Overwolf Developer Privacy Policy

Last Updated: July 09, 2024

This privacy policy (“Privacy Policy” or “Policy”) describes how Overwolf Ltd. (“Overwolf”, “we”, “us”, or “our”) collect, use and disclose certain information, including your personal information and the choices you can make about that information.

This Privacy Policy which is incorporated by reference to Overwolf Developers Terms and Conditions (together the “Terms”), governs our processing practices when you use, develop or distribute your App within the Developer Platform.

It is hereby clarified that this Privacy Policy governs solely the Personal Information collected from the Developers when interacting with the Developer Platforms and this Privacy Policy shall not apply in the following cases:

• You are a visitor of our online website https://www.overwolf.com/ Please see our Website Privacy Policy for more information on how your personal information will be collected and processed by us.

• You are an end user of our Overwolf Platform or Curseforge. Please see our Platform Privacy Policy for more information on how your personal information will be collected and processed by us.

Please note that this Privacy Policy governs solely the collection and processing of the Developer Personal Information and not Personal Information of End Users that is collected and processed when they engage and use the Developer's application and services. The processing of the such end user's data shall be subject of the terms of Overwolf Data Processing Agreement between Overwolf and the Developer.

Overwolf participates in the IAB Transparency & Consent Framework and complies with its Specifications and policies. Overwolf's CMP number within the framework is 246.

Overwolf's use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements

1. PRIVACY NOTICE

1.1 POLICY AMENDMENTS:

We reserve the right to amend this Policy from time to time, at our sole discretion. The most recent version of the Policy will always be posted on the website. The updated date of the Policy will be reflected in the “Last Modified” heading. We will provide notice to you if these changes are material, and, where required by applicable law, we will obtain your consent. Any amendments to the Policy will become effective within 30-days upon the display of the modified Policy. We recommend you review this Policy periodically to ensure that you understand our most updated privacy practices.

1.2 CONTACT INFORMATION AND DATA CONTROLLER INFORMATION:

Overwolf Ltd. incorporated under the laws of Israel, and it is the controller of your Personal Data.

You may contact us and our DPO as follows:

Kontaktieren Sie uns

Overwolf, Ltd.
Data Protection Officer: dpo@overwolf.com.
Per Post:Sapir Tower, 40 Tuval St. Ramat Gan, Israel, 5252247.

Representative for data subjects in the EU and UK Contact Information:

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g., requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website. https://prighter.com/q/13682628040

1.3 DATA SETS WE COLLECT AND FOR WHAT PURPOSE:

You can find here information regarding the purposes for which we process your personal data as well as our lawful basis for processing, the definition of “personal” and “non-personal” data, and how it is technically processed.

Non-Personal Data

During your interaction with our Developer Platform, we may collect aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Developer Platform (“Non-Personal Data “). We are not aware of the identity of the user from which the Non-Personal Data is collected. The Non-Personal Data being collected may include your aggregated usage information and technical information transmitted by your device, such as: the type of browser or device you use, language preference, time and date stamp, country location, etc.

Personal Data

We may also collect from you, directly or indirectly, during your access or interaction with the Developer Platform, individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual (“Personal Data”). The types of Personal Data that we collect as well as the purpose for processing and the lawfulness are specified in the table below.

We do not knowingly collect or process any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person's health or data concerning a person's sex life or sexual orientation (“Special Categories of Personal Data”).

The table below details the processing of Personal Data, the purpose, lawful basis, and processing operations:

DATA SET	PURPOSE AND OPERATIONS	LAWFUL BASIS
Account Data: When you install our Developer Platform, you may choose to create an account. Through the registration process you are required to provide us during Personal Data, such as your name, email address, etc. In case you decide to register and create account by connecting your Gmail account we will use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirementsFurther, you will be requested to provide your payment details such as your bank account number, billing address, country, etc. All together shall refer as "Account Data".	Account Data is processed solely to provide execute our engagement with you.	We process the Account Data for the purpose of fulfilling our contract obligations with.
Online Identifiers and Usage Data: When you use our Developer Platforms, we will collect certain online identifiers such as: IP address, machine ID, cookie ID, agent ID, and other unique identifiers (“Online Identifiers”). We may further collect information related to your interaction with the Developer Platforms, features used, duration of use, click stream, errors that occurred, etc. (“Usage Data”). The Usage Data is usually connected to an Online Identifier.	Online Identifiers and Usage Data are used for analytics and operational purposes, correcting errors and bugs, adjust language preference, if applicable, to enable you to use the Developer Platform and to provide you with its functionalities.	When the processing of Personal Data is for operations and providing the Developer Platform functionalities, the lawful basis would be contract necessity. Last, the Personal Data maybe processed subject to our legitimate interest of understanding how our services are used, correcting errors and enhancing experience.
Direct Marketing: As a Developer, we will send you invoices, materials and marketing content through the email information you provided during your onboarding.	We will use this information to keep you updated with offers and content such as updates, new capabilities and features, and to send you supporting documentation.	We process such information subject to our legitimate interest. You can opt-out at any time, however certain content (such as invoices) will still be sent.
Support: When you contact us for support, we will process your contact information such as name and email address, and any other information you related to your request.	We process the information solely to provide you with the technical support needed.	Processed for the purpose of fulfilling our contract obligations with.

