: These cookies allow us to recognize and count the number of users and to see how users use and explore our Website. These cookies help us to improve our Website, for example by ensuring that all users are able to find what they are looking for easily.
Functionality cookies: These cookies are not essential, but help us to personalize and enhance your online experience on our Website. This type of cookies allows us to recognize you when you return to our Website and to remember, for example, your choice of language.
Targeting cookies: These cookies record the visit of a user on our Website, the pages a user has visited and the links a user has followed in order to enable us to make our Website more relevant to the users' interests.
We do not require that you accept cookies and you may withdraw your consent to our use of cookies at any time by adjusting your browser’s privacy settings. However, if you decline to accept cookies, some functionality on our Website may be disabled and you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. Cookies can be either session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires or you delete your cookies. Expiration dates are set in the cookies themselves; some may expire after a few minutes while others may expire after multiple year

Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see "Choices About How We Collect, Use and Disclose Your Personal Information".

Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also known as clear gifs, pixel tags, single-pixel gifs and web bugs) that are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. Unlike cookies, which are stored on the user’s computer hard drive, web beacons are embedded invisibly on the web pages (or in an email) and are about the size of the period at the end of this sentence. Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages or opened an e-mail, to understand usage patterns and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). We also may receive an anonymous identification number if you come to our site from an online advertisement displayed on a third-party website.

Analytics. We use third party analytics and advertising tools and technologies, in particular Google Analytics and DoubleClick provided by Google, Inc., USA ("Google"). These tools and technologies collect and analyze certain types of information, including IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and purchase history, media access control address (MAC Address), mobile unique device identifiers, and other similar information via the use of cookies. The information generated by Google Analytics and DoubleClick about your use of the Website (including your IP address) may be transmitted to and stored by Google on servers in the United States. Because we activated IP anonymization for Google Analytics and Double Click, Google will anonymize the last octet of a particular IP address. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on Website activity and managing advertising content. To learn how you can opt out from this information collection by Google see "Choices About How We Collect, Use and Disclose Your Personal Information" below.

How We Use Your Personal Data

We will only use your personal data when the applicable local law allows us to. Most commonly, we will use your personal data in the following circumstances:

For purposes of providing the services, customer management and functionality and security as is necessary to perform the services provided to you under our term and conditions and any other contract that you have with us.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purposes for Which We Use Your Personal Information

In general, we use information that we collect about you or that you provide to us, including Personal Information, for following purposes:

Provision of services: to present our Website and its contents to you, including any interactive features on our Website, and to provide you with information, products or services that you request from us; we also collect and use Personal Information to verify your eligibility and deliver prizes in connection with contests and sweepstakes;
Customization of content: to perform research and analysis about your use of, or interest in, our Website content, products, or services, in order to develop and display content and advertising tailored to your interests on our Website and other sites;
Advertising: to communicate with you about products or services that may be of interest to you either from us, our affiliates or other third parties (For more information, see "Choices About How We Collect, Use and Disclose Your Personal Information");
Analytics: to determine whether users of the Website are unique, or whether the same user is using the Website on multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages viewed, demographic patterns;
Functionality and security: to diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement;
Compliance: to enforce our terms and conditions and to comply with our legal obligations;
in any other way we may describe when you provide the information; or for any other purpose with your consent provided separately from this privacy policy.

Disclosure of Your Personal Information

We do not disclose your Personal Information except in the limited circumstances described here.

We may disclose your Personal Information to members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) to the extent this is necessary for the purposes of provision of services, customer management, customization of content, advertising, analytics, verifications, functionality and security, and compliance.
Service providers. To our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, processing credit card payments, risk and fraud detection and mitigation, providing customer service, performing business and sales analysis, customization of content, analytics, security, supporting our Website functionality, and supporting contests, sweepstakes, surveys and other features offered through our Website. These service providers may have access to Personal Information needed to perform their functions but are not permitted to share or use such information for any other purposes.
Legal successors. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Website users is among the assets transferred. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this privacy policy.

We access, preserve and share your Personal Information with regulators, law enforcement or others where we reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, (d) protect against harm to the rights, property or safety of our company, our users, our employees, or others; or (e) to maintain and protect the security and integrity of our Website or infrastructure. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We also may share aggregated information with third parties for conducting general business analysis. This information does not contain any Personal Information and may be used to develop content and services that we hope you and other users will find of interest and to target content and advertising.

Transfers of Your Personal Information to Other Countries

Whenever in the course of sharing information we transfer Personal Information to countries outside of the European Economic Area and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this privacy policy and as permitted by the applicable laws on data protection.

By using the Website you consent to the transfer of information that we collect about you, including personal information, to any country in which we, members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) or our service providers are located.

Retention of Personal Information

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Where we no longer need to process your Personal Data for the purposes set out in this Privacy Policy, we will delete your Personal Data from our systems.

Where permissible, we will also delete your Personal Data upon your request. Information on how to make a deletion request can be found under "Your Rights Related to Your Personal Information".

If you have questions about our data retention practices, please send us an e-mail at support@nutaku.net.

The period for which we keep your Personal Information that is necessary for compliance and legal enforcement purposes varies and depend on the nature of our legal obligations and claims in the individual case.

