Our Privacy Policy

Effective Date:

We have updated our Privacy Policy. In addition to clarifying changes, we have added explanations regarding the collection of user content, location information and device data, use of data for account verification, and data sharing with third-party services. You can find more details about the data we collect and how it is used in this Privacy Policy.

This Privacy Policy will be applicable worldwide. However, different applications may apply under specific data protection laws applicable in certain regions:

• For users in the EU: This Privacy Policy applies within the framework of the EU General Data Protection Regulation (GDPR).
• For users in the United Kingdom: This Privacy Policy is implemented within the framework of UK GDPR and Data Protection Act 2018.
• For users in Turkey: This Privacy Policy applies under the Law No. 6698 on Protection of Personal Data (KVKK).
• For users in the USA: Where applicable, state data protection laws (e.g., CCPA, CPRA) apply.

Welcome to Wibto ("Platform"). The Platform is provided and controlled by [Wibto Ltd.] ("Wibto", "we", "us" or "our"). We attach great importance to protecting your privacy and respect your personal data.

This Privacy Policy describes our practices regarding personal data we collect from you or that you provide to us. If you do not accept this policy, please do not use the Wibto Service.

If you have any questions about how your personal data is used, you can contact us at support@wibto.com.

1. What Information Do We Collect From You?

When you start using Wibto, create your account, or upload content to the Platform, we collect and process certain information you provide to us. This data is processed to provide our service, enhance security, personalize your experience, and fulfill our legal obligations.

Additionally, when you download our mobile application and interact with the Platform without creating an account, we may collect certain information about you.

The information we collect generally falls into the following categories:

• Your Profile Information

When you register with Wibto, you provide us with the following information:

• Your username, password, email address and/or phone number.
• Your date of birth (when applicable, for age verification purposes).
• Information you share on your profile (e.g., your user description, interests).
• Your profile photo or profile video.

• User Content and Behavioral Information

Content you create or upload on Wibto ("User Content") is processed. These include:

• Photos, videos, descriptions, comments you upload.
• Tournaments you participate in, your likes, items saved to "My Favorites".
• Technical data related to User Content (e.g., resolution, file type).
• Your usage behaviors (e.g., videos you watch, duration of interaction with content, advertisements you view, problems you encounter within the app).
• Personalized recommendations and advertisements based on your interests, age, and preference inferences.
• Surveys, contests, and challenges you participate in.

• Information Received From Third Parties

• Social network integration: If you register with Wibto using your third-party social media accounts (e.g., Google, Apple, Facebook), your username, public profile information, and data necessary for authentication may be obtained from these accounts.
• Business partners: Advertisers, advertising networks, or analytics providers may share aggregate and anonymous data about your interaction with Wibto and other platforms. This is used to measure advertisements and present appropriate content to you.

• Technical Information

The following information is automatically collected from the devices you use to access the Platform:

• IP address, mobile carrier, device model, operating system, browser information.
• App version, language setting, screen resolution.
• Device identifiers, advertising identifiers.
• Error logs and performance information.
• Usage data through cookies and similar technologies.
• When you log in on multiple devices, we may link your cross-device activity.

• Location Information

• Country, province, and district information you select when creating your account.
• Current location you add at your preference when sharing tournaments.
• Approximate/real-time location obtained via SIM card, IP address, or GPS (only with your permission).

• Finding and Inviting Your Friends

• Phone numbers or email addresses may be processed through features that allow you to invite contacts from your directory to the app.
• This information is used only for inviting your friends and is not shared with third parties.

• In-App Purchases

• When you make premium membership or in-app purchases, payment transactions are carried out through the App Store or Google Play.
• Wibto does not directly store your credit card information; however, it keeps records such as payment date, purchased product, and transaction amount for the successful completion of the purchase transaction.
• If you use PayPal or similar third-party payment providers, the privacy policies of these providers also apply.

• Identity and Age Verification

• To access certain features (e.g., live streaming, verified account, Pro Account), you may need to verify your age or identity. In this case, we may request an identity document or information showing your age.

