This privacy policy (“Privacy Policy” or “Policy”) describes how Overwolf, Ltd. (collectively with its affiliates and subsidiaries shall be referred to as “Overwolf”, “we”, “us”, or “our”), collects, uses and discloses certain information, including Personal Data (as defined hereunder) of its website visitors, available at: https://www.overwolf.com/("website" and "user", "you" or "your", respectively), all as detailed hereunder. 

This Privacy Policy constitutes an integral part of our >Overwolf Website Terms of Use (collectively the “Terms”), and provides you with information regarding what Personal Data do we collect and for what purposes, our data processing operations, the lawful basis pursuant to which we process your Personal Data, third parties to whom Personal Data will be transferred, data retention periods, etc. This Privacy Policy also describes how you may exercise your rights, where and to the extent applicable under relevant privacy legislation, including the EU General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act of 2018 and as amended by the California Privacy Rights Act of 2020 effective January 1, 2023 (“CPRA”) (collectively “CCPA”) (the GDPR and CCPA together “Privacy Legislation”). 

Definitions used herein but not defined herein shall have the meaning ascribed to them in the Terms or the relevant Privacy Legislation. 

You are not required by law to provide us with any Personal Data. Sharing your Personal Data with us is entirely voluntary. However, without your data, we would not always be able to provide you with all or some of our services.

Further, please note that this Privacy Policy governs solely the use of our informative and promotional website and landing pages. This Privacy Policy shall not apply in the following cases and on the following of Overwolf services:

• YOU ARE AN END USER THAT USES THE OVERWOLF PLATFORMS (AS SUCH TERMS DEFINED WITHIN THE OVERWOLF PLATFORM TERMS OF USE), OR USING ANY OTHER APPLICATIONS THAT WERE DEVELOPED AND OWNED BY OVERWOLF AND DISTRIBUTED THROUGH OUR PLATFORMS;  
• A DEVELOPER THAT USES THE OVERWOLF DEVELOPER PLATFORMS (AS SUCH TERM IS DEFINED IN THE OVERWOLF DEVELOPERS TERMS AND CONDITIONS), AND THE OVERWOLF SOFTWARE WHICH ENABLES INTEGRATION OF APPS; 
• A MOD AUTHOR THAT USES THE OVERWOLF CURSEFORGE PLATFORM (“CURSEFORGE”) FOR THE CREATION AND DISTRIBUTION OF GAME MODS (AS SUCH TERM IS DEFINED IN THE  OVERWOLF MOD AUTHORS TERMS AND CONDITIONS; 

If you are any of the above, please see our applicable Privacy Policies applicable on the respective service for more information on how your personal information will be collected and processed by us for providing these services to you. 

1. POLICY AMENDMENTS

We reserve the right to amend this Privacy Policy from time to time, at our sole discretion. The most recent version of the Privacy Policy will always be posted on the website and the update date will be reflected in the “Last Modified” heading. We will provide notice to you if these changes are material, and, where required by applicable law, we will obtain your consent. Any amendments to the Privacy Policy will become effective within 30 days upon the display of the modified Privacy Policy. We recommend you review this Privacy Policy periodically to ensure that you understand our most updated privacy practices.

2. CONTACT INFORMATION AND DATA CONTROLLER INFORMATION

Overwolf, Ltd. incorporated under the laws of Israel, is the Data Controller (as such term is defined under the GDPR or equivalent Privacy Legislation) of your Personal Data collected through this website.

You may contact us and our privacy team as follows: 

For any question, inquiry or concern related to this Privacy Policy or the processing of your Personal Data, you may contact our privacy team as follows: 

Data Protection Officer: [email protected]

Overwolf, Ltd.

Sapir Tower, 40 Tuval St. Ramat Gan, Israel, 5252247.

Representative for data subjects in the EU and UK Contact Information:

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g., requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website. https://prighter.com/q/13682628040.

