Privacy Policy

INTRODUCTION

Wercams including its affiliates (collectively referred to as the "Company", "we", "our", or "us"), offers online entertainment services (the "Services") through:

• Internet websites we operate, including Wercams.com;
• Downloadable applications and software, such as mobile applications available through app stores; and
• Non-downloadable online applications (e.g., HTML5 applications).

Please read this Policy carefully and use it to make informed decisions. Your access to and use of our Service, whether by visiting our website ("Websites") or creating an account through our Service, signifies that you have read, understood, and agreed to this Policy, including the collection, use, retention, and disclosure of your personal information as outlined. If you do not agree with the terms of this Policy, please do not use our Services. You are not legally obligated to provide us with any Personal Information, but without it, we cannot offer you the full range or best experience of our Services.

Personal information refers to any information that identifies or can reasonably identify an individual, including but not limited to: your name, surname, date of birth, address, IP address, email address, phone number, ID documents, financial documents (such as utility bills or bank statements), and other non-public information associated with any of the foregoing (collectively, "Personal Information"). Processing activities include the collection, use, retention, and disclosure of such data.

Your Personal Information will be processed by us, including our agents and employees, and where appropriate, by other companies within our group and our partners and subcontractors, in accordance with this Policy.

If you have any questions regarding this Policy or our use of your Personal Information, please refer to our table of contents and the section "HOW TO CONTACT US?" below.

This Policy covers the following topics:

1. WHAT INFORMATION WE COLLECT
2. MINORS
3. PURPOSES AND CONDITIONS FOR PROCESSING PERSONAL INFORMATION
4. MARKETING
5. WITH WHOM WE SHARE INFORMATION
6. INTERNATIONAL TRANSFER OF INFORMATION
7. THIRD-PARTY TRACKING TECHNOLOGIES
8. RETENTION OF PERSONAL INFORMATION
9. YOUR RIGHTS
10. CHANGES TO THE PRIVACY POLICY
11. LANGUAGE VERSION
12. HOW TO CONTACT US
13. SUPPLEMENTAL CALIFORNIA STATE LAW NOTICE ("SUPPLEMENTAL NOTICE")

1. WHAT INFORMATION WE COLLECT

We collect Personal Information from users and visitors of our Service, including:

• Registration and Login: When you open an account and register to use our Service, you will be asked to provide details such as your email address, username, and password. When updating your account profile, we also collect additional Personal Information from you.
• Identification Documentation: We collect and store uploaded documents to identify customers, process requests, and comply with applicable laws and regulations. These documents are also used to prevent and detect fraud, money laundering, and terrorist funding.
• Payment Information: While we do not directly access or use your payment information, our trusted third-party payment processors collect certain payment details, such as credit card numbers and bank account details, to facilitate your use of the Service.
• Voluntary Information: We collect information that you voluntarily provide to personalize your account or for specific functions, including communications with us, feedback, and additional information shared through your use of the Service.
• Device Information: We collect connection details and information about your device, software, or hardware that could identify you, such as unique device identifiers (e.g., UDID, IMEI, MAC address), browser fingerprinting, IP address, blockchain address, wallet type, and geo-location data.
• Information from Third Parties: We collect Personal Information from third-party service providers to verify your identity and prevent fraudulent or illegal activity.
• Log-in History and Technical Information: We collect technical information transmitted by your device to enhance the functionality of the Service and provide a better user experience.
• Analytics Information: We collect information about your use of the Service, such as application usage, log files, user activity (e.g., pages viewed, user movements, time spent, online browsing, clicks, actions), timestamps, and alerts for troubleshooting errors and research purposes.

2. MINORS

We do not sell or share Personal Information of users under the age of 18. Our Services are not intended for persons under the age of 18 or the age of legal consent in any applicable jurisdiction, whichever is higher ("Legally of Age"). If you are not Legally of Age, do not use the Services or provide any Personal Information to us. We reserve the right to verify any Personal Information collected from you. If we become aware that a user who is not Legally of Age has shared any information, we will discard it. If you believe a minor has shared information with us, please contact us at DPO@wercams.com.

