Overwolf respects your right to privacy. Your ability to make informed choices about the uses of your information is important to us. This Privacy Notice explains Overwolf's policy regarding the collection, use, disclosure, retention, and protection of Personal Data. The terms of this Privacy Notice apply to information collected by Overwolf from you, unless different terms are specified as part of a special offer or in another form or contract we provide you.
Overwolf products and services may also use or offer products or services from third parties, for example, apps ("Third Party Apps") that are developed for the Overwolf platform by third parties ("Third Party App Developers"). Information collected by third parties, including by means of Third Party Apps, is governed by their privacy practices. By downloading any Third Party Apps you expressly agree to such privacy practices. We encourage you to learn about the privacy practices of those third parties.
Under the applicable laws, Overwolf is the "data controller" of personal data collected through the Services. Our registered office is 5 Jabotinsky St. Ramat Gan, Israel, 5252006 and our registration number is 514330331. Sometimes we have access to the end user information on behalf of the Third Party Apps and/or Third Party App Developers. In such cases, the applicable Third Party App Developers serves as a controller with respect to such Third Party App Developer's end user Personal Data (as defined below).
"Personal Data" means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law.
Privacy Notice Key Points
The key points listed below are presented in further detail throughout this Privacy Notice. These key points do not substitute the full Privacy Notice.
1. Information we collect. When you interact with us through the Services, we receive and store certain information, such as operational information required to provide the Services, analytical information used to improve and customize the Services for you, and diagnostic information to improve the performance and stability of the Services. You can choose to opt out from most of these via Overwolf settings, except from operational information which is required to make Overwolf work. If you choose to create an Overwolf account, you will be requested to provide us with your email address, username, and your profile picture. Signing up is not mandatory, and you can use Overwolf without an account. When you visit our websites we collect analytical information through analytics tools to improve and customize the Services.
2. How we use information. We use the information we collect and/or receive mainly to administer and provide the Services, contact you with administrative information, contact you with marketing offers (if you indicate your desire to receive them), and improve the Services.
3. Basis for processing information. Processing your information is necessary for the performance of the Terms and the provision of the Services to you. Processing for the purposes of developing new and enhancing our products and Services, for the marketing of our products and services, for analytics and usage analysis, for fraud prevention and for security and for our recordkeeping, protection of our legal rights, and complying with our legal obligations – are all necessary for the purposes of legitimate interests that we pursue.
4. Third-party service providers. Like many businesses, we sometimes use trusted third-party subcontractors and service providers to assist us in the operation of the Services, and process the information on our behalf and under our instructions. Examples of such services include, but are not limited to databases for supporting product features, analytics tools, email services, customer support services etc.
5. Advertising service providers. We work with trusted and well known advertising service providers to facilitate the integration of in-app ads by app developers. This helps app developers make a living and provide you with high quality products that are free of charge. To support the personalization of ads, limited information (app name, computer hardware summary, last played games) may be provided to the advertiser when ads are displayed. App developers may choose whether to integrate in-app ads or not. If ads are integrated, app developers may choose to support opting out of ads by offering a paid subscription plan for their app. Additionally, Overwolf is currently in the process of developing the option to opt out of ad personalization, which we expect to be available by the end of September 2020.
6. International transfer. We may use trusted third-party service providers and/or subcontractors located in countries other than your own, and may send them your Personal Data in order to provide you with the Services. We will ensure that we have agreements in place with such parties that ensure the same level of privacy and data protection as set forth in this Privacy Notice. You hereby consent to such international transfer.
7. Security. We implement industry standard measures aimed at reducing the risks of damage and unauthorized access or use of Personal Data, but they do not provide absolute information security. Such measures include physical, electronic, and procedural safeguards (such as secure servers, firewalls, antivirus and SSL encryption), access control, and other internal security policies.
8. Your rights. Subject to applicable law and additional rights as set forth below, you may have a right to access, update and/or delete your Personal Data and obtain a copy of the Personal Data we have collected about you. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Data processed for direct marketing purposes. You also have the right to object at any time to processing your personal data for certain purposes, including marketing purposes.
9. Data retention. We retain information for as long as necessary for the purposes set forth in this Privacy Notice. To determine the appropriate retention period, 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 those purposes can be achieved through other means, as well as applicable legal requirements.
11. Children. We do not knowingly collect personally-identifiable information from children under the age of eighteen (18). In the event that you become aware that an individual under the age of eighteen (18) has enrolled without parental permission, please advise us immediately.