3. THE TYPES OF PERSONAL DATA WE COLLECT, PURPOSE OF USE AND LAWFUL BASIS FOR PROCESSING PERSONAL DATA

You can find here information regarding the data sets we collect, the purposes for which we process your data as well as our lawful basis for processing, and how the data is technically processed. In general, we may collect two types of information from you, depending on your interaction with us: 

"Non-Personal Data"

During your interaction with our website, we may collect aggregated, non-personal non-identifiable information which may be made available or gathered via your access to and use of our website (“Non- Personal Data”). We are not aware of the identity of the user from which the Non-Personal Data is collected. The Non-Personal Data which is being collected may include your aggregated usage information and technical information transmitted by your device such as: type of browser, internet service provider (ISP), operating system type and version, mobile network information, device settings (e.g. default language), etc.

"Personal Data"

We may also collect from you, during your access or interaction with our website, individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Data” or “Personal Information”).

For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists. 

We do not knowingly collect or process any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person's health or data concerning a person’s sex life or sexual orientation (“Special Categories of Personal Data”). 

The table below details the processing of Personal Data, the purpose, lawful basis and processing operations:

4. HOW WE COLLECT YOUR INFORMATION:

Depending on the nature of your interaction with the website, we may collect information as follows:

Automatically – we may use cookies (as elaborated below) or similar tracking technologies to gather some information automatically when you interact with our website.

Provided by you voluntarily – we will collect information if and when you choose to provide us with the information such as contact us communications, applying for a job, etc.

COOKIES AND SIMILAR TRACKING TECHNOLOGIES:

We use “cookies” (or similar tracking technologies) when you access our website. The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, as well as for statistical purposes, analytic purposes and for advertising and marketing purposes. For more information please read our Cookies Policy HERE.   

5. DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:

We may share your Personal Data with third parties, including between our partners or service providers. You can find here information about the categories of such third-party recipients.

Where we share information with services providers, agents and partners, we ensure they only have access to such information that is strictly necessary in order to enable us to operate and provide the website. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations (such service providers may use other Non-Personal Data for their own benefit).

6. USER RIGHTS:

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights and controls in connection with your Personal Data. Depending on your relationship with Overwolf, data protection and privacy laws provide you with some of the following principal rights regarding your Personal Data, including (and depending on your jurisdiction): (i) the right to access your Personal Data that we process; (ii) the right to ensure your Personal Data is accurate, complete and up to date; (iii) the right to have your Personal Data amended (by correcting, deleting or adding information); (iv) the right to object to the processing of your Personal Data, to the extent applicable; (v) the right to withdraw consent, subject to legal or contractual restrictions and reasonable notice; (vi) the right to non-discrimination and (vii) the right to cease sharing or selling your Personal Information as such term is defined under the CCPA (if applicable, and as further detailed in our CCPA Privacy Notice.

You may exercise any or all of your above rights in relation to your Personal Data by filling out the Data Subject Request (“DSR”) by using the following link: https://support.overwolf.com/en/support/tickets/new or by sending us an e-mail to [email protected]. 

When you contact us and request to exercise your rights regarding your Personal Data, we will require certain information from you in order to verify your identity and locate your data, the process of locating, and deleting the data may take reasonable time and effort, as required or permitted under applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply. 

You have the right to lodge a complaint with the EU Member State supervisory authority if you are not satisfied with the way in which we handled the complaint. 

For additional rights under various jurisdictions, please refer to Section 12 “JURISDICTION-SPECIFIC NOTICES” herein below. 

Certain rights can be easily executed independently by you without the need to fill out the DSR Form:

• You can opt-out from receiving our marketing emails by clicking the “unsubscribe” link;
• you can withdraw consent for processing Personal Data for analytics or marketing purposes, by using the cookie setting on the website.

Use the Global Privacy Control (“GPC”) signals.

You can also opt out of interest-based advertising with some of the service providers we use, such as Google HERE, Google Analytics HERE.

7. DATA RETENTION:

In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you will express your preference to opt-out, where applicable. 

Other circumstances in which we will retain your Personal Data for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice of our intention to do so.