3. PURPOSES AND CONDITIONS FOR PROCESSING PERSONAL INFORMATION

This section outlines the purposes and legal bases for processing your Personal Information:

Purpose	Legal Basis
Provision of our Service; Support and Customer Relations: We use your Personal Information for customer service, account management, service operation, and responding to inquiries and user rights requests.	Performance of contractual obligations (Art. 6.1(b) GDPR/UK GDPR); your consent (Art. 6.1(a) GDPR/UK GDPR); compliance with legal obligations (Art. 6.1(c) GDPR/UK GDPR); legitimate interests (Art. 6.1(f) GDPR/UK GDPR). Legitimate interests include enforcing policies and protecting against fraud and misuse.
Improving our Service: We analyze information about your use of our Service to improve its usability and effectiveness, including debugging and internal research.	Legitimate interests (Art. 6.1(f) GDPR/UK GDPR) in providing and improving our Service.
Marketing, Advertising, and Analytics: We use your Personal Information for advertising (including behavioral and non-personalized ads), marketing our Service, and gathering usage information for analytics.	Consent (when required) and legitimate interests (Art. 6.1(a), 6.1(f) GDPR/UK GDPR). Legitimate interests include providing tailored services, content, and ads, and promoting our Service.
Integrity: We process information to maintain the integrity and security of the Services.	Compliance with legal obligations (Art. 6.1(c) GDPR/UK GDPR); legitimate interests (Art. 6.1(f) GDPR/UK GDPR). Legitimate interests include ensuring the integrity of our Services and user safety.
Payments: We use third-party payment processors to connect your payment instruments to your account.	Performance of contractual obligations (Art. 6.1(b) GDPR/UK GDPR); legitimate interests (Art. 6.1(f) GDPR/UK GDPR), including enforcing policies and preventing misuse; compliance with legal obligations (Art. 6.1(c) GDPR/UK GDPR).
Dispute Resolution and Legal Claims: We collect information to investigate policy violations, resolve disputes, and establish and defend legal claims.	Legitimate interests (Art. 6.1(f) GDPR/UK GDPR) in establishing and defending legal claims.
Corporate Transactions: We share information with potential purchasers or investors during corporate transactions.	Legitimate interests (Art. 6.1(f) GDPR/UK GDPR).
Fraud Prevention: We process information to detect and prevent fraudulent and illegal activity and enforce policies.	Legitimate interests (Art. 6.1(f) GDPR/UK GDPR) in protecting against fraud.
Compliance with Laws: We process information to comply with various legal obligations, such as identity verification and data subject rights compliance.	Compliance with legal obligations (Art. 6.1(c) GDPR/UK GDPR); legitimate interests (Art. 6.1(f) GDPR/UK GDPR).

Where you have not consented (or have withdrawn consent) to our processing of your Personal Information, we will continue processing it as necessary for (a) the performance of our contract (Terms of Use), (b) compliance with legal obligations, or (c) our legitimate interests (including marketing).

Special Categories of Personal Data

In certain instances, our processing of your Personal Information may include special categories of personal data as defined under Article 9 of the GDPR/UK GDPR. We only process such information when it is strictly necessary for the following purposes and to the extent permitted by applicable law: (i) prevention or detection of unlawful acts; (ii) prevention of dishonesty, malpractice, or other seriously improper conduct where obtaining your consent would prejudice these purposes. Disclosure of this information to competent authorities, such as law enforcement bodies, will also follow these strict guidelines.

4. Marketing

We use your Personal Information, including your email address, to provide you with promotional materials through various marketing techniques, such as direct email and post. This includes information about our Service and products, services, websites, and applications related to the Company's business partners and affiliates, like the website cybersays.club (collectively, "Marketing Affiliates"), which we believe may interest you.

