PRIVACY POLICY STATEMENT

Last Updated: June 2018

PART I. GENERAL INFORMATION

This Privacy Policy (“Policy”) sets out how AAA Internet Publishing Inc. trading as wtfast (“wtfast”, “we”, “us”, “our”) collect and process information about you when you visit our website https://www.wtfast.com (the “Website”) or use our Gamers Private Network (or “GPN”) software service (the “wtfast Service”).

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Policy.

We recommend that you read this Policy in full to ensure you are fully informed. However, if you only want to access a particular section of this Policy, then you can click on the relevant link below to jump to that section.


PART II. WHAT WE COLLECT AND HOW WE USE IT

  1. Information you give us
    1. You may provide us with personal information, when you use our Website, correspond with us, or enter into any of our competitions, promotions or surveys. Where we request information from you, we will collect the information set out in the relevant forms or pages. You may choose to provide additional information to us when you contact us or otherwise interact with us.
    2. If you download and use the wtfast Service you will be required to create an onlinewtfast account (“Account”) before access will be granted. If you are a regular user of our Website but not a user of the wtfast Service, you may also wish to create an Account with us.
    3. The information that you provide when setting up your Account may include your name, email address and telephone number. If you register to hold an Account with us, you will also have a unique username and password which enables you to access your Account.
    4. If you choose to upgrade to a Premiumw tfast Account via our Website, we will also collect your delivery address, billing address and payment information in order to manage your payments. Please note that we will not be storing your payment information, this will be done via a third party payments company (e.g. PayPal or Paymentech).
    5. If you subscribe to receive our newsletter, we will ask you to provide us with your name and email address.
    6. If you contact us via email then we will collect your email address and the correspondence between us.
    7. The personal information that you provide to us will be used for the purposes made clear to you at the time you submit your information, for example for enabling you to use our Website and subscribing to or accessing the wtfast Service, for administrative and troubleshooting purposes and/or (if we have appropriate permissions to do) to send you direct marketing communications. As explained in Section 3.2 below, we may also use this information for further purposes when combined with other information we collect about you.
  2. Information we collect automatically via the Website
    1. When you visit our Website, we may automatically collect certain information from your device. In some countries, including in the European Economic Area, this information may be considered personal information. The information collected may include your IP address, log-in information, location information, browser type and version, browser plug-in types and versions, operating system and platform, information about your visit including the URL clickstream to, through and from our Website, download errors, length of visits to certain pages and page interaction. We collect information automatically through the use of various technologies, including through cookies and similar tracking technologies, and this is explained further in the “Cookies and other technologies” section below.
    2. We use the information we collect automatically: (i) to administer our Website and the wtfast Service for internal operations including troubleshooting purposes; (ii) to ensure that content from our Website is presented in the most effective manner for you and your devices; (iii) as part of our effort to keep our Website and the wtfast Service safe and secure; (iv) to measure or understand the visitors to our Website and the wtfast Service, where they come from and what content is of interest to them: (a) for analytics purposes; (b) to measure the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and (c) to make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.
  3. Information we receive from other sources (including the wtfast Service)
    1. We may receive and collect information about you if you use the wtfast Service, including what games you play, how you interact with them, when and for how long whilst using the wtfast Service. We use this information to improve our games and for the same reasons set out in paragraph 2.2 above.
    2. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them (including information that is publicly available). For more information about the third party service providers and partners that we work with, please see Part III Who we share your information with.
    3. If you choose to connect or engage with our Website or the wtfast Service via or in connection with a social media account or channel, we may receive certain information about you from your applicable social media provider. Exactly what information we might receive will depend on your social media privacy settings, but will typically include your basic profile information and email address. We use this information for the same reasons set out in paragraph 2.2. above.
    4. Where permitted by law, we may combine this information we receive from other sources, including from social media websites, with information that you provide to us and information we automatically collect about you, including using cookies. We may use this information and the combined information for learning more about your preferences as our customer, for enhancing your user experience on our Website and for providing you with information, content and offerings tailored to your needs.
  4. Cookies and other technologies
    1. A cookie is a text file containing small amounts of information that can be sent to your browser and which may then be stored on your device as a tag that distinguishes your device but does not name you. We collect certain information automatically through the use of cookies and other similar tracking technologies (“cookies”). Some of our Website pages use cookies to better serve you when you return to the Website. For information about the specific cookies used on this Website and how you can block or turn off cookies, please refer to our Cookie Statement.
  5. Links to other websites and social media
    1. Where we provide links to other websites, we do so for information purposes only. The other websites are outside our control and are not covered by this Policy. If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their privacy policy, which may differ from ours.
    2. On some pages of our Website, third parties that provide content, applications or plugins through our Website may track your use of content, applications and plugins or customize content, applications and plug-ins for you. For more information, please refer to our Cookie Statement.