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of personal data to third-party countries, as further detailed in the Data Transfer Section, is based on the same lawful basis as stipulated in the table above.

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Developer Platforms and to enforce the Terms, as well as to protect the security or integrity of our databases and the Developer Platforms, and to take precautions against legal liability. Such processing is based on our legitimate interests.

We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Developer Platforms provided through the Developer Platform, as detailed above. If we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data or for as long as it remains combined.

1.4 HOW WE COLLECT YOUR INFORMATION:

Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows:

• Automatically, when you use our Developer Platform, including through the use of Cookies (as detailed below) and similar tracking technologies.

• When you voluntarily choose to provide us with information, such as when you contact us, all as detailed in this Policy.

• Provided from third-parties, such as our partner, applicable cookie management platforms and etc.

1.5 COOKIES AND SIMILAR TECHNOLOGIES:

We use “cookies” (or similar tracking technologies) when you use our Platform. The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a webpage. We will use cookies for various purposes such as:

• Essential Cookies - which are strictly necessary for the website to work correctly (usually appear under our name/cookie tag);

• Functional Cookies - designated to save your settings on the Platform - your language preference or other view preferences (also, under our name/cookie tag);

• Session Cookies - used to support the Platform's functionality - such Cookies are usually stored only temporarily during a browsing session and are deleted from your device when you close the browser.

• Analytics Cookies - give us aggregated and statistical information to improve the services and further develop it.

You can find more information about our use of cookies here.

1.6 DATA SHARING - CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:

We share your data with third parties, including our partners or service providers that help us provide our Developer Platforms. You can find here information about the categories of such third-party recipients.

CATEGORY OF RECIPIENT	DATA THAT WILL BE SHARED	PURPOSE OF SHARING
Service Providers	All data	We may disclose Personal Data to our service providers, contractors and third parties, including, but not limited to, our cloud and hosting provider, analytics and marketing providers, CRM systems, Salesforce, etc., the service providers are limited by contracts which limit their use of the data, and requires implementing security measures. The service providers process the data solely to provide the needed services. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services.
Any acquirer of our business	All data	We may share Personal Data, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy.
Governmental agencies, or authorized third parties.	Subject to law enforcement authority request.	We may disclose certain data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose.

When we share information with services providers and Partners, we ensure they only have access to such information that is strictly necessary for us to provide the Developer Platforms. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).

1.7 DATA RETENTION:

In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you express your preference to optout, where applicable.

Other circumstances in which we will retain your Personal Information for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.

1.8 SECURITY MEASURES:

We work hard to protect the Personal Data we process from unauthorized access, alteration, disclosure, or destruction. We have implemented physical, technical, and administrative security measures for the Developer Platforms that comply with applicable laws and industry, such as encryption using SSL, we minimize the amount of data that we store on our servers, restricting access to Personal Data to Overwolf employees, contractors, and agents, etc. as we further explain in our Security Policy. Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty, express, implied, or otherwise, that we will always be able to prevent such access.

Please contact us at: dpo@overwolf.com (or developers@overwolf.com) if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party's attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

1.9 INTERNATIONAL DATA TRANSFER:

Our data servers in which we host and store the information are located in the US, EU, UK (including AWS hosting servers). The Company's HQ are based in Israel in which we may access the information stored on such servers or other systems such as the Company's ERP, CRM, Salesforce, and other systems. In the event that we need to transfer your Personal Data out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Furthermore, when Personal Data that is collected within the European Economic Area ("EEA") is transferred outside of the EEA to a country that has not received an adequacy decision from the European Commission, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union. Thus, we will obtain contractual commitments or assurances from the data importer to protect your Personal Information, using contractual protections that EEA and UK regulators have pre-approved to ensure your data is protected (known as standard contract clauses), or rely on adequacy decisions issued by the European Commission. Some of these assurances are well-recognized certification schemes.

1.10 USER RIGHTS

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.

