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This Privacy Policy (hereinafter – Policy) describes how we, AlphaSoft LLC, handle personal data that we process when users use the Game, the measures taken by the Company to ensure the security of personal data, and the rights that users, as subjects of personal data, have.

This Policy applies to all information that we and/or our partners and affiliates may obtain about the user while using the Game.

This Policy is an integral part of the License Agreement, which is located on the Game’s official website at http://wtlgame.com.

We take a responsible approach to ensuring compliance with user personal data protection requirements. The Company collects and processes such data basing upon the principle of minimal necessity and only in strictly limited amounts, as necessary to ensure gameplay, technical support, and the exercise of rights under the License Agreement, in compliance with applicable data protection laws in the countries where the Game is used.

We protect such information and store it in an anonymized form, except in cases described below.

Anonymous or depersonalized information that we cannot link to your identity does not constitute personal information about you (your data). The collection of such data is not intended to identify the User’s person.

1.1. Personal data - any information or data that can identify a person or is indirectly related to the Subject of Personal Data

1.2. Anonymized personal data - are data that, when used, make it impossible to determine the attribution of personal data to a specific Subject of Personal Data without the use of additional information.

1.3. Subject of Personal Data - You, individual, Game User.

1.4. Game - is a set of software products for electronic computers called “Will To Live Online”, part of which is installed on the User’s personal computer

1.5. Game User Account or Account - a set of data about the User stored in a computer system, necessary for identification and provision of access to the Game

1.6. Company – “AlphaSoft” Limited Liability Company

Address of registration: 100008, Republic of Kazakhstan,
Karaganda city, Loboda street, building 25/3, non-residential premise 3.

1.7. Web-site — wtlgame.com.

1.8. Platform - the online platform “Steam” of the “Valve Corporation” company, as well as the online platform “VK Play” of the VK Play LLC

1.9. The meanings of other terms in the Policy are defined in the License Agreement.

This Policy applies to the Game and sets forth the Company’s rights and obligations to ensure the protection regime for personal information that you, the User, may provide by your confirmed consent when launching and using the Game. You thereby confirm that your consent is free, unambiguous, and given voluntarily and in your own interests. The platform on which the Game is located and from which you download it has its own rules for processing users’ personal data and is therefore solely responsible for compliance.

To review the Platform Policy, please visit:

https://store.steampowered.com/privacy_agreement/
https://documentation.vkplay.ru/terms_vkp/privacy_vkp/

3.1. This game is intended for adults, fully capable people.

3.2. If you are under the legal age according to the legislation of your country of residence, please do not provide us with your personal information. In any case, you should not use the Game.

3.3. If you are a parent or guardian and believe that your child has provided us with information in violation of the prohibitions and without your consent, you may contact us to request is to remove your child’s information from our system.

3.4. In any other case, by continuing to use the Game, the User confirms that he/she has reached the age of legal capacity under the legislation of his/her country of residence, has accepted the terms of the Policy, or that his/her parents or guardians have read, understood and accepted all the terms of the Policy on behalf of the User.

4.1. For any questions regarding this Policy, our handling of your Personal Data, or our compliance with applicable legislation, please contact us at: law@willtoliveonline.com.

4.2. All inquiries received by the Company are classified as restricted information and cannot be disclosed without the written consent of the User, except in cases expressly provided for by applicable relevant legislation.

The Company, in order to comply with the data protection or data privacy laws of the countries where the Game is used, ensures the privacy of Users, complies with the current legislation on the protection of the privacy of Users’ personal data and confirms the compliance of the Company’s internal processes with this Policy.

6.1. The Company processes the User’s data only in cases where such processing is necessary to fulfill the terms of the License Agreement concluded with the User, to fulfill our legal obligations and to protect our legitimate interests in order to provide technical support to the User, to save the User’s progress in the Game, to analyze statistics in the Game, to correct errors, and to improve the Game process.

6.2. Personal information permitted for processing under this Policy includes information provided by the User to assist them in using the Game. The User may contact us by email or by submitting support requests. In this case, the Company will process the following User data for the purpose of providing feedback: email address, Game character name, and any data provided by the User when contacting Game support.

6.3. In some cases, to improve the quality of the Game and provide technical support, the Company may process the data about your equipment and its properties (central processor, video card, screen resolution, etc.).