SECURITY MEASURES:

We work hard to protect Personal Data we process from unauthorized access or unauthorized alteration, disclosure or destruction. We have implemented physical, technical and administrative security measures for the website that comply with applicable laws and industry such as: encryption using SSL, we minimize the amount of data that we store on our servers, restrict access to Personal Data to Overwolf employees, contractors and agents, etc. Note that, we cannot be held responsible for unauthorized or unintended access that is beyond our control, and we make no warranty, express, implied or otherwise, that we will always be able to prevent such access.

Please contact us at: [email protected] if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy or if you become aware of a third party's attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

8. INTERNATIONAL DATA TRANSFER:

Our data servers in which we host and store the information are located in the US. Overwolf's HQ are based in Israel in which we may access the information stored on such servers or other systems such as Overwolf’s ERP, CRM and other systems. In the event that we need to transfer your Personal Data out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Furthermore, when Personal Data that is collected within the European Economic Area ("EEA") is transferred outside of the EEA to a country that has not received an adequacy decision from the European Commission, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union. Thus, we will obtain contractual commitments and or assurances from the data importer to protect your Personal Data, using contractual protections that EEA and UK regulators have pre-approved to ensure your data is protected (known as standard contract clauses), or rely on adequacy decisions issued by the European Commission. Some of these assurances are well recognized certification schemes.

9. ELIGIBILITY AND CHILDREN PRIVACY:

This website is not intended for use by children (the phrase "child" shall mean an individual that is under the age defined by applicable law which with respect to the EEA is under the age of 16 and with respect to the US, under the age of 13) and we do not knowingly process children’s information. We will discard any information that we receive from a user that is considered a "child" immediately upon our discovery that such a user shared information with us. Please contact us at: [email protected] if you have reason to believe that a child has shared any information with us.

10. JURISDICTION-SPECIFIC NOTICES:

Additional Information for California Residents

This section applies only to California residents. Please see the CCPA Privacy Notice, which discloses the categories of Personal Information collected, purpose of processing, source, categories of recipients with whom we share the Personal Information for a business purpose, whether the Personal Information is sole or shared, the retention period, and how to exercise your rights as a California resident.

Additional Information for Colorado Residents

This section applies to Colorado residents acting only as an individual or household context (and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context). Pursuant to the Colorado Privacy Act (“CPA”) please see below the disclosure of the categories of Personal Data that are collected or processed, the purposes, how consumers can exercise their rights, and appeal such decision, categories of third-parties the controller shares or sells the Personal Data, or sells the Personal Data for advertising and how to opt-out.

“Personal Data” as defined in the CPA means information that is linked or reasonably linkable to an identified or identifiable individual and does not include publicly available information that is lawfully made available from government records, or that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; or information excluded from the CPA scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) or 42 CFR Part 2- “Confidentiality Of Substance Use Disorder Patient Records”, Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or and the Driver’s Privacy Protection Act of 1994, Children’s Online Policy Protection Act of 1998 (COPPA), Family Educational Rights and Privacy Act of 1974, national Security Exchange Act of 1934, higher education data and employment data.

“Sensitive Data” include (i) racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life or sexual orientation; (ii) Genetic or biometric data that can be processed to uniquely identify an individual; or (iii) child data. 

Under CPA, Overwolf needs to provide a privacy notice that identifies the categories of Personal Data that are collected or processed, the purposes, how consumers can exercise their rights, and appeal such decision, categories of third-parties the controller shares or sells the personal data, or sells the Personal Data for advertising and how to opt-out.

Highlights Sections

In Section 3  to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 5 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. Section 6 to this Privacy Policy details and discloses your rights and Personal Data shared or sold for targeted advertising. 

Deletion Right Exemptions

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete your Personal Data. If the request is submitted by someone other than you, proof of authorization (such as power of attorney or probate documents) will be required. The deletion right is not absolute and in certain circumstances we may deny such request. We may deny your deletion request, in full or in part, if retaining the information is necessary for us or our service provider(s) for any of the following reasons: (1) complete the transaction for which we collected the Personal Data or Personal Information, provide the service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (2) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (3) debug products to identify and repair errors that impair existing intended functionality; (4) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (5) comply with the law or legal obligation; (6) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; (7) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (8) make other internal and lawful uses of that information that are compatible with the context in which you provided it. We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our processors to take similar action.

