Privacy Policy
Last Updated: July 1, 2025
Effective: July 1, 2025
Thank you for choosing our games. This Privacy Policy explains:
• What personal data we collect and why we collect it;
• How we use and share that data;
• Your choices and rights regarding your data.
This Policy covers the Whoot website (the “Website” ) and all Whoot games, applications, and related services (collectively, the “Services” ). By continuing to use the Services on or after the effective date, you acknowledge that you have read, understood, and agree to this Privacy Policy. It does not apply to the practices of third parties that Whoot does not own or control.
We comply with all applicable privacy laws and process your personal data only on a lawful basis. Where the law requires your express consent, you hereby consent to the processing described in this Policy and in our Terms of Service. If you do not wish to consent, please discontinue use of the Services.
Contact Us
If you have questions about data protection or wish to exercise a privacy right, please reach out through the in-game “Support” channel for the quickest response, or contact us at:
Name of the controller:
Whoot Limited
Address:
Room E03, 12/F, Phase 2, Kweishun Industrial Building, 42 Tai Lin Pai Road, Hong Kong SAR
Email: 
[email protected]
1. Data We Collect
a. Information You Provide
• Contact details — country/region, first and last name, email address, username
• User-generated content — files, text, images, videos, or other material you upload or transmit
• Profile & game info — screen name, avatar, game progress, scores, achievements, purchases (item, date, amount), tournaments entered, play-session details, membership or team data, chat messages posted in team forums
• Survey feedback — ratings, comments, or other responses you voluntarily provide
b. Information We Collect Automatically
• Analytics data — in-game events, ad interactions, crash logs, diagnostic metrics (e.g., battery level, latency, frame rate), IP address, browser and OS details, device performance data, Website browsing activity
• Device identifiers — unique device ID, IDFA (iOS), Google Advertising ID (Android), IDFV (iOS), App Set ID (Android), Game Center ID
• Approximate location — inferred from your IP address
c. Information We Receive from Partners
• Data from linked third-party accounts (e.g., Facebook, Apple, Google)
• Approximate demographics derived from IP addresses
• Fraud-prevention signals (e.g., refund-abuse or ad-click-fraud indicators)
• Payment-verification details from platform providers
• Advertising and analytics data that helps us improve and measure our Services
2. Why We Collect Your Data
• Personalize your in-game profile and activate paid content. We set up or adjust your screen name, avatar, and other profile elements, and make sure any purchases or paid services are properly delivered to your account.
• Optimize our games for you and your device. We tailor graphics, network settings, in-game events, promotions, and special offers to suit your hardware and gameplay style.
• Manage our organization and daily operations. Operational and financial metrics help us plan, budget, and run the Services efficiently.
• Verify your identity and entitlement. We confirm who you are and whether you are eligible for particular products or Services when you contact us or log in.
• Invite you to participate in surveys. We may ask for feedback on our company, partners, or Services to improve what we offer.
• Maintain security, safety, and integrity. We monitor for intrusions, bots, exploits, and other threats that could harm players, data, or infrastructure.
• Operate, improve, and optimize the Services. Usage analytics help us fix bugs, balance gameplay, and develop new features.
• Personalize the overall user experience. We study player preferences to enhance enjoyment, accessibility, and engagement.
• Provide access to specific areas and features. Social tools, multiplayer competitions, and other functionality rely on processing your data.
• Communicate service-related information. We send confirmations, technical notices, updates, security alerts, and other essential messages.
• Enable player-to-player communication. In-game chat and official social-media channels let players interact with each other.
• Respond to comments and inquiries. Customer-support channels use your data to troubleshoot and resolve issues.
• Prevent prohibited or illegal activities. Anti-fraud and anti-cheat measures protect the game environment and our players.
• Measure interest in our Services. Metrics such as session length and retention help us understand engagement.
• Ensure internal quality control. Audits and reviews keep our processes compliant and reliable.
• Comply with laws and enforce our rights. We process data to satisfy legal obligations, enforce the Terms of Service, or defend legal claims.
• Activate, verify, and enforce parental controls. Where applicable, we confirm guardian consent and apply age-appropriate limits.
• Fulfil contractual and legal requirements. Data processing allows us to meet obligations to you, platform providers, and partners.
• Provide support via customer-service channels. Ticket tracking and status updates rely on certain account information.
• Conduct internal research and analysis. Aggregated data informs game balance, design decisions, and future development.
• Evaluate and carry out business transactions. Relevant data may be processed to assess or complete mergers, acquisitions, restructurings, or asset transfers.
• Engage in marketing activities. Where permitted, we deliver advertisements, promotions, newsletters, and other marketing communications tailored to you.
3. Who Can Access Your Data
3.1 Other Users in Online Communities
If you take part in our online communities or send virtual items (“virtual gifts”) to other players, we may share your public-profile information with other community members. This may include your:
• screen name;
• profile picture or avatar;
• in-game scores and achievements;
• virtual items you have gifted;
• any other information you choose to make public.