• Use Without Creating an Account

• Even if you download the app and visit the Platform without opening an account, limited technical information (IP address, device type, language and country setting) may be collected. This is necessary for the app to perform its basic functions.

2. Cookies

As Wibto, we use cookies and similar technologies (e.g., web beacons, pixel tags, local storage, SDKs) ("Cookies") to enable you to use our Platform more efficiently, improve your experience, enhance our services, analyze your usage, and provide you with personalized content and advertisements.

Cookies are small data files placed on your device and enable you to use certain features and functions of the Platform. Web beacons or pixel tags are small visual markers that allow us to understand that certain pages or content have been viewed.

• For what purposes do we use cookies?

• To ensure Platform performance and security.
• To measure and analyze which pages you visit and how you use the Platform.
• To personalize your experience and show you content that suits your interests.
• To measure the effectiveness of advertisements and provide you with more relevant ads.
• To detect errors and improve our services.

• Third-party cookies

Wibto may allow our business partners (e.g., advertising networks, analytics providers, third-party service providers) to collect information about your online activities through cookies. This information may be used to provide you with advertisements or content based on your interests and preferences. Wibto is not responsible for the privacy practices of these third parties; their data processing activities are conducted under their own privacy policies.

• How can you control your cookie preferences?

• You can reject, limit, or delete cookies by changing your browser settings.
• You can use your device settings or app permissions to limit personalized advertisements on your mobile device.
• Since cookie rejection or disabling operations are specific to the device or browser, you may need to perform separate operations for each device and browser.
• Please note that if you disable cookies, some features or functions of Wibto may not work properly.

• Consent

By continuing to use Wibto, you are deemed to have consented to the use of cookies for the purposes specified in this Privacy Policy. You have the right to withdraw your consent at any time.

3. How We Use Your Personal Data

As Wibto, we process the personal data we collect about you for the following purposes:

• Service communication: To inform you about updates, changes, or new features in our services.
• User support: To answer your questions, provide technical support, and troubleshoot.
• Personalized experience: To offer content and tournament recommendations based on your interests and interactions.
• Content sharing and interaction: To enable you to share your photos and videos in tournaments and interact with other users.
• Messaging: To enable you to use the in-app messaging feature on Wibto.
• Premium and virtual items: To manage your premium membership, in-app purchases, or participation in sponsored tournaments.
• Communication: To communicate with you regarding your account, security, or community rules.
• Security and abuse prevention: To detect and prevent harassment, fraud, spam, illegal or inappropriate activities on the Platform.
• Content moderation: To detect content that violates our Community Rules, review complaints, and provide a safe environment.
• Performance: To ensure that the Platform works optimally on your devices.
• Improvement and development: To improve Wibto, offer new features, highlight popular tournaments and campaigns.
• Testing and analysis: To conduct analyses, tests, and trials to increase the reliability of the Platform.
• Socialization: To enable you to invite your friends and communicate with other users through your directory or connections.
• Location-based socialization: If you explicitly choose to share your location information so that other users can see it, other people in the same location may see you and have the opportunity to communicate with you. This feature is only activated with your explicit consent and you can turn it off from privacy settings at any time. If you choose not to share your location information, other users cannot access your location and this feature remains disabled.
• Earning additional points: Within the scope of certain features on Wibto, we may process your step count and similar activity data in order to earn you additional points. This data is collected and processed only with your explicit consent. Since your health data is special category personal data, it is protected with the highest security measures and is not shared with third parties for marketing purposes. Your activity data is used only for scoring, ranking, and motivation purposes. You can turn off this feature at any time and withdraw your consent to the processing of your data.
• Age verification: To verify that you are of appropriate age to use the Platform, in accordance with legal requirements.
• Advertising: To show you personalized advertisements and sponsored content based on your interests.
• Location-based services: To offer regional rankings, local tournaments, and recommendations based on your location (only with your explicit permission).
• Algorithm development: To use anonymized data for our content recommendation systems to learn and improve in order to enhance your experience.
• Policy enforcement: To enforce our terms of use, community rules, and privacy policy.
• Transaction management: To facilitate the sale, promotion, and purchase processes of goods and services, including premium memberships, content promotion, advertisements, and user support.