12. Third-party applications and services. All use of third-party applications (including the Third Party Apps) or services is at your own risk and subject to such third party's privacy policies.
13. Communications. Subject to your consent and applicable law, we may send you e-mail or other messages about us or our Services. You can stop receiving future communications from us by following the UNSUBSCRIBE link located at the bottom of each communication, by emailing us at firstname.lastname@example.org or through your account settings.
14. Changes to the privacy notice. We may change this Privacy Notice from time and shall notify you of material changes.
15. Comments and questions. If you have any comments or questions about this privacy notice, or if you wish to exercise your legal rights with respect to your Personal Data, please contact us at email@example.com.
When you interact with us through the Services, we may collect information from you, as further described below:
Information we collect
When you interact with us through the Services, we receive and store certain information, as further described below:
- Operational information required to make the Services work, such as what apps you install and use, your app subscriptions, your privacy consents and settings configuration. We may also record IP addresses for fraud prevention purposes.
- Analytical information used to improve and customize the Services for you, such as information regarding how you use Overwolf and apps, and what games you play. You can opt out of this via Overwolf settings.
- Diagnostic information to improve the performance and stability of the Services, such as information about your computer hardware and how it performs when using the Services, stability and crash reports. You can opt out of this via Overwolf settings.
- Optional account information - if you choose to create an Overwolf account, you will be requested to provide us with your email address, username, and an optional profile picture. Please note that signing up is not mandatory, and you can use the Services without an Overwolf account.
- Optional billing information - using the Services is free of charge. However, some optional features may require payment. If you choose to use optional paid features, you will be requested to create an Overwolf account, and also to provide us with your billing information.
Please note that if different users use one downloaded client, we view the consent provided and/or notification made of how we process Personal Data when the client is downloaded to apply to all the different users of such a client. Please do not use such a client unless you agree to the terms of this Privacy Notice.
How we use information
We use the information we collect from and about you for any of the following purposes: (1) to provide you with the Services and provide a safe and enjoyable user experience; (2) providing customer support and processing your orders, requests, questions and concerns; (3) understand the usage trends and preferences of our users and services in order to maintain, analyze, develop, update, and improve our products and services; (4) to provide you with customized content, targeted offers, and advertising on the Service, on the Third-Party Apps, on other third-party sites or apps you may visit; (5) to contact you with informational newsletters and promotional materials relating to our Services; (6) to review the usage and operations of our Services; (7) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below), including for monetizing purposes; (8) protect against activities that may threaten the security, integrity, or availability of our or another party's products, systems, and services and address any problems with the Services (9) to satisfy our legitimate interests, while at all times ensuring that your rights and freedoms are not affected and (10) maintain corporate or business records consistent with our retention policies and applicable law.
Aggregated information is anonymous and will not be linked to any specific individual. In an ongoing effort to better understand and serve the users of the Services, we may conduct research on our customer demographics, interests and behavior based on the information collected. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate information with our affiliates, agents and business partners without restriction, under commercial terms that we can determine at our sole discretion. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
We may use your Personal Data as required or permitted by any applicable law.
We use your Personal Data based upon the following legal bases: (i) when necessary for legitimate interests we pursue; (ii) when necessary for the performance of the Terms and the provision of the Services to you; (iii) when you have consented to such processing, and (iv) when necessary to comply with a legal or regulatory obligation.
The legitimate interests we pursue when processing your Personal Data include the following purposes: (i) developing and enhancing our products and Services; (ii) for analytics and usage analysis of our Services; (iii) for the marketing of our products and services; (iv) for fraud prevention and security; and (v) for our recordkeeping and protection of our legal rights. In conducting such processing activities, we balance these legitimate interests against the rights and interests of our users. If you would like more information regarding how we make such determinations, please contact us through the contact information specified below.
Please note that we may process your Personal Data for more than one legal basis depending on the specific purpose for which we are using your Personal Data. Please contact us if you would like details about the specific legal ground we are relying on to process your Personal Data.
We will not share Personal Data with third parties or other Overwolf users without your explicit permission or according to this Privacy Notice, except when required by law, regulation, subpoena or court order.
Agents, consultants and related third parties
Like many businesses, we use third-party service providers to perform certain business-related functions. Examples of such functions include hosting of databases and servers, backend system for managing Appstore content, processing payments, product and website analytics, customer support services, remote support, email services, social marketing, CRM and sales tracking for business development backend systems, communications with app developers, writing and maintaining QA test cases.