You may exercise any or all of your above rights in relation to your Personal Data by filling out a Data Subject Request (“DSR”) using the following link: https://support.overwolf.com/en/support/tickets/new or by sending us an e-mail to dpo@overwolf.com. More information about how you can independently exercise your rights, can be found here (Deletion of accounts and Data) and here (Exporting Your Data).

You have the right to lodge a complaint with the EU Member State supervisory authority if you are not satisfied with the way in which we handled the complaint.

For additional rights under various jurisdictions, please refer to Section “JURISDICTION-SPECIFIC NOTICES” herein below.

1.11 ELIGIBILITY AND CHILDREN PRIVACY:

The Developer Platforms are not intended for use by individuals below the age of 18, and we do not knowingly process children's information. We will discard any information we receive from a user that is considered a "child" immediately upon discovering that such a user shared information with us. Please contact us at: dpo@overwolf.com if you have reason to believe that a child has shared any information with us.

2. JURISDICTION-SPECIFIC NOTICES:

2.1 ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) effective November 2020, and as amended by the CPRA, effective January 1, 2023.

Please see the CCPA Privacy Notice which discloses the categories of personal information collected, purpose of processing, source, categories of recipients with whom the personal information is shared for a business purpose, whether the personal information is sole or shared, the retention period, and how to exercise your rights as a California resident.

2.2 ADDITIONAL NOTICE TO COLORADO RESIDENTS

Under the Colorado Privacy Act (“CPA”) if you are a resident of Colorado, acting only as an individual or household context (and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context), your rights with respect to your personal data are described below.

“Personal Data” as defined in the CPA means: “information that is linked or reasonably linkable to an identified or identifiable individual” and does not include any of the following: publicly available information, de-identified or aggregated consumer, and information excluded from the CPA scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) or 42 CFR Part 2- “Confidentiality Of Substance Use Disorder Patient Records”, Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or and the Driver's Privacy Protection Act of 1994, Children's Online Policy Protection Act of 1998 (COPPA), Family Educational Rights and Privacy Act of 1974, national Security Exchange Act of 1934, higher education data and employment data.

Sensitive Data includes (i) racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life or sexual orientation; (ii) Genetic or biometric data that can be processed to uniquely identify an individual; or (iii) child data. We do not process or collect any sensitive data.

Section 1.3 “DATA SETS WE COLLECT AND FOR WHAT PURPOSE” of the Privacy Policy, we describe our collection and processing of personal data, the categories of personal data that are collected or processed, and the purposes. Additionally, in Section 1.6 “DATA SHARING - CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH” details the categories of third-parties the controller shares for business purposes.

2.2.1 YOUR RIGHTS UNDER CPA:

Herein below, we will detail how consumers can exercise their rights, and appeal such decisions.

Right to Access/ Right to Know	You have the right to confirm whether and know the Personal Data we collected on you	You can exercise your right by reviewing this Privacy Policy, in case you would like to receive the Personal Data you can submit a request using the following link: https://support.overwolf.com/en/support/tickets/new or contact us by sending us an e-mail to dpo@overwolf.com with a request to receive a copy of your data
Right to Correction	You have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.	You can exercise this right directly through your account or by submitting a request using the following link: https://support.overwolf.com/en/support/tickets/new or contact us by sending us an e-mail to dpo@overwolf.com
Right to Deletion	You have the right to delete the Personal Data, this right is not absolute and in certain circumstances we may deny such request. We may deny your deletion request, in full or in part, if retaining the information is necessary for us or our service provider(s) for any of the following reasons: (1) Complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you; (2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (3) Debug products to identify and repair errors that impair existing intended functionality; (4) Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (5) Comply with the law or legal obligation; (6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent; (7) Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (8) Make other internal and lawful uses of that information that are compatible with the context in which you provided it. We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our processors to take similar action.	If you would like to delete your Personal Data you can submit a request using the following link: https://support.overwolf.com/en/support/tickets/new or contact us by sending us an e-mail to dpo@overwolf.com You do not need to create an account with us to submit a request to know or delete.
Right to Portability	You have the right to obtain the personal data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.	If you would like to receive the Personal Data you can submit a request using the following link: https://support.overwolf.com/en/support/tickets/new or contact us by sending us an e-mail to dpo@overwolf.com to receive a copy of your data we will select a format to provide your Personal Data that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
Right to Appeal	If we decline to take action on your request, we shall so inform you without undue delay, within 45 days of receipt of your request. The notification will include a justification for declining to take action and instructions on how you may appeal.If we deny the appeal, you may contact the Colorado Attorney General using this link: https://coag.gov/office-sections/consumer-protection/ or (720) 508-6000.	Not more than 60 days after receipt of an appeal we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reason for the decisions.
Duty not to violet the existing laws against discrimination or non-discrimination	Such discrimination may include denying a good or service, providing a different level or quality of service, or charging different prices.	We do not discriminate our users.