PART III. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We may disclose your personal information to the following categories of recipients:
  1. Group companies, third party services providers and partners
    1. We may disclose your personal information to group companies, third party services providers and/or partners that provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website or the wtfast Service), or who otherwise process personal information for purposes that are described in this Policy or notified to you when we collect your personal information.
    2. Our service providers and partners fall into the following categories:
      1. business partners
      2. sub-contractors in technical, payment and delivery services
      3. advertising networks
      4. analytics providers
      5. search information providers
      6. credit reference agencies
      7. hosting providers
  2. Competent law enforcement body, regulatory, government agency, court or other third party
    1. We may disclose your personal information to a competent law enforcement bodies, regulatory, government agencies, courts or other third parties where we believe disclosure is necessary:
      1. as a matter of applicable law or regulation
      2. to exercise, establish or defend our legal rights, or
      3. to protect your vital interests or those of any other person.
  3. Actual or potential buyer (and its agents and advisers)
    1. We may disclose your personal information to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Policy.
  4. With your consent
    1. We may disclose your personal information to any other person with your consent to the disclosure.


PART IV. YOUR DATA PROTECTION RIGHTS AND OUR LEGAL BASIS FOR PROCESSING

  1. Depending on applicable law, you may have the following data protection rights:
    1. If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “Contact us” heading below.
    2. In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can do so by contacting us using the contact details provided under the “Contact us” heading below.
    3. You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “Contact us” heading below.
    4. Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time by contacting us using the “Contact us” heading below. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
    5. You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
    6. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
  2. Our legal basis for processing personal information (EEA visitors or users only)
    1. If you are a visitor form the European Economic Area, our legal basis for collecting and using the personal information described in Part II above will depend on the personal information concerned and the specific context in which we collect it.
    2. However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
    3. If we ask you to provide information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
    4. If we collect and use your personal information on the basis of our legitimate interests (or those of any third party) this interest will normally be to operate our Website and the wtfast Service and communicating with you as necessary to provide our Website and the wtfast Services to you, improving our Website and the wtfast Service, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We have other legitimate interests and it appropriate we will make these clear to you at the relevant time what those interests are.
    5. If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact us” heading below.


PART V. DATA TRANSFERS, SECURITY AND RETENTION

  1. International data transfers
    1. Your personal information may be processed in the country in which it was collected and in other countries, including the United States, whose data protection laws may be different to the laws in your country. In any event, we will ensure your personal information remains adequately protected in accordance with the standards described in this Policy, wherever it is processed.
    2. Specifically, our Website and wtfast Service servers are located in Canada, and our group companies and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.
    3. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information to our third party service providers and partners where necessary and further details can be provided upon request.
  2. Security
    1. We use appropriate technical, organizational and administrative measures to protect any personal information we process about our visitors, our customers and their end users. Transmissions to and from secure areas of our Website are protected using SSL (Secure Socket Layer) encryption.
    2. However, please note that no Internet transmission can ever be guaranteed 100% secure, and so we encourage you to take care when disclosing personal information online and to use readily available tools, such as Internet firewalls, anti-virus and anti-spyware software, and similar technologies to protect yourself online.
    3. Where you have a password, which enables you to access our Website, you are responsible for keeping this password secure and confidential.
  3. Data retention
    1. We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). This may mean we need to retain some information after you have closed your wtfast Account with us or stopped using the wtfast Service.
    2. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.


PART VI. ABOUT US AND THIS POLICY

  1. Changes to this Policy
    1. If we change this Policy, we will post those changes on this page in addition to updating the “Last Updated” date at the top of this webpage. If we make material changes, we will notify you more directly, for example by posting a notification or message on the Website and/or in the wtfast Service or by emailing you prior to such changes taking effect. We encourage you to review this Privacy Policy frequently to stay informed of the latest modifications.
  2. Contact us
    1. This Website is maintained by AAA Internet Publishing Inc. trading as wtfast.
    2. General Privacy Inquiries: Please submit any questions, concerns or comments you have about this Privacy Statement or any requests concerning your Personal Data to our support team by email to dponull@wtfaster.com or writing to us at: #201 – 1441 Ellis Street, Kelowna, BC, V1Y 2A3, CANADA.