We will only use your Personal Information for marketing purposes where we have a legitimate interest or your affirmative consent. You can opt out of receiving further marketing communications from us or our business partners at any time by following the unsubscribe link in the promotional emails or contacting our customer support. Even if you opt out of marketing emails, we will still send you service-related updates and notifications.

5. With Whom We Share Information

We do not rent, sell, or share your Personal Information with third parties ("Recipients") except as described in this Privacy Policy. Personal Information is disclosed to Recipients only to the extent necessary for the specific purposes outlined in this Policy. Recipients may include:

• Affiliated companies;
• Subcontractors and third-party service providers, including cloud computing companies, marketing affiliates, identity verification and fraud prevention services, and data verifiers;
• Payment service providers, payment processors, and banks;
• Third parties providing services related to the operation or promotion of the Services;
• Auditors, contractors, or advisors involved in any of the Company’s business processes;
• Third parties investigating, detecting, or preventing fraudulent or illegal activities, such as governmental authorities, police, banks, and other investigatory organizations;
• Governmental and regulatory bodies, as required by applicable laws and regulations;
• Potential purchasers or investors in the Company or any of its affiliates, particularly in the event of a corporate transaction, such as a sale, merger, reorganization, bankruptcy, consolidation, or asset sale.

6. International Transfer of Information

Given the global nature of our operations, we may need to transfer your Personal Information to countries outside the European Economic Area ("EEA"). The data protection laws in these countries may not be as comprehensive as those within the EEA. To ensure the protection of your Personal Information, we use contractual means, such as standard contractual clauses approved by the European Commission, or other mechanisms to provide an adequate level of protection.

For more information on the international transfer of your Personal Information, please refer to our contact details in the section "HOW TO CONTACT US?"

7. Third-Party Tracking Technologies

We use third-party advertising technologies on our Websites to serve advertisements when you visit or use our Services. These technologies include web beacons, cookies, pixels, scripts, tags, and other tracking technologies ("Tracking Technologies"). They automatically collect information about your online behavior and device to improve and personalize your navigation and enhance our Services' performance. Third parties also use this information to provide targeted content.

You can set your browser to refuse third-party cookies or to alert you when cookies are being sent. Additionally, you can opt out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA").

For more information on these practices and how to opt out, please visit our Cookie Notice at Cookie Policy and the respective websites of NAI and DAA: NAI Opt-Out and DAA Choices.

8. Retention of Personal Information

If you have registered an account with our Services, we will retain your Personal Information while your account is active. Additionally, we will keep your Personal Information for as long as necessary to comply with our legal obligations, such as Know-Your-Customer and Anti-Money Laundering regulations. We may also retain your information for longer periods to meet our legitimate interests, such as fraud prevention and record-keeping.

If you wish to delete your Personal Information, please contact us at DPO@wercams.com. We will make reasonable efforts to accommodate your request.

9. Your Rights

You have certain rights concerning the collection and processing of your Personal Information. To exercise these rights, please contact us using the details provided in the section "HOW TO CONTACT US?" Your rights include:

1. Right of access: Obtain a copy of your Personal Information held by the Company.
2. Right to data portability: Receive your Personal Information in a structured, commonly used, machine-readable format, and request its transmission to a third party.
3. Right to rectification: Request correction of inaccurate, incomplete, or outdated data (unless retention in original form is required by law).
4. Right to erasure: Request deletion of your Personal Information, understanding that this may affect your ability to use the Service.
5. Right to restrict or object to processing: Request the Company to limit or cease certain data processes, provided no other lawful basis for processing exists.
6. Right to withdraw consent: Withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
7. Right to lodge a complaint: Address complaints to Privacy@Wercams.com. If unsatisfied, you can also file a complaint with the relevant data protection authority.

Please note that these rights are not absolute and are subject to our legitimate interests and regulatory requirements. Contact us with any questions, requests, or complaints. We aim to respond promptly. If you are unsatisfied with our response, you can lodge a complaint with the competent supervisory authority.

