Date: 12.10.2023

The purpose of this Privacy Policy is to inform the Walken Sketch Mobile Application users as to the information we collect, what we do with this information, and how your information is protected. This Privacy Policy will outline our information administration practices in relation to the information we acquire at Walken Sketch Mobile Application and affiliated services. At all times, Walken Sketch Mobile Application strives to uphold the privacy of individuals and abides by the laws, principles and regulations of the British Virgin Islands. ‘Walken Sketch’ refers to the operators of the WalkenSketch Mobile Application, as well as to any services or products offered by or in connection to the operators of that domain and application, or any associated applications or services.

When you access our Website, Mobile Application or Extension we automatically collect from your device language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and other unique identifiers (such as IDFA and AAID). We need this data to provide our services, analyze how our customers use the Walken Sketch and to serve ads.

For improving the Walken Sketch and serving ads, we may share this data with third parties.As a result of sharing this data with third parties we (1) analyze different interactions (what products our users have viewed); (2) serve ads (and show them only to a particular group of users, for example, to those who have added a product to a cart).

Where applicable, if you do not provide us the relevant Personal Data, you may not be able to use our Services completely. You should not use the Services if you do not agree with this Policy, our Terms of Use and any other agreement that governs your use of the Services.

BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such a case, you must (a) contact us and request deletion of your data; and (b) leave the Service and not access or use it.

If any questions remain unanswered, please contact us at [email protected].

Privacy Policy Consent

By using the Walken Sketch Mobile Application and its affiliated services, you consent to the Privacy Policy and its information administration practices. Walken Sketch Application may provide additional disclosures in relation to the privacy policy. These documents will apply supplementary to Walken Sketch’s Privacy Policy. These disclosures may expand on information administration practices or provide further clarification for specific practices.

If you disagree with or are not comfortable with any aspect of Walken Sketch Application’s Privacy Policy, you should immediately cease the use of Walken Sketch’s services.

Changes to the Privacy Policy

Walken Sketch reserves the right to alter and/or modify this privacy policy at any time. Please review this policy periodically in case of any changes.

If any significant or substantive Privacy Policy Amendments are made, we will notify you by email.

Who Does Walken Sketch’s Privacy Policy Apply To?

Walken Sketch’s Privacy Policy applies to users of Walken Sketch’s services, including individuals, merchants, and legal entities.

Walken Sketch’s users are those who use and/or purchase Walken Sketch Mobile Application or affiliated services.

What Personal Information Do We Collect?

Walken Sketch only collects information that is vital to the provision of our services.

The information that we may collect includes, but is not limited to:

1. Identification Information:email, wallet number.
2. Technical data and User Information:we may collect certain device information, including the following:
1. Devise make, model, and operating system;
2. Device properties related to screen size, orientation, audio, battery, device memory usage, setting, and boot time;
3. Device settings related to accessibility features, front size, theme;
4. Carrier;
5. Operating system;
6. Name and properties of mobile application through which a consumer interact with the Services;
7. Country, time zone, and locate settings (country and preferred language);
8. City- and/or country-level or other coarse geolocation data;
9. Network connection type and speed;
10. IP Address;
11. Internet browser user-agent used to access the Services;
12. HTTP header information;
13. Advertising IDs (IDFA/GAID/Amazon FOSAID);
14. Vendor IDs (IDFV); and
15. Advertising and tracking preferences and restrictions.
3. Usage Data (Events):Indicates if the activity happened on mobile or web; Length of user's last session, in seconds; Length of user's current session, in seconds; Number of sessions recorded; Push notification token, i.e., registration token (Android), device token (iOS); clicks on User’s ads; the type of ads and the webpage or Application from which such ads were displayed; downloads and installations of applications.
4. Diagnostic information:for example, logs, error reports and events and the type, number, date and page relating to this information.

Why Do We Collect This Information?

1. To Create a Better Experience for Our Clients

The collection of data will allow us update and create new services that will better meet our client’s needs. At Walken Sketch, we endeavour to create a more personalised experience for our clients.

Providing Service includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.

As a result of this processing, we will use your e-mail, for example, to register in the application. To do this, we give you the opportunity to register through a Google account or Facebook.

