WaveClear Privacy Policy

 

Last updated: July 15, 2025

 

1. Introduction
      WaveClear Ltd (“WaveClear”, “we”, “our”) is committed for protecting the privacy of the users of our Apps  ( “you”, “your” or “user”, respectively) That starts with helping you understand our privacy practices. The following information describes how WaveClear collects and processes information about you when you use our products that may include but not limited to our desktop application and website (the “Apps”).
      This document (the “Privacy Policy”) aims to provide you with a clear understanding of what information we collect and why we collect it, how it is used and shared, how we secure your information and the choices available to you regarding the collection of such information. 
      We strongly encourage you to read this document in conjunction with our privacy overview, which summarizes the key aspects of our privacy practices.
   The App and Website is not intended for children under the age of 16. We do not, knowingly or intentionally, collect information about children who are under 16 years of age. IF YOU ARE UNDER THE AGE OF 16 YOU MAY NOT USE THE APP AND WEBSITE.

2. Data Collection and Use

      Through your use and access of our Website and App, we collect information in the following ways:

    - Automatically Collected Data: Some information is automatically gathered when you use and access our Website and App. This includes non-personal information like session durations, the content you access on the Website and App, the frequency and scope of your use, and details about your computer and internet connection, such as the operating system and browser type and Personal Information.
    - Voluntarily Provided Personal Information: Information that can personally identify you may also be collected, which includes but is not limited to your full name, email address, and content of your message and conversation with us (the “Personal Information”). This Personal Information is collected during your interaction with us.
    - Third Party Providers: We may be provided with information from third parties such as Riot Games which are the owner and operator of League of Legends (“LOL”) or Overwolf which are the operator of the App’s marketplace. By connecting your LOL and Overwolf account with our App we receive your account details and Usage and Gameplay Data (as defined below). We may further be provided with information from third parties which our partners and provide you with certain technology and features you install to operate in connection with our App.
   The Personal Information collected by us includes the following:
    - Online Identifiers: such as your Internet Protocol address, device ID and etc. Where we process such Online Identifiers for operational, optimization, functional, and security purposes, we process your data based on our legitimate interest. Where we use the Online Identifiers for marketing, personalized ads, and tracking it will be based on your consent provided through the Overwolf Platform.  
    - Account Information: In order to use the App you are required to have an Overwolf account  and a LOL account. Once you install and launch the App, LOL client, and accept the App’s terms and privacy policy, we receive from Overwolf your LOL game name and game tag and uniquely associate your App and your LoL account in our systems
    - Purchase Data. When you decide to make a purchase on our App, the payments are in-app payments and shall be subject to the Overwolf Platform terms and privacy: https://legal.overwolf.com/docs/overwolf/platform/platform-privacy-policy. We do not keep any payment method data such as credit card number or bank account and all of the payment and transaction data is collected and processed by Overwolf.
    - Usage and Gameplay Data. We will collect action and usage data when you use our App. This includes, but is not limited to screens you engaged within our App, the date and time you accessed and used the App, the number of clicks within the App , the duration of your sessions. We may receive further from Riot’s API and Overwolf’s API, such as in game click, User game name, gameplay data, user match history, game statistics, performances in various app and game challenges, ranking in a global leaderboard with other players regarding such training or competition and real-time game performance metrics ("Gameplay and Usage Data"). We will analyze this data in order to determine your focus and provide you with insights and information that will allow you to improve your gaming skill. Please see Riot’s privacy notice for more information https://www.riotgames.com/en/privacy-notice.
    - Video and Image of the Face: where you decide to access certain features, you may be required to download and install additional features and software components (e.g. the TruSight SDK install package) which will collect and process your face image while you use the app. The image and video are processed on your device to provide analysis, insights, and user value regarding mental and game skill performance such as (but not limited to) stress, emotional response to game events, and mindset training tools. We or TruSight do not save nor store on our servers your video and image. The analysis of your image and video, which does not include personal information is collected and processed by us to provide you with our Services and by Revealense  in accordance with Revealense privacy policy.
      We may use the collected information as part of our Services and operations as follows: 
    - Providing the Services and Website and App features: in order to operate our Website and App and provide you with the Website and App services and other features that can be accessed and used through the Website and App we will need to access, collect and process the Personal Information.
   -  Improvement and Development of Services: We analyze the collected information to improve and develop our App and Services. This includes improving and enhancing the App and ensuring it adds value to our users.
    - Research and Statistical Analysis: We may process collected data for research and statistical analysis purposes. In such cases, all data will be anonymized so that it cannot be used to identify you personally. This anonymized data may be used to improve our services, contribute to industry research, or for other analytical purposes. We may share this data with our partners and other research parties.
    - Maintaining a Safe and Secure Environment: Your information is used to enhance the safety and security of our Website and App. This includes preventing fraud, verifying identity, and taking actions against activities that violate our terms of service, publishers and Overwolf regulations, or applicable law.
    - Personalizing Content and Marketing: We may leverage personal information to customize our App’s content and marketing strategies including delivering of ads to better suit your interests and enhance your overall experience.
    - Advertisement: Our App may include advertisements (Ads) placed via Overwolf which will use personal data such as your IP address, online activities, and demographic data for the purpose of displaying targeted advertisements (Targeted Ads). If you prefer not to receive Targeted Ads or to prevent other interest-based advertising identifiers from being used in the App, you can adjust your privacy settings to reset these preferences or opt-out of such targeted advertising through the Overwolf Platform. Please be aware that opting out of Targeted Ads does not mean you will no longer see Ads in our App. However, these Ads will not be personalized based on your interests. 