Response Timeline

We will respond to your request within 45 days after receipt of a verifiable Consumer Request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at: [email protected] and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Colorado AG at: https://coag.gov/file-complaint/.

If you have an account with us, we may deliver our written response to that account or via email at our sole discretion. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You do not need to create an account for submitting a request. 

Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 

ADDITIONAL INFORMATION FOR CONNECTICUT RESIDENTS

Under the Connecticut Data Privacy Act, Public Act. No. 22-14 (“CDPA”) if you are a resident of Connecticut, acting in an individual or household context (and not in a commercial or employment context or as a representative of business, non-profit or governmental entity), your rights with respect to your personal data are described below.

“Personal Data” means any information that is linked or reasonably linkable to an identified or identifiable individual and does not include publicly available information that is lawfully made available from government records, or that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; or information excluded from the CDPA scope, such as: HIPAA, GBPA, non-profit entities, higher education, employment data and FCRA, Driver's Privacy Protection Act of 1994, Family Educational Rights and Privacy Act, Farm Credit Act. 

“Sensitive Data” means data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life, sexual orientation, citizenship, or immigration status; The processing of genetic or biometric data for the purpose of uniquely identifying an individual; Personal data collected from a known child; Precise geolocation data. In certain cases, we will process precise geolocations data if you explicitly enable the GPS permission within our properties. 

Under CDPA, Overwolf is required to provide you with a clear and accessible privacy notice that includes: categories of Personal Data processed, purpose of processing, instructions for exercising consumer rights and appealing decisions, categories of Personal Data shared with third parties, categories of third parties with whom data is shared, and any sale of data or targeted advertising.

Please read the “Highlights Sections” and “Deletion Right Exemptions” paragraphs under the CPA Additional Information.

Response Timeline

We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests and we inform you of such extension within the initial 45 day response period, together with the reason for the extension.

If we decline to take action on your request, we shall so inform you without undue delay, within 45 days of receipt of your request. The notification will include a justification for declining to take action and instructions on how you may appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Connecticut Attorney General at link: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

ADDITIONAL INFORMATION FOR VIRGINIA RESIDENTS

Under the Virginia Consumer Data Protection Act, as amended (“VCDPA”) if you are a resident of Virginia acting in an individual or household context (and not in an employment or commercial context), you have the following rights with respect to your Personal Data.

“Personal Data” means any information that is linked or reasonably linkable to an identified or identifiable natural person, and does not include publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; Information excluded from the VCDPA scope, such as: HIPAA, GBPA, non-profit entities, higher education, employment data and FCRA, Driver's Privacy Protection Act of 1994, Family Educational Rights and Privacy Act, Farm Credit Act. 

The VCDPA requires Overwolf to disclose the categories of Personal Data processed, purpose of processing, how you can exercise your rights, including how a you may appeal our decision with regard to the consumer request, the categories of Personal Data shared with third parties and with whom, and if Overwolf sells Personal Data to third parties or processes Personal Data for targeted advertising. 

Please read the “Highlights Sections” and “Deletion Right Exemptions” paragraphs under the CPA Additional Information.

Response Timeline

We will respond to your request within 45 days after receipt of a verifiable Consumer Request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at: [email protected] and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Virginia Attorney General at: https://www.oag.state.va.us/consumercomplaintform.

If you have an account with us, we may deliver our written response to that account or via email at our sole discretion. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You do not need to create an account for submitting a request. 

Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request we will not be able to grant your request.

ADDITIONAL INFORMATION FOR UTAH RESIDENTS (EFFECTIVE JANUARY 2024)

Under the Utah Consumer Privacy Act (“UCPA”) if you are a resident of Utah, acting in an individual or household context (and not in a commercial or employment context) your rights with respect to your Personal Data are described below. “Personal Data” means data which is linked or reasonably linkable to an identifiable individual, and does not include de-identified data and publicly available data or data that is processed not within the scope of UCPA. 

Please read the “Highlights Sections” paragraph under the CPA Additional Information.