In order to transfer a possible prize to you, we ask you for your wallet details. You can use any crypto wallet or register it on the Walken app.

To host personal data and enable our Website to operate and be distributed we use Firebase Hosting, which is a hosting and backend service provided by Google LLC. We use Firebase Performance Monitoring, which is monitoring service provided by Google.

We also use the AppLovin SDK services provided by AppLovin Corporation to provide analytics and improve the quality of our services.

2. To Protect Our Clients

We collect your personal data to ensure the Service providing, to analyze your behavior during the usage of our Service, to add new features to our Service and to provide our third-party service providers with information, crucial for their services.

Providing Service includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.

3. To Comply with Regulatory Requirements

The services offered by Walken Sketch are subject to international regulations which require us to collect your personal information.

4. To Enforce our Terms in Our User Agreement

It is important for Walken Sketch to regulate its services and its customers relating to the prevention and mitigation of any potentially prohibited activities, enforcing our agreements with third parties, and violations of our user agreement. For these purposes, it is essential for Walken Sketch to collect user data.

If Walken Sketch is unable to process user information for these reasons, the consequence is the termination of your account as we cannot perform our services in accordance with our terms.

5. Maintain your Registration as a Client

This will allow you to access your account safely and securely whenever and wherever you wish.

6. Ensure Quality Control

We store user information for quality control and staff training, to ensure we provide users with accurate information.

7. Marketing Activities

We may send you marketing or promotional offers to inform you of Walken Sketch Application or affiliates’ events, to deliver targeted marketing, and to provide you with promotional offers based on your communication preferences. We use information relating to your usage of Walken Sketch and contact information to provide a better marketing experience.

Who Will We Share Your Information With?

Information that Walken Sketch Application collects may or may not be used or disclosed to:

• We, Move To Play Holdings LTD;
• Google Inc. (analytics) https://policies.google.com/privacy, https://firebase.google.com/terms/analytics/ ;
• Adjust GmbH (analytics platform) https://www.adjust.com/terms/privacy-policy/;
• AppLovin Corporation’s services, including but not limited MaxSdk (for marketing, analytics and advertising) https://www.applovin.com/privacy/ ;
• FacebookSDK (analytics platform) https://opensource.fb.com/legal/privacy;
• Stripe (payment service) https://stripe.com/privacy;
• Recurly (payment service) https://recurly.com/legal/privacy/;
• Amazon Web Services, Inc. (analytics platform) https://aws.amazon.com/privacy/;
• Individuals, entities, organisations, as part of Walken Sketch related services to clients and includes, but is not limited to, experts, tribunals, law firms, and other associated professionals;
• Persons the client has expressly authorised or consented;
• Walken Sketch’s associated commercial and business partners, which include, but are not limited to, professional advisors, commercial organisations, and business agents;
• Comply with legal obligations or requirements;
• Develop business and commercial relationships;
• Law enforcement agencies and other public authorities. We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.
• Third parties as part of a merger or acquisition. As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
• Respond to any enquiries where necessary; and
• All other matters, services, engagements, business developments, and commercial enterprises to the maximum extent permitted by law.

How Is Your Information Protected?

Walken Sketch considers our user privacy to be of great importance. That is why we have implemented multiple security measures to ensure that client data is secure, free from unauthorised access, alteration, disclosure, and destruction. For example, we implement the following security measures:

• Security procedures within our offices;
• IT security procedures including password protection, site monitoring, firewalls; and
• Mandatory confidentiality guidements for all staff within the business.

However, despite the measures we have in place, data protection is never completely secure. We cannot guarantee the security of your personal information.

Your consent. Term of storage of your personal data.

The User hereby freely gives, specific, informed and unambiguous consent to the processing of the personal data relating to the User and mentioned above for the purposes of personal data processing indicated above.

For the purposes of analytics and advertising, we use services and solutions provided by third parties. Such parties process data on our behalf and the respective technical solutions represent a part of the Services. Any transfer of your Personal Data is based on a written agreement, and we make sure such a third party complies with the applicable data protection regulations. Such third parties process Personal Data in accordance with their own privacy policies. Please, check privacy policies of such third parties.