3. Security Measures
      Our top priority is to ensure the privacy of your Personal Information that we collect and use for the purpose of providing you with our Services.
      We are considering the sensitivity of data that we are storing and processing. Our security team and developers are following common security best practices integrated into each process and system, to protect them against common security threats. 
      Our implemented security measures combine technological, administrative, and operational security controls together to ensure optimal security of all information assets.

4. Cookies 
      We use “cookies” and similar tracking technologies such as software developer kits (”SDKs”) when you access or use our Services. Such tracking technologies are small text files that a website (cookie) or an application (SDK) places and stores on your device while you are viewing or using our App. 
      Such tracking technologies are very helpful and can be used for various purposes. These purposes include: (i) allowing you to navigate between pages efficiently; (ii) enabling automatic activation of certain features; (iii) remembering your preferences; and (iv) making the interaction between you and our Services quicker and easier.
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
    

5. Your Data Protection Rights 
      Under applicable privacy protection laws, individuals have certain rights and controls regarding their Personal Data we process and maintain. Depending on your relationship with us, your jurisdiction and the privacy laws that apply to the processing of your Personal Data, the principal rights might include:  
    - Right to be informed – you have the right to be provided with information regarding our Personal Data collection and privacy practices. All is detailed under this Privacy Policy.  
    - Right to access/inspect your Personal Data - you have the right to ask us to confirm whether or not we collect and use your Personal Data, and if so, you have the right to know which Personal Data we specifically hold about you ask for a copy of your Personal Data or access it;
    - Right to correct/rectify your Personal Data - you have the right to ask us to correct or update any of your Personal Data that is incorrect, after verifying the accuracy of the data first, taking into account the nature of the processing and the purposes (or request deletion for inaccurate Personal Data).  
    - Right to erase your Personal Data (the right “to be forgotten”) - you have the right to request the erasure of certain Personal Data, if specific conditions are satisfied, for example, if you think  we no longer need to use it for the purpose we collected it from you, in case the process of your Personal Data was based on your consent, where we have used it unlawfully, or where we are subject to a legal obligation to erase  your Personal Data. any request for such erasure will be subject to our rights and obligations under applicable law (e.g.,  legitimate interests such as record keeping with regards to our engagements, completing transactions, providing a good or service that you requested, taking actions reasonably anticipated within the context of our ongoing business relationship with you, fulfilling the terms of a written warranty, detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible for such activities; debugging products to identify and repair errors that impair existing intended functionality; exercising right provided for by law; engaging in public or peer-reviewed scientific, historical, or statistical research in the public interest, etc.). You are not required to create an account with us to submit a deletion request;
    - Right to restrict our processing of your Personal Data - you have the right to ask us to restrict or limit the purpose for which we process your  Personal Data in certain circumstances and where certain conditions are satisfied (such as where the accuracy of the Personal Data is contested by you, for a period enabling  us to verify the accuracy of the Personal Data; where the processing is unlawful and you oppose the erasure of the Personal Data; where we no longer need the Personal Data for the  purposes of the processing).;  