4. How We Share Your Personal Data

As Wibto, we share your personal data only with the purposes and parties specified below, in a legitimate, limited, and lawful manner:

• Business Partners and Social Networks

• If you choose to register with Wibto using your third-party social network accounts (e.g., Google, Apple, Facebook), you may share your username, email address, and public profile information with the relevant service provider. Similarly, we will be sharing information such as your application ID, access token, and application URL with the relevant social network.
• If you choose to link your account with a third-party platform, information is shared with these platforms to the extent you permit.
• If you choose to share the content you produce on Wibto on social media or messaging applications (e.g., Instagram, WhatsApp), the relevant content (e.g., video link, your username, description) is shared on these platforms.

• Payment Providers

• During premium membership or in-app purchases, payment transactions are carried out through the App Store, Google Play, or third-party payment providers (e.g., PayPal, Stripe).
• Wibto does not directly store your credit card information. However, data such as transaction ID, purchase date, and amount may be shared for verification and successful completion of payment transactions.

• Service Providers

• To ensure that Wibto operates safely, quickly, and enjoyably, data may be shared with cloud service providers, content moderation firms, security services, and marketing/communication providers.
• These service providers process your data only on our behalf and in accordance with our instructions.

• Analytics Service Providers

• Third-party analytics services (e.g., Google Analytics, Firebase Analytics) may be used to measure Platform performance, improve user experience, and provide personalized content.
• These providers may process anonymized or aggregated data to understand user behaviors.

• Advertisers and Advertising Networks

• To provide you with more relevant advertisements, limited data may be shared with advertisers and advertising networks (e.g., device ID, engagement statistics).
• This data may be used to measure the effectiveness of advertisements, analyze which content receives more attention, and personalize sponsored tournament recommendations.
• Information that personally identifies you (e.g., your name, email) is not shared with advertisers unless you give permission.

• Our Group of Companies

• For the development of Wibto, ensuring its security, and user support, data may be shared among companies we are affiliated with, subsidiaries, or group companies.

• Law Enforcement and Legal Obligations

• When legal obligations or official requests are involved, your personal data may be shared with law enforcement or authorized institutions.
• These situations may include:
  • Compliance with legal obligations,
  • Suspicion of violation of our terms of use,
  • Prevention of fraud, deception, or security threats,
  • Protection of Wibto, our users, or public safety.

• Public Profiles

• If you make your profile public, the content you upload may become visible to all users on Wibto.
• This content may also be viewed by search engines, content aggregators, or third-party platforms.
• To protect your privacy, you have the option to mark your account as private from your settings.

• Purchase, Merger, or Transfer Transactions

• In cases such as the sale, transfer, merger, or liquidation of all or part of Wibto, user data may be among the transferred assets.
• In such a case, our users will be informed.

5. Where Do We Store Your Personal Data?

As Wibto, the personal data we collect from you is stored securely on Google Cloud Platform (GCP) infrastructure. Google Cloud provides services through data centers distributed worldwide. Therefore, your data may be stored and processed on servers located in the United Kingdom, European Economic Area (EEA), or countries outside the EEA such as the USA and Singapore.

• Industry-standard security measures offered by Google Cloud (encryption, access controls, security certificates) are used for the security of your data.
• For data transferred outside the EEA or the United Kingdom, necessary protection measures are implemented under GDPR, UK GDPR, and KVKK. In this context, the European Commission's Standard Contractual Clauses (SCCs) or equivalent mechanisms are used.
• Your data is processed only for the purposes specified in this Privacy Policy and is not shared with unauthorized third parties.

6. Your Preferences

By logging into Wibto, you can access, view, and edit most of your profile information. You can also delete the User Content you have uploaded.