In certain cases we may transfer information about you to other third parties (for example, independent personal data controllers), if we are obliged or allowed to do so by applicable laws. If it is the case, we transfer such information while adhering to applicable personal data protection laws.

If Move To Play Holdings LTD is involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control, we may transfer Personal Data, together with business assets, to another company. In this case the respective notification will be available on the web-page of the Privacy Policy.

Children’s data

The Walken Sketch is intended for users who are at least 16 years old. People under the age of 16 are not permitted to use the Walken Sketch Application without permission and oversight by a legal guardian over the age of 18 years.

In accordance with the Federal Children’s Online Privacy Protection Act of 1998 (“COPPA”), we will never knowingly solicit, nor will we accept, personally identifiable information from users of the Service known to be under 16 years of age. Please see our privacy policy for additional information, including information regarding how to notify us of any concerns you may have in this regard.

If you believe that we have information from or about anyone under sixteen (16) years of age, please notify us by email at [email protected] for fastest processing, please include the phrase “COPPA Concern” in the subject line and in the body of your message.

Legal Bases

Every time we collect and process your information, we do so in accordance with on of the following legal basis:

• Contractual Necessity—for data we use to provide you with Services you have requested;
• Legal Obligation—for data we use to comply with our legal obligation or to respond to a lawful request for information;
• Legitimate Interest—for data we use for purposes that are not harmful to your privacy and can be reasonably expected from the context of your use of the Walken Sketch, such as analytics, research, marketing, advertising, and continuous improvement of the Walken Sketch; and
• Consent—you consent to collection of data when you install the Walken Sketch and you can withdraw your consent at any time by uninstalling our games.

If you do not want us to collect any personal information about you, you should stop using the Walken Sketch.

Do We Use Cookies?

Cookies are small files which a website uses to identify you when you come back to the site and to store details about your use of the site.

Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies, but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our websites.

Walken Sketch may use cookies, and/or other tools to store and sometimes track information, such as analysing website traffic to help us provide a better website visitor experience. We may also collect certain information such as browser type, operating system, IP address, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

In addition, cookies may be used to serve relevant ads to website visitors through third party services. These ads may appear on this website or other websites you visit.

Obtaining Information Through Third Party Sources

Walken Sketch will occasionally obtain information about you through third party. Information will only be obtained as required permitted by applicable law. Examples of this include public databases, credit bureaus, resellers and channel partners, and social media platforms.

We also may transfer your Personal Data to a third party in the following cases:

• if we need so to protect legal rights of Move To Play Holdings LTD our end users, business parties or other interested parties;
• if we need so to enforce our agreements with you;
• if we need so to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

Automatically Collected Data

Walken Sketch receives and stores certain types of data whenever you interact with Walken Sketch services. Data collected automatically includes any category listed under personal usage information.

Why We Share Personal Information with Other Parties

Walken Sketch will never sell or rent your personal information. We will only share your information in the following circumstances:

• We share your information with third party identity verification services to prevent fraud. Walken Sketch Application shares this information to confirm your identity with relevant public records to prevent fraud. These third-party services will store your information; however, they will only use this information for purposes of identity verification.
• Walken Sketch Application may share your information with affiliated service providers. These affiliated services providers may include debt collection service agents, marketing firms, and technology services. All affiliated service providers are contracted to solely use this information for purposes that affiliate with Walken.
• We will share your information with financial institutions which Walken Sketch Application has partnered with to process payments.
• We may share your information with companies or entities that we purchase or merge with. The new company or entity will uphold this Privacy Policy.
• We may share your information with law enforcement officials or other entities when required to do so under applicable law.
• We may share your information with law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement or any other applicable policies.

How We Protect and Store Personal Information

Walken Sketch may hold sensitive information in our facilities or service providers located worldwide. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

Walken Sketch cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of your data will not occur. Please note that the client plays a critical role in ensuring their own personal information.

Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us at the email address, mailing address or telephone number listed at the end of this Privacy Policy.

Personal Information Rights

With Walken Sketch, you have a right to access, correct, object, and delete personal information.

