Privacy Policy

WeBeGo Privacy Policy

Effective Date: This Privacy Policy is effective December 20, 2021.

Your privacy, and the privacy of the registered users of WeBeGo mobile applications and websites (collectively, the “App”), is important to us. In connection with your use of the App and the services provided by the App (such services and the App, collectively, the "Service"), we ask for and may collect a variety of information as more fully described below.

Accordingly, we have adopted the following privacy policy (“Privacy Policy”) which describes:

· How and why we collect certain information from you via the Service;

· How we use and with whom we share such information;

· How you can access and update such information; and

· The choices you can make about how we collect, use and share your information.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including third party websites, services and applications (collectively, "Third Party Services") that you may elect to access through the Service or to individuals that we don't manage or employ.

Please read this Privacy Policy carefully, and feel free to contact us at privacy@webego.com if you have any questions regarding its content. This Privacy Policy is incorporated into and made a part of the WeBeGo End User License Agreement (“EULA”). Terms not defined herein shall have the meaning set forth in the EULA found at https://www.webego.com/home/terms-of-use.

1) THE INFORMATION WE MAY COLLECT

A. PERSONAL INFORMATION: REGISTRATION, ACCOUNT AND USER DATA

We may collect personally identifiable information (“Personal Information”) about you and your use of the Service, as described in more detail below:

Device Information. We may collect information about the device you’re using the Service from, including the type of device, the operating system being used to use the Service, device settings and unique device identifiers.

Registration Information. Some WeBeGo services may require you to create an account to use the Service (an "Account"). To create an Account, you must provide information including:

- A username

- A password

- Your email address (which must be a functioning email address)

Of these categories of information, we will not publicly disclose your password or email address.

Additional User Information. You may also provide us with additional information in connection with your use of the Service (“User Information”), using a third-party ID or log-in, such as an ID for a social networking site or gaming service, including:

- A photograph that may appear as your profile picture

- Your date of birth, and gender

- Transactional information based upon your activities on the App and other information you provide in connection with your use of the Service.

- Personal and contact information you provide to us through information pages, feedback pages, email correspondence, “invite players”, chats, dispute resolution or shared by you from other third party social applications, services or websites.

- Additional personal information we ask you to submit to authenticate yourself or if we believe you are violating App policies.

Information Received from Other Users. We may receive information about you from other users of the Service, such as when they invite you to play a game.

Information You Provide About Your Third Party Accounts. You may be able to link your Account to certain Third Party Services. In order to do so, you may provide us with your username or other user ID (i.e., your Facebook ID) on each of those Third Party Services. You may also be required to engage in an authorization process with each of those Third Party Services, where we receive a token that allows us to access those accounts so that we can, for example, when you choose, post your content, or links to your content, to those services. We do not receive or store your passwords for your Third Party Service accounts.

Information Obtained From Third Party Services. In some cases, we may obtain supplemental information about you from third parties such as demographic and navigation data, as permitted by law. To the extent we obtain such information, we may use the information about you that we receive from third parties to improve and personalize the Service.

Information Collected From Advertisers And Publishers. We may collect Non Personal Information and Personal Information from advertisers who participate in WeBeGo’s advertising network. Such information may be used for internal analysis in order to perform and improve the Service and any associated technologies. Advertiser registration information may be used by WeBeGo to provide customer support to the applicable advertiser and to send to such party account-related information, including invoices, payments, technical notices, updates, security alerts, and support, administrative and promotional messages.

Email Addresses. Should a user explicitly provide their email address to us via any means of contacting WeBeGo, we will have then collected that email address of the user for the purpose of user support.

Promotions. From time to time we may provide you the opportunity to participate in surveys, contests or sweepstakes (collectively, “Promotions”) on the App. If you decide to participate, we will request certain Personal Information from you. Participation in Promotions is voluntary and you have a choice whether or not to disclose this information. We may use this information to administer your participation in each Promotion.

Please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other App users with whom you may choose to share your information or engage in a transaction. Therefore, we cannot and do not guarantee that content you post on the App will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the App. You understand and acknowledge that, even after removal, copies of content you post may remain viewable in cached and archived pages on the Internet or if other App users have copied or stored content you post. Any improper collection or misuse of information provided using the Service is a violation of the Service terms and should be reported via privacy@webego.com.

B. NON-PERSONAL INFORMATION

We may also collect aggregate, non-personally identifiable information about you and your use of the Service, as described in more detail below, including by using Advertising IDs (GAID), "cookies," web beacons, local shared objects, software development kits, mobile analytics software, and/or similar technologies (collectively “Non Personal Information”).