If you have not registered an account on our Website, we may not have sufficient information to identify you. We may request additional information to verify your identity and handle your request appropriately.

10. Changes to the Privacy Policy

We reserve the right to modify this Policy at any time, so we encourage you to revisit this page regularly. We will make reasonable efforts to notify you of substantial changes to this Policy as required by law. Any amendments, updates, or alterations will become effective upon publication of the revised Privacy Policy on our Websites with the "Last Revised" date indicated. Your continued use of the Service after the Last Revised date constitutes acceptance of and agreement to be bound by those changes.

11. Language Version

This Policy has been drafted in English, which is the original and controlling version. Translations of this Policy into other languages are provided solely for convenience and do not control the meaning or application of this Policy. In cases where there is a discrepancy between the meanings of translated versions of the Policy and the English language version, the English version shall prevail.

12. How to Contact Us

For general inquiries about our Services or how we use your information, please contact us via email at DPO@wercams.com or by mail:

For EU representative contact:

• Privacy@wercams.com.

We strive to respond promptly and address any concerns you may have. If you are dissatisfied with our response, you have the right to contact the appropriate data protection supervisory authority.

13. Supplemental California State Law Notice ("Supplemental Notice")

This section addresses specific requirements under the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (Cal. Civ. §§ 1798.100–1798.192) ("CCPA") and any subsequent amendments.

13.1 Categories of Personal Information and Sharing

We may share your Personal Information with the third parties listed in Section 5 of this Policy. However, we do not sell your Personal Information.

In the preceding 12 months, we have/not disclosed, shared, or sold the following categories of Personal Information:

Category of Personal Information	Examples	Categories of Third Parties	Disclosure, Sharing, or Sale of Personal Information
Identifiers or Members	Real name, email address, account name	Auditors, contractors, governmental authorities	Not sold
Visual data	Photos, videos	Marketing affiliates	Shared
Protected classification characteristics	Gender identity, sexual orientation, race	Marketing affiliates	Shared
Commercial data	Service records, consumption history	Subcontractors, cloud computing companies	Shared
Internet or other electronic network activity data	Browsing history, interaction information	Marketing affiliates	Shared
Geolocation data	Device location	Cloud computing companies, data verifiers	Shared
Inferences drawn from other Personal Information	User profiles	Marketing affiliates	Shared
Sensitive Personal Information	State identification, precise geolocation	Identity verification, fraud prevention services	Shared

13.2 Sources of Personal Information

In the past 12 months, we have collected Personal Information from:

• Consumers directly
• Advertising networks
• Internet service providers
• Data analytics providers

13.3 Your Additional Rights

In addition to the rights outlined in Section 9 ("Your Rights"), if you are a California resident, you may exercise the following rights:

1. Right to limit use and disclosure of sensitive Personal Information: You can request limits on the use and disclosure of your sensitive Personal Information for specific business purposes.
2. Right to Opt-Out of the Sale or Share of Personal Information: If we sell your Personal Information, you have the right to opt-out of such sales. After opting out, we may continue to disclose some Personal Information for business-related purposes.
3. Right to non-discrimination: You have the right not to face discrimination for exercising your privacy rights. This includes differences in service quality or pricing.

You can challenge our decisions regarding your rights request by contacting DPO@wercams.com. We will review and arbitrate your appeal in accordance with applicable laws.

13.4 Authorized Agent

You may designate an authorized agent to act on your behalf to exercise your rights under applicable laws. To proceed, your authorized agent must:

• Be a natural person or business entity
• Provide a signed declaration authorizing them to act on your behalf

To use an authorized agent, please send us a certified copy of your written declaration to the contact details provided under "HOW TO CONTACT US?" Ensure the declaration includes sufficient information for us to verify your identity and understand your request.

Please note, we cannot fulfill your request or provide Personal Information if we cannot verify your identity. Verifiable consumer requests do not require an account with us and are processed solely for identity verification purposes.