Privacy Policy

1  Background

This Privacy Policy (Policy) applies to Across and Down WW SRL (we, us, our or WealthWords), each related entity of WealthWords, including any wholly-owned subsidiary of WealthWords, any holding company of WealthWords, any other subsidiary of such holding company, and any company in which WealthWords has a shareholding interest (together, WealthWords Group). This Policy relates to your use of any part of the Website.

The purpose of this Policy is to outline our key legal obligations regarding the collection, storage and use of personal data obtained via our website (www.wealthwords.com) and any future mobile application (together with the Website). Please read this Policy carefully before using the Website.

We hope that this Policy will help you make informed decisions about sharing your personal data with us, and ensure that our processing of personal information is sufficiently transparent.

This Policy takes effect from the time it is uploaded to the Website. We reserve the right to amend this Policy at any time.

2  What sort of data do we collect and why do we collect it?

When you submit information from which your identity can be ascertained, you are providing us with personal data which may be subject to protection under relevant privacy legislation. Typically, this information will include things like your name, contact details and IP address.

This personal data is collected and stored in a database maintained and managed by the WealthWords Group.

The primary purpose of collection is to enable WealthWords to provide to you, and to enable you to access, WealthWords’ services. For example, we may use your personal data to process and transfer your winnings.

When you use the Website or when you contact our technical support team, we may also collect personal data for training and product review and improvement purposes.

3  How do we store your personal data securely?

Your personal data is stored on a number of secure electronic storage servers. We have taken a number of steps within our organisation to protect against personal data loss, misuse, unauthorised access, modification or disclosure. We use appropriate security technology to ensure that your data is transmitted safely to us through the internet or other electronic means.

Security measures that we use may include:

  • storing personal data in a fragmented form;

  • encrypting user access details such as user names and passwords;

  • utilising third party security systems; and

  • technological protection measures to limit the ability of third parties to crawl data; and

  • secure Socket Layer (SSL) technology to protect any credit card or other payment information you provide.

WealthWords Group employees and sub-contractors who provide services to the WealthWords Group who have access to your personal data are bound by confidentiality not to disclose your personal data.

Furthermore, we take appropriate contractual and operational steps to ensure that the server host has limited access to your personal data.

WealthWords is committed to improving its security measures and developing a comprehensive security management system.

4  Who does WealthWords disclose your personal data to?

We only disclose your personal data in a manner consistent with the purpose for which it was acquired from you.

When you use the Website, we may disclose your personal data to third party service providers who assist us in the delivery of our services.

Aside from disclosures within the WealthWords Group and to third party service providers, your personal data will not be disclosed to any additional third parties without your consent.

5  Transfer of personal data outside of your country

Where a third party service provider or an electronic storage server is located outside of your country of residence, we may be required to transfer your personal data outside of that country. By using the Website, you consent to the disclosure of personal data outside of your country of residence, where necessary to facilitate the delivery of WealthWords’ services.

6  What happens if you do not provide the personal data?

If you do not consent to us collecting, storing using and processing your personal data we will be unable to provide you with our services. Please direct any concerns you may have about your personal data to the Data Protection Officer as per paragraph 9.

7  What are your rights regarding access to your personal data?

You are entitled to access your personal data held by us so that you can determine its relevance and accuracy.

Where personal data has been processed by a third party, you are also entitled to a description of the personal data processed by that third party and the purpose for which they were processing your personal data.

If you wish to make a complaint against us relating to your personal data, you can raise the complaint with our Data Protection Officer who will endeavour to respond to you within a reasonable period.

8  Internet Cookies

In addition to collecting personal data from you through the Website, we also use “cookies” to collect data from your computer or other device to assist your use of the Website and to improve the functionality of our services.

A “cookie” is a small file stored on your computer, tablet, mobile or other device (device) which allows certain information to be “remembered” by your web browser. Cookies generally allow your computer to recall and move through websites faster and easier. “Sessional cookies” are used for retaining user information for the duration of a website browsing session. “Persistent cookies” are used to retain information for repeat future uses of a website.

Cookies are able to identify your device and your history of use of the Website.

It is possible for you to set your web-browser to refuse to accept cookies; however, this may diminish the performance of the Website.

9 How to contact us

If you wish to access and/or correct your personal data, or if you wish to make a complaint regarding our use, management or storage of your personal data, please contact our Data Protection Officer as below:

Title: Data Protection Officer
Email Address: support@wealthwords.com
Our Data Protection Officer will endeavour to respond to you within a reasonable period. We reserve the right to verify your identity before responding to your request.