3.2 Contest, Sweepstakes, and Survey Providers
We may disclose your personal data to third parties that help us run contests, sweepstakes, or surveys and process the related feedback.
3.3 Service Providers
We share personal data with carefully selected third-party service providers (“Service Providers”) that support delivery of the Services, including:
(i) IT & Technical Support:
Hosting maintenance, security
(ii) Customer Service Support:
Ticket handling, live chat
(iii) Analytics & Search Services:
Crash reporting, usage analytics, search optimisation
(iv) Other Operational Support:
Payment processing, fraud prevention
Each Service Provider is bound by contract to: (a) process personal data only on our documented instructions, and (b) use the data solely for the contracted purpose unless the law requires otherwise.
3.4 Disclosures for Legal Requirements and Rights Protection
We may access, preserve, and disclose your personal data to third parties (such as legal advisers or law-enforcement authorities) when necessary or appropriate, including:
• Compliance with law—to satisfy law-enforcement or national-security requests, court orders, or subpoenas;
• Responding to you—to address your own lawful requests;
• Protecting rights and safety—to safeguard your, our, or others’ rights, property, or safety;
• Enforcing policies or contracts;
• Collecting debts owed to us;
• Preventing harm or illegal activity—to avoid physical injury, financial loss, or to investigate or prosecute suspected wrongdoing;
• Legal claims—to establish, exercise, or defend legal rights;
• Other good-faith disclosures—where we believe disclosure is necessary or appropriate.
3.5 Advertising Networks and Advertising Partners
We partner with third-party advertising networks and partners to show ads and personalised content on sites and apps not operated by Whoot. These third parties may collect data directly from your browser or device (e.g., through cookies) in order to:
• deliver and optimise targeted advertisements; and
• provide related services such as ad reporting, attribution, analytics, and market research.
Where allowed by law, we may also share limited personal data with these partners so they can show you content we believe you may like.
3.6 With Your Consent
We may share or publicly disclose your personal information when you expressly authorise us to do so—for example, by letting us post a player testimonial on our website.
3.7 Asset Transfers and Changes of Control
If we sell assets, merge, or undergo any other change of control, we may disclose your personal data to prospective buyers and their advisers as needed to evaluate and complete the transaction.
3.8 Targeted Advertising
We use third-party advertising technology providers (“Ad Tech Providers”) to serve targeted ads across websites and apps. To enable this, we may share:
• advertising identifiers (e.g., IDFA, Google Advertising ID);
• IP addresses;
• details of the Services you used and the timestamps of use; and
• inferred interest categories.
Ad Tech Providers combine this information with other data they hold to deliver interest-based ads and related services (e.g., ad measurement, attribution, analytics, market research).
4. International Data Transfers
Because we operate globally, your data may be transferred to—and processed in—countries outside your own. We protect these transfers with appropriate safeguards such as the European Commission’s Standard Contractual Clauses or equivalent measures.
5. Requests to Exercise Privacy Rights
Subject to the laws that apply to our processing of your personal data, you may have the right to:
• Access – obtain a copy of the personal data we hold about you.
• Correct or Delete – request correction of inaccurate data or deletion where legally permitted.
• Restrict Processing – ask us to limit processing in certain circumstances.
• Object – object to processing on specific legal grounds.
• Data Portability – receive the data you provided to us in a structured, commonly used, machine-readable format and, where feasible, ask us to transmit it to another controller.
6. Virtual Currency and Goods
• Virtual currency and virtual goods may be used only within Whoot games and have no real-world monetary value.
• All purchases of virtual currency or goods are final and non-refundable, unless we state otherwise.
• Whoot may modify, remove, or discontinue virtual items at any time without liability.
7. Cookies and Similar Technologies
We and our partners use cookies, device identifiers, and similar technologies to:
• deliver personalised content and features;
• analyse usage patterns;
• serve advertisements;
• prevent fraud.
You can disable cookies via your browser settings, but some features of the Services may not function properly.
8. Data Protection Measures
• We employ technical and organisational safeguards to protect data against unauthorised access, loss, or misuse.
• We retain data only as long as necessary for the purposes stated in this Policy. Inactive-account data may be anonymised.
• Even after a deletion request, we may keep limited data where required to meet legal obligations.
9. Children’s Privacy
We do not knowingly collect personal data from children under 13. If we learn that we have done so, we will delete the data promptly. If you believe a child under 13 has provided us with data, please contact us immediately.
10. Retention of Personal Data
We keep personal data only for as long as necessary to fulfil the purposes for which it was collected, or to comply with legal, accounting, or reporting requirements, enforce our rights, or respond to legal requests. When data is no longer needed, we delete it securely.
11. Changes to This Privacy Policy
We may update this Policy from time to time. When we do, we will:
• post the revised version here with an updated “Last Updated” date;
• for material changes, notify you via email, an in-game notice, or another appropriate method.The revised Policy takes effect on the date it is posted unless we specify otherwise.
12. Contact Us
Whoot products and services are subject to U.S. export-control laws; you agree to comply with them. For privacy questions or support, email [email protected]. We will address your concerns promptly.