We offer you various tools to give you more control over your content and account:

• You can set who can see your videos or photos.
• You can control who can send you messages or who can comment on your content.
• If you prefer, you can completely delete your account through Settings.

In addition to these, you may have the following rights under the laws of your country:

• Request access to your data,
• Correct or delete your data,
• Restrict the processing of your data,
• Request portability of your data,
• Object to the processing of your data,
• Withdraw your consent.

These rights are protected under the EU General Data Protection Regulation (GDPR), UK GDPR, KVKK, and other relevant data protection laws.

To exercise your rights, ask questions, or get more information about how your data is processed, you can contact us at:
📧 support@wibto.com

7. Security of Your Personal Data

As Wibto, we take appropriate technical and administrative measures to ensure the security of your personal data. In this context, we strive to protect your data with encryption, access controls, authorization mechanisms, and up-to-date security protocols.

However, data transmission over the internet is never completely secure. Although Wibto implements reasonable and current security measures, it cannot guarantee the absolute security of data transmitted over the Platform. Therefore, risks that may arise during the transmission of information belong to the user.

To protect the confidentiality and integrity of your data:

• We limit access to your personal data only to authorized personnel and our business partners.
• We regularly evaluate risks and update our security systems when deemed necessary.
• We continuously monitor our systems to detect and prevent potential security vulnerabilities.

From time to time, Wibto may contain links to websites belonging to our business partners, advertisers, or affiliates. Third-party sites you access through these links have their own privacy policies. Wibto is not responsible for the content of these policies or the practices of third parties. We recommend that you review the privacy policies of the relevant sites before sharing any information.

8. How Long Do We Keep Your Personal Data?

As Wibto, we store your personal data only for the period necessary to fulfill the processing purposes. When determining this period, we consider:

• The period necessary to provide the service,
• Mandatory retention periods stipulated by relevant legislation (e.g., tax, accounting, commercial, and consumer legislation),
• Periods that may be necessary for the establishment, exercise, or defense of rights.

• General Principles

• We keep your data as long as you benefit from the service.
• When your personal data is no longer needed to provide the service, your data is deleted, anonymized, or kept only as aggregated statistical data.
• Due to our legal obligations, certain data may continue to be stored for the period stipulated in the relevant legislation (for example, 5 years under Tax Procedure Law No. 213, 10 years under Turkish Code of Obligations).
• Under GDPR/UK GDPR, we undertake not to store your data unnecessarily after the processing purposes have ended.

• In Case of Account Deletion

• If you delete your account or stop using Wibto, your personal data will be deleted or anonymized within a reasonable time.
• Anonymized data may be stored only for statistical analysis and research purposes in a way that cannot directly identify you.

9. Information About Children

Wibto is not intended for children under the age of 13. In some countries, this age limit may be higher due to local legislation (for example, generally 16 years in the European Union and the United Kingdom, 13 years in Turkey).

• If you believe we have inadvertently collected personal data about a child under this age limit, please contact us immediately: 📧 support@wibto.com
• In such a case, we delete the relevant account and remove the data from our systems without delay.
• Wibto may implement measures such as age verification and identity control to protect children's safety.

10. Complaints

If you have a complaint regarding the processing of your personal data, we kindly request that you contact us first. You can send your complaint to:
📧 support@wibto.com

We will review your request as soon as possible and try to find a solution.

In addition, you also have the right to apply to the data protection authority of your country.

In any case, we are pleased to support you in exercising your right to complain.

11. Changes

We may update the Wibto Privacy Policy from time to time. In such a case:

• The "Last Updated" date at the top of the Policy will be changed.
• The new Privacy Policy will be published through the app or our website, and you will be notified when necessary (for example, through in-app alerts, email, or other means of communication).
• The updated Privacy Policy will come into effect after all notifications are provided as required by applicable law.
• Your continued access to or use of Wibto after the Policy comes into effect means that you accept the updated Privacy Policy. If you do not accept the updated policy, you can delete your account and stop using Wibto.

Note: This is a legal document. If you have questions about this Privacy Policy, please contact us at support@wibto.com.