EFFECTIVE DATE: MAY 31, 2020.

In accordance with the Terms of Service and Conditions of Use, Sherwa offers:

  • a) Platform for connecting Provider Users to Users who take the Services of coach services in games, these being unrelated to the platform.
  • b) Platform for “queue” – formation of an organized registration queue for a joint game in “games”, these being unrelated to the platform.
  • c) in-app facility products (cosmetics – eg avatar sales);

For this, we will need some information about you, since the use of the platform, anonymously, is expressly prohibited. We will only use your information in accordance with applicable legal requirements. Thus, this Privacy Policy helps in the understanding of data collection, as well as its effective application.

1 – DECISION ON THE INFORMATION USED

Sherwa Online Services INC is the controller of your users’ personal data and is responsible for making decisions about how to use this information.

If you have any questions or comments about this Policy, you can send an email to contact@sherwaonline.com

2 – INFORMATION COLLECTED AND USE

This Policy deals with the use of any information that can be used to identify users, called “personal data”, to provide our Services, exclusively. When you sign up for our Services, you voluntarily grant us the following personal data:

  • Name
  • User ID in the game related to the provision of services
  • E-mail
  • Birth date
  • Username in app

Depending on your residence, you may be able to exercise certain rights in relation to your personal data, subject to applicable legal exemptions. In cases where the EU’s General Data Protection Regulation (“GDPR”) applies, your rights consist of:

The right to be informed;
The right of access;
The right to rectification;
The right to delete;
The right to restrict processing;
The right to data portability;
The right to object;
and Rights in relation to automated decision making and profiling

You may also have the right to file a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights regarding personal data about you. We encourage you to contact us first, so that we have an opportunity to address your concerns directly before doing so. You can also contact us with your personal data queries or for assistance in modifying or updating your personal data and exercising your rights. Our contact details are provided at the end of this Privacy Notice.

For marketing, such as our communications with you about events, forums, game resources, promotions and purchase opportunities, an “unsubscribe” option is provided at the bottom of each communication. In addition, we can be contacted directly to unsubscribe.

This collected information is used for registration and authentication of the Sherwa account, as well as for the use of our Services.

The Provider User of legal age is obliged to provide his personal photo on his Sherwa user, and for minors, such data transmission is optional, provided that he is represented or assisted by his legal representative.

The minor Taker User is prohibited from using a personal photo in his profile, and for the legal aged, this use is optional.

Such personal data will be used to create the profile and identify the person within the app, which can be used by Sherwa to verify the compliance of the terms of use, as well as to allow connection with the games.

In the case of using an account with an external service, the personal data collected depends on the external account, such as the privacy policy of the external account, which allows you to view this data when you use it to access our Services. However, this will not affect how they are used by Sherwa.

Sherwa collects and uses your device’s location information as you use our Services. Its location is identified using a number of technologies, including GPS, WiFi points and triangulation of cell towers.

There is also the collection and use of some information about your mobile device, including device identifiers, operating system, model, configuration, adjustment and information about installed third party applications and software, to operate our Services.

Personal data is also provided by the user in the case of an intermediary purchase, in case of signing up to participate in joint games, participate in a competition, research or communicate with us. Depending on the Services chosen, Sherwa may include one, several or all of the data mentioned above.

We are interested in using your data for the purposes listed below:

  • Use your IP address, browser type, operating system, website visited before accessing our Services, page of our Services you have browsed or the resources you use and the time spent, links on our Services, device identifiers and advertising, your settings and user preferences and your in-app purchases to understand how our Services are being used
  • Use your contact information (e-mail address) for communication purposes, providing technical and customer support
  • Use your internal account ID to assign content of interest to the account, if you choose to submit your preferences to Sherwa through the Services
  • Use your email address as well as your Sherwa ID within the app to share updates and news about our Services
  • To provide social interaction features and to play with other users;
  • To offer new or additional features for our Services
  • To organize the registration queue for a joint match in a game;
  • To make legal or regulatory disclosures and to establish, exercise or defend legal claims

We rely on your consent regarding the use of cookies or similar technologies. To the extent that cookies collect your personal data, Sherwa will process them, based on your express consent, by submitting to the terms of this Policy, either anonymously or under a pseudonym.

3 – SHARING OF PERSONAL DATA

We do not share your personal data with third parties outside the platform.

We will share your personal data with our other users, to create interactivity, allowing the connection of the Provider User and the Borrower User for the purposes of a particular game or match.

Some external service providers, especially those involved in processing payments and requesting financial and billing information, may collect your information from their own privacy policies, so we are not responsible for the misuse of your data as a result of this use. This is because they do not share their financial information, credit card number, accounts, among others, with Sherwa, limiting sharing only to information related to your purchase.

For the purposes of cooperating with the government and other law enforcement officials, we may reasonably share your information:

  • to answer demands and lawsuits, with the observance of all legal requirements;
  • to protect our assets, rights and security, as well as that of third parties and the general public;
  • in order to investigate and cease any activity considered illegal, unethical or legally actionable.

4 – PERSONAL DATA PROTECTION AND MAINTENANCE PERIOD

Sherwa has security measures in place to prevent your personal data from being (accidentally) lost, used or accessed in an unauthorized way, or even altered and improperly disclosed, within our platform. The access of employees, agents, contractors, service providers will only occur due to the commercial need to know you, but personal data will only be processed in accordance with our instructions and are subject to the duty of confidentiality

You will be notified via email in case of any suspicion of violation of your personal data, as well as the regulatory institution, when we are legally obliged to do so.

The maintenance of your personal data will be for the period necessary to provide our Services. Upon termination and interruption, we will remove your personal data from our system or make it anonymous, in order to prevent the association with you.

When removing your personal data, we will take reasonable and feasible measures to make it irrecoverable or irreproducible.

For Services that allow the participation of minors between 13 and 16 years old, confirmation of consent is mandatory, by accepting the Terms and Conditions of use for the transmission and maintenance of personal data, under the terms of this Policy. It is recommended that the legal representative monitors the online activity and use of the Service by that minor.

The legal representative’s verified consent to collect, use or disclose the personal data of the minor mentioned above is mandatory. We can request the legal representative’s email address to confirm this consent and, in case of refusal or non-repsonse within a reasonable time, the user in question will be excluded.

The legal representative has the right to review, delete and refuse after the collection, use and disclosure of the minor’s personal data, and must notify Sherwa by e-mail at contact@sherwaonline.com

If we become aware that the minor’s personal data was collected without the consent of the legal representative, we will delete such information as soon as possible.

5 – CHANGE IN PRIVACY POLICY

Any personal data we collect is covered by the Privacy Policy in effect when the information was collected. We can change it at any time and in any way, by sending notification to users with reasonable notice to evaluate the terms of the new Policy.