Log Data. Our servers may automatically record log data information ("Log Data") from anyone who uses the Service. Log Data may contain details such as your web request, IP address, date and time of your request and one or more cookies with the help of which your browser can be recognized. Other actions, such as interactions with our Service and advertisements, may also be included in the Log Data.

Location Information: We may collect and store location information regarding your use of the Service and any content you provide. This includes, but is not limited to, GPS, geo-location and geo-tagging information. We may use such location information to improve and personalize the Service for you.

Information Collected From Advertisers And Publishers. We may collect Non Personal Information and Personal Information from advertisers who participate in WeBeGo’s advertising network. Such information may be used for internal analysis in order to perform and improve the Service and any associated technologies. Advertiser registration information may be used by WeBeGo to provide customer support to the applicable advertiser and to send to such party account-related information, including invoices, payments, technical notices, updates, security alerts, and support, administrative and promotional messages.

2) HOW WE USE INFORMATION COLLECTED FROM YOU

We may use both Personal Information and Non-Personal Information collected from you in any one or more of the following ways:

Personal Information may be used as follows:

- To register and service your Account;

- To resolve disputes and troubleshoot problems;

- To prevent, detect, and investigate potentially prohibited or illegal activities, and enforce our App terms;

- To compare information for accuracy, and verify it with third parties;

- For our internal records, tracking and business purposes;

- To contact you to respond to your questions or requests or to provide you with technical support;

- To provide you with information regarding changes to the Service which may affect your Account, your use of the Service, and/or the products and services available through the Service

Non-Personal Information may be used for various purposes, including:

- To improve the Service;

- To customize the user experience of the Service;

- To administer the Service;

- To analyze trends, track user movement and gather statistical information for aggregate use; and

- To promote the Service or customize advertising that may be visible to you in connection with the Service.

3) HOW WE SHARE OR DISCLOSE INFORMATION COLLECTED FROM YOU

Your information may be shared as follows:

Safety, Security And Compliance With Laws. We may disclose any information, including Personal Information, to law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to a criminal investigation, investigation of fraud, alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability. In such events, we will disclose information relevant and necessary to the investigation or inquiry, such as name, city, state, ZIP code, telephone number, email address, User ID history, IP address, fraud complaints, payment history, and anything else we may deem relevant to the investigation. Without limiting the above, in an effort to respect your privacy and our ability to keep the WeBeGo community free from bad actors, we will not otherwise disclose your personal information to law enforcement, other government officials, or other third parties without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss or to report suspected illegal activity.

Business Transfers. In the event WeBeGo LLC undergoes a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, we may transfer your Personal Information to the successor organization in such transaction. If, in our reasonable discretion, believe that material changes to WeBeGo’s privacy practices will occur as a result of the business transition, we will attempt to notify you via email and post a notice on the App alerting you to the business transition prior to transferring your Personal Information so that we can elect whether to delete your account.

To Service Providers Performing Services On Our Behalf. We may contract with third party companies to perform services on our behalf, including fraud investigations, advertising, bill collection, rewards programs, site operations, marketing assistance, e-mail delivery, hosting services, customer service and data analysis.

Testimonials. We may post user testimonials on our App which may contain Personal Information. We do obtain the user’s consent via email prior to posting the testimonial to post their name along with their testimonial. If you wish to request the removal of your testimonial, you may contact us at privacy@webego.com.

4) HOW TO ACCESS AND UPDATE YOUR INFORMATION

You can access and update the information that you have provided to us as follows:

- You may contact us in writing at privacy@webego.com and request to review or make changes to your Personal Information collected by us; or

- You may review and make changes to certain Personal Information and Non-Personal Information by logging into your Account and updating your Account profile (Accounts may not be designed and/or implemented in each WeBeGo App and/or Service).

Deleting Your Data

We offer you the ability to request deletion of your Personal Information we may have collected and stored about you, subject to our Data Retention policy described below. If you would like to have your Personal Information deleted with respect to any WeBeGo Apps and/or Services, please contact privacy@webego.com. Deleting your Account may not fully remove the content you have published from our systems, as caching of, backups of, copies of, or references to your Account profile may not be immediately removed. In addition, given the nature of the Services, some of the activity on your Account prior to deletion may remain stored on our servers.

Data Retention

We may retain personal information where required by law or where we have ongoing legitimate business need to do so. For example, we may retain such information to provide you a service you have requested, to comply with applicable legal, tax or accounting requirements, or where necessary for fraud prevention, dispute resolution, or enforcement of our contracts and terms.