    - Right to object to how we use your Personal Data - you can object to any use of your Personal Data which we have justified by our legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information; 
    - Right to withdraw consent/opt-out - when the lawful basis for processing your Personal Data is your consent, you may withdraw such consent at any time. You have the right to opt-out from Direct Marketing, if applicable, by unsubscribing through the email received. We do not profile you in a manner that has a significant effect on you or other individuals, therefore there isn’t an opt-out option.
    - Data portability right - you have the right to ask us to provide a copy of your Personal Data in a portable format and, to the extent technically feasible, readily usable format that allows you to transmit the Personal Data to another entity without hindrance. We will select the format in which we provide your copy;  
    - Right to appeal or lodge a complaint - If we decline to take action on your request, we will inform you without undue delay as required under applicable laws. The notification will include a justification for declining to take action and instructions on how you may appeal, if applicable. Under the GDPR you have the right to lodge a complaint with the applicable Data Protection Authority in the EU or the Information Commissioner in the UK. 
      For US Residents, please further review our Notice to US Residents below to learn more about your rights under applicable US law. If you wish to file a request regarding any of the above, you may contact us at: [email] 

6. Data sharing and Transfers Outside the EEA
      In line with our commitment to privacy and GDPR principles, we may need to share your Personal Information under certain circumstances:
    - With Third Parties: To perform our contractual and legal obligations, it may be necessary to share your Personal Information with third parties. This includes affiliates, subsidiaries, or third-party service providers who assist us with services such as marketing, data management, maintenance and including advertisers to provide you with Ads.
    - For Analytics: We also share information with analytics service providers for analytics services, which helps us in compiling aggregated statistics about the effectiveness of our Website and App and Services.
    - Leader boards and Game Statistics: We may share your gameplay statistics, including your in-game nickname and performance data, with third-party providers of leaderboards and game statistics websites. This sharing is conducted in a manner similar to how Riot Games publishes such data, and may include information that could be considered personal information under applicable privacy laws. The purpose of this sharing is to enable the display of rankings, achievements, and other game-related statistics on external platforms that enhance your gaming experience. We may further, subject to your choice, share your “mindset” as captured by our App (includes focus, recollection, awareness, and other metrics related to your mindset and focus playing the game)
    - For Business Purposes: In certain scenarios, such as corporate mergers, consolidations, sales of assets, or other fundamental corporate changes, your information may be transferred. 
    - Subject to your consent: In cases you decide or instruct us to share your information we will do so with the parties of interest with whom you decide to share your information.
    - For Compliance: We may release information in compliance with legal obligations, such as warrants, subpoenas, or court orders, or in special cases, such as unlawful acts using our Services, security breaches, or physical threats.
      These third parties may be located in countries outside of your own and outside the European Economic Area (“EEA”). In such cases, we ensure that they comply with obligations similar to those in this Privacy Policy and adhere to our data privacy and security requirements. They are permitted to use the Personal Information only for the purposes we specify. When transferring your Personal Information internationally, we use appropriate and suitable safeguards, including a variety of legal mechanisms like contracts, to ensure your rights and protections travel with your data.

