Privacy policy.

This Privacy Policy describes how your personal information is collected, used and shared when you visit wellch.net. Website or install and use Wellchosen Investments applications.

Wellchosen Investments WEBSITE

PERSONAL INFORMATION WE COLLECT

When you visit the Website, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

 We collect Device Information using the following technologies:

    - “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit https://www.allaboutcookies.org.

    - “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

    - “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

    - The Site is hosted on squarespace.com. For more information about use of cookies, used on squarespace.com visit squarespace.com Cookie Policy https://www.squarespace.com/cookie-policy/ and Privacy Policy https://www.squarespace.com/privacy/.

 When we talk about “Personal Information” in this Privacy Policy, we are talking also about Device Information.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with third parties to help us use your Personal Information, as described above.  For example, we use squarespace.com to power our website.  We also use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here:  https://www.google.com/intl/en/policies/privacy/.  You can also opt-out of Google Analytics here:  https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.  For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

FACEBOOK - https://www.facebook.com/settings/?tab=ads

GOOGLE - https://www.google.com/settings/ads/anonymous

BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at:  https://optout.aboutads.info/.

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser. 

YOUR RIGHTS

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you, or otherwise to pursue our legitimate business interests listed above.  Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

MINORS

The Site is not intended for individuals under the age of 13.

CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

Wellchosen Investments Applications 

When you install and use Wellchosen Investments mobile applications, we can collect and process some of your data for different legitimate purposes.

You will find below explanations regarding the reasons why Wellchosen Investments may collect data and the legal basesWellchosen Investments relies on in each case. 

Wellchosen Investments collects data: 

• To provide you with the services you asked for

  (e.g., knowing that you completed the first level to allow access to the second one)

  • Legal basis – such data processing is strictly necessary for the service(s) asked

• To run analytics and understand how users interact with our product and services in order to continuously improve it

  (e.g. identifying that a feature is annoying for users or that a level is too difficult for most gamers)

  • Legal basis - Express consent. Wellchosen Investments only processes or shares personal data collected through Wellchosen Investments mobile apps for analytics purposes once you express your consent through the pop-up notice included in our apps.

• To serve advertising tailored to the preference and interests of our users

  and allow Wellchosen Investments to continue to provide free services and products

  • Legal basis – Express consent. Wellchosen Investments only processes or shares personal data collected throughWellchosen Investments mobile applications for personalized advertising purposes once you express your consent through the pop-up notice included in one of our mobile apps.

For all data processing activities that rely on users’ consent, you can withdraw your consent at any time from the “settings” page in our various mobile applications.

Please only note that in the case where you withdraw your consent or where you refuse to consent in the first place, you will still be served with advertising but that may be less relevant to you as it will not be tailored to your interests.

What data does Wellchosen Investments collect from its mobile apps?

For all the purposes listed above the data that Wellchosen Investments collect is limited to:

• The apps you are using

• Your IP address

• Your Mobile Advertising ID (Apple IDFA or Google AAID - which are technical identifiers developed by mobile operating systems for advertising purposes which remain under your control and can be reset or erased at any time in through your device settings)

• Technical information about the device you use and your connection (user agent, type of connection, timestamp)

• Data pertaining to your activities on our applications and notably the way in which you interact with our applications (for instance, how and when you use our applications) and with the advertising served in our applications (for instance, number of ads served, potential clicks)

With who may your data be shared & why?

Wellchosen Investments does not share your personal data with third parties without your prior consent. 

When you consent to the collection of data for advertising and analytics purpose, we may share the data listed above with the following categories of recipients:

• Ad Partners: that allow us to monetize the ad inventory of our apps and provide users with free products and services.

  Those partners usually collect data via their own tools (Software Development Kits or “SDK”). You will find a list of our partners implementing advertising SDKs through our applications and the privacy policies of their services that describe their practices and allow you to exercise your rights directly toward them hereafter:

  • Adcolony -https://www.adcolony.com/privacy-policy/

  • Applovin -https://www.applovin.com/privacy/

  • Criteo -https://www.criteo.com/privacy/

  • Facebook -https://www.facebook.com/about/privacy

  • Fyber -https://www.fyber.com/privacy-policy/

  • Google -https://policies.google.com/privacy

  • Inmobi -https://www.inmobi.com/privacy-policy/

  • Ironsource -https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/

  • Mintegral -https://www.mintegral.com/en/privacy/

  • Mopub -https://www.mopub.com/legal/privacy/

  • Oath -https://policies.oath.com/in/en/oath/privacy/

  • Ogury -https://ogury.com/privacy-policy/

  • Tapjoy -https://www.tapjoy.com/legal/tapjoy-users/#privacy-policy

  • Vungle -https://vungle.com/privacy/

• Analytic companies: that provide us with tools and technologies that allow us to better understand how users interact with our services and will help us improve it. Those partners also usually collect data via their own SDKs. You will find a list of our partners implementing analytical SDKs through our applications hereafter:

  • Adjust -https://www.adjust.com/terms/privacy-policy/

  • GameAnalytics -https://policies.google.com/privacy email: privacy@gameanalytics.com

  • Google -https://policies.google.com/privacy

  • Mixpanel -https://mixpanel.com/legal/privacy-policy/

  • Tenjin -https://www.tenjin.io/privacy/

• Authorities: only to the extent we are obliged to by applicable laws and regulations.

Data deletion requests

Wellchosen Investments

To delete user data collected by Wellchosen Investments, please reach out to iod@wellch.net.

If you also want to request the deletion of the data that may have been collected about you or your device by our third-party partners that are acting as independent data controllers, you will find above the links to their privacy policies.

Voodoo

Voodoo does not collect any of your personal data, and only provides an SDK package to retrieve the data collected by the above mentioned third-party partners. You can still contact them to request the deletion of their accesses to the partners’ interfaces.

email: dpo@voodoo.io

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at iod@wellch.net or by mail using the details provided below:

 Vasili Michailidi 9, 3026 Limassol, Cyprus