5) SENSITIVE DEVICE PERMISSIONS

Camera. A WeBeGo App may require and request the use of the user's device camera for the purposes necessary to function within the App.

6) THIRD PARTIES

Advertising Networks: WeBeGo allows advertisements from the third party ad networks to be displayed in our Apps or Services. We work with third party advertising partners like Google and their partners (listed here: https://support.google.com/admob/answer/9012903/ ). We may share certain of your information with these partners to make advertising more relevant, measure its effectiveness, and help recognize your devices and serve ads. We or they may also employ cookies or similar technologies, as described above, to ensure appropriate advertising and personalized experiences. WeBeGo makes commercially reasonable efforts to ensure that the third party ad networks are configured to comply with applicable privacy laws, and we reasonably believe this to be the case for each of them.

If we determine a Service to be directed at children under the age of 13, we configure each of these ad networks to be compliant with the Children’s Online Privacy Protection Act of 1998 (COPPA). For persons located in the EEA, we also configure networks to be compliant with the General Data Protection Regulation of 2016 (GDPR).

WeBeGo's third parties are listed under Appendix A of WeBeGo's End User License Agreement (“EULA”) and can be found at https://www.webego.com/home/terms-of-use

Obtaining EEA Member Consent: WeBeGo Apps request consent for personalized advertisements using Google's User Messaging Platform (UMP) or Google's Consent SDK.

For Residents of California: Third Party advertisements within WeBeGo Apps have been tailored to only present California residents with non-personalized advertisements (via Google Admob Blocking Controls).

For your consideration: some WeBeGo Apps may be designed not to limit the user experience if network/internet is unavailable. If App experience does not require network access, and if you prefer to not share information with third party advertising networks, and to not display advertisements within the Apps, ensure that your device does not provide the WeBeGo App internet/network service (example: turn on airplane mode prior to launching, and during use of WeBeGo App). Note that you must still agree to WeBeGo's terms of service and privacy policy.

If you would prefer to opt out of having information about your mobile app usage used for interest-based advertising, you may do so through your device settings ("Limit Ad Tracking" on iOS and "Opt Out of Ads Personalization" on Android). Please note that you may continue to receive generic non-personalized ads that are not based on your preferences.

7) GENERAL TERMS

Links To Third Party Apps. We are not responsible for the practices employed by websites linked to or from the App nor the information or content contained therein. When you navigate away from the App to another website, our Privacy Policy is no longer in effect.

Security. We use reasonable administrative, technical, personnel and physical measures to safeguard Personal Information in our possession against loss, theft and unauthorized use, disclosure or modification. Regardless of the precautions taken by you or by us, "perfect security" does not exist on the Internet. We cannot ensure or warrant the security of any information you transmit to us, and you transmit such information at your own risk. While we take reasonable precautions against possible security breaches of the App, no website or Internet transmission is completely secure, and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your Personal Information safe (including your Account password).

Minimum Age. We understand the importance of protecting the privacy and safety of children using our services, as outlined by the Children’s Online Privacy Protection Act of 1998 (COPPA), and as outlined by the General Data Protection Regulation of 2016 (GDPR). Accordingly, we do not knowingly collect, use, or disclose personal information from children under 13 (or children under the age of 16 for those in the EEA, United Kingdom, or Switzerland). Users of WeBeGo Apps must be at least 13 years of age (or must be at least 16 years of age for those in the EEA, United Kingdom, or Switzerland). We do not knowingly accept consent or registrations from users that are considered minors (those who are under 13 years of age (or those under 16 years of age in the EEA, United Kingdom, or Switzerland). We will delete Accounts of any users that we find that do not meet these requirements. If you become aware that your child has provided us with Personal Information or is using the Service without your consent, please contact us at privacy@webego.com. Furthermore, if you are aware that any child under the age of 13 has become a registered user, please inform us at privacy@webego.com so that we can take the appropriate steps to remove the Account and any related Personal Information.

Rights and Choices Available to EEA Residents. If you are a resident of a member country of the European Economic Area ("EEA"), the United Kingdom, or Switzerland, you may have the following rights with respect to any information about you that constitutes "personal data" under EEA law:

Access your personal data: You may have the right to obtain confirmation regarding whether we process your personal data and obtain a copy of the personal data that we may have collected about you (Note: this right only applies to personal data relating to you, and not to another user).

Rectify or correct your personal data: You may have the right to correct your personal data where it contains inaccuracies.