7. Data Retention
      We retain Personal Information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Once the data is no longer needed, we will securely delete or anonymize it.

8. Additional Notice For Us Residents
      Residents of certain U.S. states (depending on the applicable state law, acting in an individual or household context and not in a commercial or employment context or as a representative of business), including California, Colorado, Connecticut, Virginia, and Utah, may have additional rights under applicable privacy laws and be entitled to additional disclosures. 
      "Personal Data" under applicable US privacy laws, generally means any information that is linked or reasonably linkable to an identified or identifiable individual (and usually does not include publicly available information that is lawfully made available from government records, or that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; or information excluded from the states laws scope, such as: HIPAA, GBPA, non-profit entities, etc.)
      “Sensitive Data” means data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life, sexual orientation, citizenship, or immigration status; The processing of genetic or biometric data for the purpose of uniquely identifying an individual; Personal Data collected from a known child; Precise geolocation data. 
      We are required to provide you with a clear and accessible privacy notice that includes the categories of Personal Data processed, purpose of processing, instructions for exercising consumer rights and appealing decisions, categories of Personal Data shared with third parties, categories of third parties with whom data is shared, and any sale of data or targeted advertising.
      Categories of Personal Data & Categories of third parties with whom Personal Data is shared: Under the paragraph “Data Collection and Use” of this Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collecting and processing, and the purposes for which Personal Data is processed, stored or used. 
      Additionally, under the paragraph “Data Sharing” of this Privacy Policy, we detail and disclose the categories of third parties we share Personal Data with for business purposes. We will not collect additional categories of Personal Data or use the Personal Data we collected for a materially different, unrelated, or incompatible purpose without obtaining your consent. 
      “Sale” of Personal Data: Under US privacy laws, in principal, the term “sale” is referring to disclosing or making available Personal Data to a third-party in exchange for monetary or other valuable consideration, including for targeted advertising purposes. We do not “sell” information as most people would commonly understand that term, we do not, and will not, disclose your Personal Data in direct exchange for money or some other form of payment however, subject to the definition of the term “Sale” under US privacy laws, we may “sell” the Identifiers.
      Consumer Rights: Residents of certain U.S. states, including Colorado, Connecticut, Virginia, and Utah, may have additional rights under applicable privacy laws, subject to certain limitations, which may include:
    - Access - the right to confirm whether we are processing their Personal Data and to obtain a copy of their Personal Data in a portable and, to the extent technically feasible, readily usable format.
    - Delete - the right to delete their Personal Data provided to or obtained by us.
    - Correct - the right to correct inaccuracies in their Personal Data, taking into account the nature and purposes of the processing of the Personal Data.
    - Opt-Out - to opt out of certain types of processing, including: (i) to opt out of the “sale” of their Personal Data; (ii) to opt out of targeted advertising by us; and (iii) to opt out of any processing of Personal Data for purposes of making decisions that produce legal or similarly significant effects.
      The paragraph “Data Subjects rights” provides additional information regarding your principal rights. 
      Exercising Your Privacy Rights: You may submit a request to exercise most of your privacy rights under U.S. state privacy laws by contacting us at: Support@WaveClear.gg
      When you submit a request, we will take steps to verify your identity and your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for denial and how to remedy any deficiencies, where applicable.
      Authorized agents may initiate a request on behalf of another individual by contacting us at Support@WaveClear.gg; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
      If we decline to take action on your request, we shall so inform you without undue delay, within the timeframe set out under applicable law. Our notification will include a justification for declining to take action and instructions on how you may appeal. Within the timeframe set out under applicable law 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 applicable authority or Attorney General of your jurisdiction 

9. Updates to this Privacy Policy
      We may update this Privacy Policy from time to time to reflect changes in our practices or applicable regulations. We encourage you to review this Policy periodically. The updated Policy will be effective upon posting on our website.

10. Ways to Contact Us
       If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us by email to: Support@WaveClear.gg