You have a right of access to the personal information that we hold about you under BVI data protection legislation, and to some related information. You can also require any inaccurate personal information to be corrected or deleted.

You can object to our use of your personal information at any time, and you may have the right to object to our processing of some or all your personal information (and require them to be deleted) in some other circumstances.

If you wish to exercise any of these rights, please contact us as set out below.

How You Can Access or Change Personal Information

You are entitled to review, correct, or amend your personal information, or to delete that information where it is inaccurate. You may do this by contacting us at [email protected].

If your account is closed or terminated, Walken Sketch will keep your account information in our database for at least two years for regulatory purposes. This ensures that those who are attempting to avoid fraud cannot achieve this by simply closing or terminating their account. When your account is closed or terminated, your information will not be used by Walken Sketch for any further purposes, including being shared to third parties.

General Data Protection Regulations (GDPR)

The General Data Protection Regulations (GDPR) apply to organisations who process data in the EU as well as organisations that offer goods or services to or monitors the behaviour of the people inside the EU. The GDPR applies to all information that can directly or indirectly influence an individual.

Walken Sketch has prepared itself for the General Data Protection Regulations by providing information as to when Walken Sketch data is deleted, have provided a transparent overview of Walken Sketch’s use of the personal information it has collected, and detailed how you can exercise your privacy rights.

European Union Residents have the following rights:

1. You will have the right to withdraw your consent to process your personal information.
2. You have the right to access your Personal Data , which we process.
3. You have the right of rectification (correction) of your Personal Data . You have the right to ask us to replace any inaccurate data about you with accurate data. If you think that the data we process are incomplete for the purpose of processing as stated in this Privacy Policy, you may ask us to complete your Personal Data accordingly.
4. You have the right to ask us to completely delete your Personal Data.
5. You have a right to request Walken Sketch provide you with a copy of your personal informationheld by us. This information will be provided without undue delay subject to some fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others.
6. You have the right to request Walken Sketch update any of your personal information that you believe incorrect or inaccurate.
7. You may also request a copy of your personal data collected during your use of the Walken Sketch.
8. Right to Erasure

You have the right to request erasure of your personal information that:

1. is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
2. was collected in relation to processing that you previously consented, but later withdraw such consent; or
3. was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.


9. Right to Data Portability

If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.

A “controller” Is a natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of your personal information.

10. Right to Restriction of or Processing

You have the right to restrict or object to us processing your personal information where one of the following applies:

1. You contest the accuracy of your personal information that we processed. In such instances, we will restrict processing during the period necessary for us to verify the accuracy of your personal information.
2. The processing is unlawful, and you oppose the erasure of your personal information and request the restriction of its use instead.
3. We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defence of legal claims.
4. You have objected to processing, pending the verification.


11. Restricted Personal Information shall only be processed with your consent or for the establishment, exercise, or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if the restriction is lifted.


12. Notification of Erasure, Rectification and Restriction

Walken Sketch will communicate any rectification or erasure of your personal information or restriction of processing to each recipient to whom your personal information has been disclosed, unless this proves impossible or involves disproportionate effort. We will inform you about those recipients if you request this information.

13. Right to Object to Processing

Where the processing of your personal information is based on consent, contract, or legitimate interests you may restrict or object, at any time, to the processing of your personal information as permitted by applicable law. We can continue to process your personal information if it is necessary for the defence of legal claims, or for any other exceptions permitted by applicable law.

14. Automated individual decision-making and profiling

You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.

15. If you are based in the EEA, you have the following rights in addition to the above: The right to lodge a complaint with supervisory authority . We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.

If you believe Walken Sketch has infringed your rights, we kindly request that you contact prior to lodging a complaint with the relevant authorities so that we may attempt to resolve the dispute. Please contact us at [email protected].

CONTACT US

If you have an enquiry regarding our Privacy Policy surrounding personal information, you can contact us at [email protected].

Move To Play Holdings LTD

Registration Number: 2096476

Address: Intershore 6th Floor, Waters Edge, Building 1, Wickham’s Cay 2, Road Town, Tortola, British Virgin Islands