Withdrawing Your Consent: Contact us if you would like to withdraw your consent to the processing of your personal data. Exercising this right will not affect the lawfulness of processing based on consent before withdrawal.

Erasing or Restricting Access to Your Information: You may request to delete or restrict access to your personal data. We may postpone or deny your request if your personal data is in current use for providing Services or for other legitimate purposes, in which case we will let you know if we are unable to do so and why.

Transferring Your Personal Data (Your Right to Data Portability): You have the right to receive your personal data that you have provided us in a structured, commonly used and machine readable format and the right to transmit that data to another party of your choice, where technically feasible. However, this right shall not apply where tit would adversely affect the rights and freedoms of others.

If you consider that our processing of your personal data infringes data protection laws, you have the right to lodge a complaint with a supervisory authority responsible for data protection. If you have any concerns about the way we process your personal data, you are welcome to contact our data protection officer at privacy@webego.com or write to us at WeBeGo LLC, 16 Caroline Street, Trumbull, CT 06611. We will look into any matters and make good faith efforts to resolve any concern you may have.

Additional Information for Residents of California:

Information We May Collect, Use, and Disclose

California law requires us to disclose information about the categories of personal information we collect and how we use them, the categories of sources from which we collect personal information, and the third parties with whom we share personal information. We have provided detailed descriptions above in the “The INFORMATION WE MAY COLLECT", and “HOW WE USE INFORMATION COLLECTED FROM YOU,” and “HOW WE SHARE OR DISCLOSE INFORMATION COLLECTED FROM YOU” sections of this Privacy Policy.

Generally, we may collect the following categories of personal information, as defined by applicable California law:

Identifiers and contact information, including first and last name, username or handle, third party service ID, IP address, unique device identifier, advertising identifier, device serial number, email address, phone number, home address or shipping address, and your friends’ names and contact information;

Internet or other electronic network activity information, such as hardware model, device software platform/OS and firmware, mobile carrier, preferred languages, device motion information, and mobile network information, and in some cases, browser type, Internet service provider, referring/exit pages and URLs, and clickstream data;

Commercial information, including in-game purchase information;

Demographic information, including your gender, age, date of birth, and language;

Non-precise geolocation information, such as approximate location as inferred from IP address;

Visual information, such as your profile picture and the profile pictures of your friends or contacts; and

Other information you may share if you use social features when accessing our Services, including the organizations, links, and other information included on your social profile pages.

In the past 12 months, we may have disclosed (or have enabled you to disclose) the following categories of personal information to third parties for business or commercial purposes:

- Identifiers and Non-precise location information (e.g., estimated location based on your IP address) with: analytics providers; and advertising networks.

- Internet and electronic network activity information with: analytics providers

WeBeGo does not sell player personal information for money or for other consideration. If the WeBeGo Apps you use/play are supported by advertisements, we do allow our advertising partners to collect certain device identifiers and electronic network activity via our Services to show ads that are targeted to your interests. To opt out of having your personal information used for targeted advertising purposes, please see the Third Parties Advertising Networks section above.

If you are a California resident, you may have the following rights with respect to any information about you that constitutes “personal information” under California law:

Access your personal information: You may have the right to obtain a copy of the specific pieces of personal information we have collected about you. (Note that this right only applies to personal information relating to you, and not to another user.)

Request deletion of your personal information: You may have the right to request that WeBeGo delete your personal information. This right may be limited to the extent that WeBeGo is permitted or required by applicable law to retain information. (Note that if you request deletion of your personal information, you may no longer be able to use or access the Services, and that if you share devices with someone else who uses the Services, that person may lose game progress or related account information and access. If you decide to use or access the Services again, WeBeGo may consider this a new Account and may collect personal information associated with that Account in accordance with this Privacy Policy.)

Obtain additional details regarding WeBeGo's information practices: You may have the right to request disclosures regarding WeBeGo’s information practices. (Note that this information is generally available in this Privacy Policy.)

If you wish to exercise any of the rights described above, please contact privacy@webego.com using your WeBeGo Account's associated email address.

You also have the right not to be discriminated against for exercising any of your rights under California law.

Changes To This Policy. If we decide to make material changes to our Privacy Policy, we will, at our discretion, attempt to notify you and other users of the App by sending a notice to the email address provided to us and/or by placing a notice on our App or on the Service. You should periodically check for such notices or updates to this Privacy Policy. Use of information we collect is subject to the Privacy Policy in effect at the time such information is used. Your continued use of the Service after the Effective Date will be an acknowledgement of our updated practices.