How We Protect the Security of Your Personal Information

We take appropriate security measures (including physical, electronic and procedural measures) to safeguard your Personal Information from unauthorized access and disclosure. For example, only authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your Personal Information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data.

You are responsible for maintaining the secrecy of your unique password and account information at all times. We are not responsible for circumventions of any privacy settings or security measures contained on the Website.

Choices About How We Collect, Use and Disclose Your Personal Information

We strive to provide you with choices regarding the Personal Information you provide to us.

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.
You may opt out of the DoubleClick cookie or of Google Analytics by visiting the Google advertising opt-out page or by downloading and installing the browser plug-in available at Google Analytics opt-out page.
You may opt out of interest-based advertising on mobile devices by activating the "Limit Ad Tracking" or equivalent feature offered by your mobile platform. It will transmit a signal to us and to third-parties that indicates your data should not be used for interest-based advertising.

Your Rights Related to Your Personal Information

Subject to local law, you have certain rights regarding the Personal Information we collect, use or disclose and that is related to you, including the right

to receive information on the Personal Information concerning we hold about you and how such Personal Information is used (right to access);
to rectify inaccurate Personal Information concerning you (right to data rectification);
to delete/erase your Personal Information (right to erasure/deletion, "right to be forgotten");
to receive the Personal Information provided by you in a structured, commonly used and machine-readable format and to transmit those Personal Information to another data controller (right to data portability)
to object to the use of your Personal Information where such use is based on our legitimate interests or on public interests (right to object); and
in some cases, to restrict our use of your Personal Information (right to restriction of processing).

If we ask for your consent to use your Personal Information, you can withdraw your consent at any time. Note that in case of a withdrawal of your consent you may no longer able to use several functionalities of our Website and our services.

You may, at any time, send us an e-mail at support@nutaku.net to exercise your above rights in accordance with the applicable legal requirements and limitations. If you are located in the European Economic Area, you have a right to lodge a complaint with your local data protection authority.

Note that some requests to delete certain Personal Information will require the deletion of your user account as the provision of user accounts are inextricable linked to the use of certain Personal Information (e.g., your e-mail address). Also note that it is possible that we require additional information from you in order to verify your authorization to make the request and to honor your request.

California Consumer Privacy Act Notice

As of January 1, 2020, the California Consumer Privacy Act of 2018 ("CCPA") provides California residents ("Consumer(s)") certain rights with respect to their personal information, as this term is defined under the CCPA. In addition to the rights we state under this policy and subject to the exceptions found under the CCPA, Consumers have the right to:

Opt-out of the sale of their personal information, should we sell their personal information;
Be informed of certain information concerning our collection and use of their personal information;
Request that we delete certain personal information we collected from them;
Appoint an agent to exercise their rights provided for by the CCPA, provided that a duly executed notarized power of attorney is presented and provided that the agent has information deemed sufficient to allow us to verify the identity of the Consumer in question and to locate his/her information in our systems;
Not be subjected to discrimination for the exercise of these rights. We will not deny California residents the use of our service, neither will we provide a different level or quality or services for exercising any of their CCPA rights, unless as permitted under the CCPA.

This Website does not sell nor has it sold in the past 12 months personal information to third parties for monetary or other valuable considerations. We may however disclose certain personal information with third parties, service providers and entities within our corporate group in order to enable them to perform certain services on our behalf and namely to make the Website work properly. Regardless, we respect the California residents’ right to exclude personal information from such sharing arrangements and to thereby opt-out of any future sale of their personal information.

If the CCPA is applicable to you and you would like to exercise your rights, please contact support@nutaku.net.

Changes to Our Privacy Policy

We may modify or revise our privacy policy from time to time. Although we may attempt to notify you when major changes are made to this privacy policy, you are expected to periodically review the most up-to-date version found at https://www.nutaku.net/legal/tos so you are aware of any changes, as they are binding on you.

If we change anything in our privacy policy, the date of change will be reflected in the "last modified date". You agree that you will periodically review this privacy policy and refresh the page when doing so. You agree to note the date of the last revision to our privacy policy. If the "last modified" date is unchanged from the last time you reviewed our privacy policy, then it is unchanged. On the other hand, if the date has changed, then there have been changes, and you agree to re-review our privacy policy, and you agree to the new ones. By continuing to use the Website subsequent to us making available an amended version of our privacy policy in a way that you can easily take notice of it, you thereby consent to such amendment.

Enforcement; Cooperation

We regularly review our compliance with this privacy policy. Please feel free to direct any questions or concerns regarding this privacy policy or our treatment of Personal Information by contacting us through this Website at support@nutaku.net. When we receive a formal written complaint, it is our policy to contact the complaining party regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the collection, use and disclosure of Personal Information that cannot be resolved by an individual and us.

No Rights of Third Parties

This privacy policy does not create rights enforceable by third parties or require disclosure of any Personal Information relating to users of the Website.

No Error Free Performance

We do not guarantee error-free performance under this privacy policy. We will use reasonable efforts to comply with this privacy policy and will take prompt corrective action when we learn of any failure to comply with our privacy policy. We shall not be liable for any incidental, consequential or punitive damages relating to this privacy policy.

Contact Information

If you have any questions about this privacy policy or our information-handling practices, please contact us at privacy@nutaku.net.

You may also contact us at 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540, Phone: +357 22662 320, Fax: +357 22343 282.