2.2.2 HOW TO SUBMIT A REQUEST UNDER CPA?

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Data. If the DSR is submitted by someone other than the consumer about whom information is being requested, proof of authorization (such as power of attorney or probate documents) will be required.

We will respond to your request within 45 days after receipt of a verifiable Consumer Request and for no more than twice in a twelve-month period. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at dpo@overwolf.com and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Colorado AG at https://coag.gov/file-complaint/

If you have an account with us, we may deliver our written response to that account or via email at our sole discretion. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You do not need to create an account for submitting a request.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

2.3 ADDITIONAL NOTICE TO VIRGINIA RESIDENTS

Under the Virginia Consumer Data Protection Act, as amended (“VCDPA”) if you are a resident of Virginia acting in an individual or household context (and not in an employment or commercial context), you have the following rights with respect to your Personal Data.

"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information. Personal Data does not include de-identified data or publicly available data, and information excluded from the scope such as: HIPAA, GBPA, non-profit entities, higher education, employment data and FCRA, Driver's Privacy Protection Act of 1994, Family Educational Rights and Privacy Act, Farm Credit Act.

The VCDPA requires Overwolf discloses the Categories of data processing and the purpose of each category, as detailed in Section 1.3 “DATA SETS WE COLLECT AND FOR WHAT PURPOSE” of the Privacy Policy, the categories of data shared and the third parties with whom it is shared, as detailed in Section 1.6 “DATA SHARING - CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH”. Further, the table above under Section 2.2 “ADDITIONAL NOTICE TO COLORADO RESIDENTS” details the rights you have under VCDPA and how you may exercise your rights.

2.3.1 HOW TO SUBMIT AN APPEAL UNDER VCDPA?

We shall respond to your request within 45 days of receipt. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period of time by contacting us at dpo@overwolf.com and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

2.4 ADDITIONAL NOTICE TO CONNECTICUT RESIDENTS

Under the Connecticut Data Privacy Act, Public Act. No. 22-14 (the “CDPA”) if you are a resident of Connecticut, acting in an individual or household context (and not in a commercial or employment context or as a representative of a business, non-profit or governmental entity), your rights with respect to your personal data are described below.

"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable individual. It does not include de-identified data or publicly available information. If further does not include information excluded from the scope such as: HIPAA, GBPA, non-profit entities, higher education, employment data and FCRA, Driver's Privacy Protection Act of 1994, Family Educational Rights and Privacy Act, Farm Credit Act.

The categories of personal data processed, purpose of processing, are detailed in Section 1.3 “DATA SETS WE COLLECT AND FOR WHAT PURPOSE”, categories of personal data shared with third parties, categories of third parties with whom data is shared, are detailed in Section 1.6 “DATA SHARING - CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH”.

Instructions on how to exercise your rights are detailed in the table above under Section 2.2 “ADDITIONAL NOTICE TO COLORADO RESIDENTS” details the rights you have under CDPA and how you may exercise your rights.

2.4.1 HOW TO SUBMIT AN APPEAL UNDER CDPA?

We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests and we inform you of such extension within the initial 45 days response period, together with the reason for the extension.

If we decline to take action on your request, we shall so inform you without undue delay, within 45 days of receipt of your request. The notification will include a justification for declining to take action and instructions on how you may appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Connecticut Attorney General at link: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

2.5 ADDITIONAL NOTICE TO UTAH RESIDENTS (effective January 2024)

Under the Utah Consumer Privacy Act (the “UCPA”) if you are a resident of Utah, acting in an individual or household context (and not in a commercial or employment context) your rights with respect to your personal data are described below. “Personal Data" refers that is linked or reasonably linkable to an identifiable individual, and does not include de-identified data and publicly available data.

The categories of personal data processed, purpose of processing, are detailed in Section 1.3 “DATA SETS WE COLLECT AND FOR WHAT PURPOSE”, categories of personal data shared with third parties, categories of third parties with whom data is shared, are detailed in Section 1.6 “DATA SHARING - CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH”.

Further, the table above under Section 2.2 “ADDITIONAL NOTICE TO COLORADO RESIDENTS” details the rights you have under CDPA and how you may exercise your rights.

2.6 NOTICE TO NEVADA RESIDENTS

Nevada law allows Nevada residents to opt out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We currently do not sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and will record your instructions and incorporate them in the future if our policy changes. You may send opt-out requests to dpo@overwolf.com or by submitting a ticket using the following link: https://support.overwolf.com/en/support/tickets/new