Automatically transferred data also include:

• User ID in the platform, is processed for the purposes of determining the User Account;
• data provided when using the in-game chat function is processed for the purpose of regulating the process of interaction between users within the Game, updating processes, and improving the quality of the Game;
• Access time;
• User’s statistics (progress and behavior inside the Game), is processed for the purpose of game process implementation.

6.4. If any government agencies send the Company notifications and/or requests regarding legal proceedings or investigations, and the User’s Personal Data is relevant, the Company will process and use this data for the specified purposes. This Personal Data will be stored until the completion of the proceedings and/or investigations, for the period required by applicable law.

6.5. In some cases, the Company transfers your Personal Information to our partners. This is necessary to fulfill the terms of the License Agreement concluded with the User, in the interests of the Company, and to comply with all legal obligations. This means that such data is controlled by our partners and used only in accordance with the legislation in force.

6.6. The Company under no circumstances collects or processes confidential information of Users that goes beyond what is necessary for using the Game, such as: gender, sexual orientation, health status, political views, race, ethnicity, religious or other beliefs.

7.1. The Company takes the necessary organizational and technical measures to protect personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.

7.2. We retain your information only for as long as necessary to achieve the purposes for which such information is collected and processed, or (if legislation in force provides for a longer retention period) for the retention period required by law. After this period, your Personal Data is deleted, blocked, or anonymized, as required by applicable/relevant law.
7.3. You can delete your Personal Data at any time by sending the Company a request for deletion via email to the email address: law@willtoliveonline.com.

It is important to understand that as a result of deleting Personal Data, further use of the Account is terminated.

7.4. In order to prevent fraudulent actions by third parties, the Company may request additional information to verify your identity, which will confirm that it was you/the User who submitted the corresponding request to delete the Account.

7.5. In certain cases, there may be circumstances that make it difficult to delete your Account and, consequently, your Personal Data. For example, if it is impossible to accurately identify the Personal Data as belonging to you or as required by the legislation in force.

7.6. In any other case, we will, at your request, delete all of your data, except for data necessary to comply with the legislation in force (e.g., tax laws), as well as to detect, investigate, and prevent violations of the License Agreement, or to resolve disputes and enforce our agreements. After deleting your Account, we will also retain anonymous or depersonalized information.

8.1. The User, as a Subject of Personal Data, under certain circumstances, has the following rights:
- to receive information about his/her Personal Data;
- to limit the use of his/her Personal Data;
- to delete the Personal Data related to User, if:

• the reason for their collection no longer exists;
• there is a legal reason for Data deleting;
• Personal Data was subject to illegal processing;
• the User submitted a personal, reasoned revocation of consent to the processing of Personal Data;
• there are relevant requirements of the legislation in force.

- the right to refuse the processing of the User’s personal information;
- the right to transfer Personal Data in certain specific circumstances;
- the right not to be subject to automated decision-making;
- the right to file a complaint with regulatory authorities.

8.2. For processing of Personal data based on consent, the User has the right to revoke this consent at any time.

8.3. In accordance with the legislation in force of the country of residence, the User may have other rights regarding the processing of his/her Personal data, including the right to determine actions regarding the results of the processing of Personal data after the death of the User.

8.4. To exercise these rights, the User shall contact the Company at law@willtoliveonline.com. The Company will endeavor to respond to the User within 10 business days of receiving the request.

9.1. In order to comply with the terms of the Policy and to protect our legitimate interests, we may transfer your personal information to third parties in cases where

9.1.1. in order to properly provide the Game to the User, the Company shall use certain third-party services. For example, those services that enable the distribution of the Game on the Platforms. These service providers undertake to maintain the confidentiality of the User’s Personal Data collected in connection with their use of the Game and all services provided thereto. We collaborate with the following partners who receive the User’s Personal Data:

• Steam. Confidentiality documents: https://store.steampowered.com/privacy_agreement/;
• VK Plaу. Confidentiality documents: https://documentation.vkplay.ru/terms_vkp/privacy_vkp/.