Third-party service providers only receive data needed to provide their services to us. We require service providers to use data only in order to perform the services we have hired them to do (unless otherwise required by law). We prohibit our service providers from selling data they receive from us or receive on our behalf. For example, we may use a company to provide us a ticketing system for the purpose of customer support. The information they may receive as part of providing that support system cannot be used by them for anything else. For more information about our service providers, please see our Third-party sub-processors page.
Advertising service providers
The Overwolf platform supports the display of ads within the Services and Third-Party apps. This helps Third Party App Developers make a living off their creations, and continuously maintain high quality products that are free of charge. It is up to the developer of the app to decide whether to include ads within the app or not. App developers must comply with Overwolf’s strict guidelines to ensure that ads never interfere with the gaming experience.
The Overwolf platform also supports opting out of in-app ads, by providing app developers the option to integrate a paid subscription plan for their app. It is up to the developer of the app to decide whether to include a subscription plan for the app or not.
To facilitate the delivery of ads within the Services and Third Party Apps, Overwolf uses trusted and well known third-party advertising service providers. For more information about the advertising service providers we work with, please see our Advertising service providers page.
Advertising service providers may personalize the ads they deliver to make them more relevant to you. This is based upon information they collect independently, and is stored in cookies by them. In addition, to support personalization of in-app ads, Overwolf may provide limited information to advertising service providers when they deliver ads. This information includes the name of the app where the ad is displayed, the last three games played on the computer, and some hardware information such as a description of the installed CPU, GPU and peripherals.
Overwolf is currently in the process of developing the option to opt out of ad personalization. We plan to have this option available by the end of September 2020.
Third Party App Developers
Third Party App Developers using our SDK or API will have access to their end users' data, including, but not limited to game data, device information, connected hardware, played games, captured media, etc. We required the Third Party App Developers to use such data only to provide the SDK/API functionality within their applications and/or services.
In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this Privacy Notice.
We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, regulation, subpoena, court order or other law enforcement obligations (ii) protect and defend the rights or property of the Company or Related Companies, (iii) to protect the rights, property or safety of third parties (iv) protect the personal safety of users of the Services or the public, or (v) protect against legal liability.
If you choose to post information on any of our online venues such as our Forums, Blogs, Social media pages, the Overwolf Appstore, etc. please remember that any information disclosed in these venues may be automatically made public, and by posting it you provide your consent to its disclosure. You should exercise caution when disclosing any information (including Personal Data) in such venues, as you do not know who will access or use such information and for what purposes.
We use subcontractors and service providers and have business partners and affiliates who are located in countries other than your own, as set forth above and send them information we receive (including Personal Data). We conduct such international transfers since we use trusted service providers located in different countries. We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice, including appropriate remedies in the event of the violation of your data protection rights in such a third country.
Whenever we transfer your Personal Data to third parties based outside of the European Economic Area (EEA), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EEA.
- Where we use providers based in the US, we may transfer data to them if they have been certified by the EU-US Privacy Shield which requires them to provide similar protection to Personal Data shared between Europe and the US or any other arrangement which has been approved by the European Commission.
Please contact us the contact information listed below if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
You hereby consent to such international transfer described above.
We make efforts to follow generally accepted industry standards to protect the Personal Data submitted to and collected by us, both during transmission and once we receive it, including by implementing the below:
Safeguards - The physical, electronic, and procedural safeguard we employ to protect your data include secure servers, firewalls and SSL encryption of data.
Access Control - We dedicate efforts for a proper management of system entries and limit access only to authorized personnel on a need to know basis of least privilege rules, regularly review permissions and revoke access immediately after employee termination.
Internal Policies - We maintain and regularly review and update our privacy related and information security policies.
Personnel - We require new employees to sign non-disclosure agreements according to applicable law and industry customary practice.
Encryption - We encrypt the data in transit using secure SSL protocols.
Database Backup– Our databases are backed up on a periodic basis for certain data and which are verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity and are tested regularly to ensure availability, and are accessed only by authorized personnel.
However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
You have certain rights in relation to the Personal Data that we hold about you, as detailed below. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:
- Right of Access and Data Portability. You have a right to know what Personal Data we collect about you and, in some cases, to have the information communicated to you. Subject to the limitations in applicable law, you may be entitled to obtain from us a copy of the Personal Data you provided to us (excluding information that we obtained from other sources) in a structured, commonly-used, and machine-readable format, and you may have the right to (request that we) transmit such Personal Data to another party. If you wish to exercise this right please contact us letting us know what information in particular you would like to receive and/or transmit. Subject to applicable law, we may charge you with a fee. Please note that we may not be able to provide you with all the information you request, for instance, if the information includes Personal Data about another person. Where we are not able to provide you with information that you have asked for, we will endeavor to explain to you why. We will try to respond to any request for a right of access as soon as possible.