As well, our partner, Epic Games and Epic Online Services, act as data controllers, enabling us to identify violations of the License Agreement. For example, when you launch the Game on your computer, the anti-cheat client application may collect certain data about your hardware and software:

• Epic Games. Confidentiality documents: https://www.epicgames.com/site/ru/privacypolicy/

9.1.2. the Company may disclose information about the collected User’s personal data to a third party, a legal successor of the Company, in connection with certain types of corporate transactions (for example, in the event of a merger, acquisition, reorganization, bankruptcy or other similar events) to that third party) so that the User can continue to receive services and information related to that enterprise with minimal possible disruption.

9.1.3. some data may be disclosed to government agencies, such as courts, tax authorities, auditors, and other competent parties, in accordance with the laws of each local jurisdiction in which we operate, or in special cases where the Company has reason to believe that disclosure of such information is necessary to identify, contact, or bring legal action if the User or third parties violate the License Agreement, any other terms of service provided by the Company or its partners, or any applicable law, in order to protect the rights and interests of the Company. The Company also reserves the right to disclose the User’s personal information if the Company has good grounds to believe that this is necessary to prevent fraudulent or any other illegal activity.

9.2. The transfer of Personal Data to third parties, regardless of their legal status, is carried out securely and under an agreement between the Company and each third party, in accordance with the legislation in force. Each third party is aware of, complies with, and is bound by the applicable Personal Data Protection Principles within the scope of applicable law and/or a specific agreement.

9.3. We may also share information that does not identify you with third parties, including aggregated or anonymized information.

10.1. The Game character’s name and other information the User provides in Game process may be available to all Game users. We ask you not to distribute any data that could identify you. At that, the Company takes all technical and organizational measures to ensure the security of the User’s Personal Data. However, if you post your personal information in publicly accessible areas or resources accessible to other Game Users, such information becomes available to other Game Users and may also be copied and/or distributed by such Users. It is important for the User to know and understand that the Company does not control data copied by other Game participants/users. In this case, the User is solely responsible for the disclosure of such information. Once other Users have accessed or copied the User’s Personal Data, neither the User nor the Company will be able to delete such Personal Data from other Users.

10.2. our Game may also have communities where users can exchange ideas and communicate with each other. When posting a message in a community, please be aware that this information will be publicly available online; you post at your own risk and are fully responsible for any information you post. Your Game character’s name and game statistics may also be available in Game recordings and other videos that the Company or other players may create and post online.

11.1. The Company may use cookies on its Website. These are small text files placed on users’ computers to analyze their user activity, such as:

Compulsory cookies

Always active. These cookies are essential for the website to function and use its features. They cannot be disabled. They are set in response to your requests, for example, when setting privacy settings, logging in, or filling in forms.

Analytical cookies

These cookies collect information that helps us understand how our Website is used, how effective our marketing campaigns are, and allows us to tailor our Website to your needs.

Advertisement cookies

These cookies provide advertising companies with information about your online activity to help them show you more relevant ads or limit the number of times you see an ad. This information may be shared with other advertising companies.

11.2. Our web-site wtlgame.com use sweb analytics service Yandex.Metrika, by “YANDEX” LLC. Yandex.Metrika uses «cookies» technology.

11.3. Information collected using cookies and Yandex.Metrika cannot identify you, but it can help us improve our website. Information about your use of this website collected using cookies will be transmitted to Yandex and stored on Yandex server. All information received complies with the Yandex.Metrika Terms of Service:

• https://yandex.ru/legal/metrica_termsofuse/
• https://yandex.ru/legal/confidential/

For information on how your data is used, please see the Yandex Legal Documents Privacy Policy section of “YANDEX” LLC at the following link:

• https://yandex.ru/legal/confidential/

11.4. You can reject collecting cookies by selecting the appropriate setting in your browser, and also prevent the transfer of visitor information to the Yandex.Metrika service using the following tool:

• https://yandex.ru/support/metrika/general/opt-out.html

However, this may affect some website functions. By using this website, you consent to the processing of your data by Yandex in the manner and for the purposes specified above.

12.1. The Company, in order to comply with the legislation in force and for other reasons, has the right to make periodical changes to the Policy and the License Agreement unilaterally.

12.2. Changes come into force from the moment they are posted on the Game website http://wtlgame.com, unless otherwise provided by the new version of the Policy and License Agreement

12.3. The user checks the publication of the latest changes on his own.

12.4. If the User disagrees with the new terms, they shall cease using the Game. By continuing to use the Game and/or interact with it in any way, the User confirms their full agreement with all provisions of the updated Policy and License Agreement.