- Right to Correct Personal Data. Subject to the limitations in applicable law, you may request that we update, correct or delete inaccurate or outdated Personal Data and/or that we suspend the use of Personal Data, the accuracy of which you may contest, while we verify the status of that Personal Data. We will correct your Personal Data within a reasonable time from the receipt of your written request thereof.
- Deletion of Personal Data ("Right to Be Forgotten"). In certain circumstances you have a right to have Personal Data that we hold about you deleted. Should you wish to have any Personal Data about you deleted, please contact us, using the contact information specified in this Privacy Notice. Subject to applicable law, we will delete Personal Data provided to us by a user within a reasonable time from the receipt of a written (including via email) request by such user to delete such collected Personal Data. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Data, you should terminate your account with us and clear our cookies from any device where you have used our Services. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, as well as other purposes, all as permissible and/or required under applicable law. We may also retain your information in an anonymized form.
- Account Deactivation. You can ask us to deactivate your account by contacting us using the information below. In order to deactivate your account, we may ask you for additional information.
- Right to Restrict Processing. You may request at any time that we limit the processing of your Personal Data if you believe that either: (i) the Personal Data is inaccurate and wish us to limit processing until we verify its accuracy; (ii) the processing is unlawful, but you do not wish us to erase the Personal Data; (iii) we no longer need the Personal Data for the purposes for which it was collected, but you still need it for the establishment, exercise, or defense of a legal claim; (iv) you have exercised your Right to Object (below) and we are in the process of verifying our legitimate grounds for processing. We may continue to use your Personal Data after a restriction request either: (a) with your consent; (b) for the establishment, exercise or defense of legal claims; or (iii) to protect the rights of another natural or legal person.
- Direct Marketing Opt Out. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Data processed for direct marketing purposes. If you do, please notify us by contacting us as detailed in this Privacy Notice. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.
- Right to Object. Subject to applicable law, you may have the right to object to processing of your Personal Data including for the purpose of direct marketing.
- Withdrawal of Consent. You may withdraw your consent in connection with any processing of your Personal Data based on a previously granted consent.
- Supervisory Authority. If you are a European Citizen, you may have the right to submit a complaint to the relevant supervisory data protection authority.
Subject to applicable law, we retain information as necessary for the purposes set forth above. We may delete information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth in this Privacy Notice. We may also retain your information in an anonymized form. In addition, retention by any of our processors may vary, in accordance with the processor's retention policy.
To determine the appropriate retention period, 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 those purposes can be achieved through other means, as well as applicable legal requirements.
Please contact us through the contact information listed below if you would like details regarding the retention periods for different types of your Personal Data.
Overwolf does not knowingly collect Personal Data from children under the age of 18, and you must be 18 years of age or older in order to install and use Overwolf. Parents are able to install Overwolf for and/or set up Overwolf accounts for their children. In this way verifiable parental consent is required in order to register a child under the age of 18 to be enrolled to Overwolf product and services, and any parent setting up an account for his or her child hereby represents and warrants that he or she is the parent or legal guardian of such child, and has the authority to provide information and render consents on behalf of such child. In the event you become aware that an individual under the age of 18 has enrolled without parental permission, please advise us immediately.
Subject to your consent and applicable law, we may send you e-mail or other messages and/or a newsletter about us or our Services. You will be given the opportunity to unsubscribe from commercial messages and stop receiving future communication from us by following the UNSUBSCRIBE link in any such email or message, by emailing us at firstname.lastname@example.org, as well as through your account settings. Please note that we reserve the right to send you service-related communications, including service announcements and administrative messages relating to your account, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications you may cancel your account.
When visiting the Services, you shall be asked to accept the terms of this Privacy Notice. If you do not agree with the terms hereof, please do not use the Services. Overwolf may update this Privacy Notice from time to time, and will post the updated Privacy Notice on this page. Please come back to this page every now and then to make sure you are familiar with the latest version. Your continued use of the Services after any changes or revisions to this Privacy Notice shall indicate your agreement with the terms of such revised Privacy Notice.
If you have any comments or questions about our Privacy Notice please contact us at email@example.com.