Privacy Policy
Effective Date: May 22, 2026
Privacy Policy
Effective Date: May 22, 2026 Last Updated: May 22, 2026
1. Introduction
Wagerfy ("we", "us", "our") is a skill-based 1v1 gaming platform operated by Wagerfy, registered in the Netherlands (KVK: 97387606), with its registered address at 1102, Amsterdam, Netherlands.
We are committed to protecting your personal data and processing it in accordance with the General Data Protection Regulation (GDPR) and other applicable privacy laws.
This Privacy Policy explains what personal data we collect, why we collect it, how we use and share it, and what rights you have as a user.
For any privacy-related questions, contact us at: hello@wagerfy.co
2. Data We Collect
2.1 Account & Identity Data
Full name
Email address
Date of birth (used to verify you are 18 or older, as required for real-money wagering)
Username / gamertag
2.2 Financial & Payment Data
Wallet balance held within the Wagerfy platform
Transaction history (deposits, withdrawals, wagers, payouts)
PayPal account details used to process payments (handled directly by PayPal — we do not store full payment credentials)
2.3 Gaming & Activity Data
Match history, results, and wager amounts
Platform activity (lobby interactions, match creation, acceptance)
Reports submitted or received under our Fair Play Policy
2.4 Technical & Device Data
IP address
Device type, operating system, and version
Mobile advertising identifiers (IDFA on iOS, GAID on Android), used for advertising attribution via Meta App Events
App version and session data
Crash reports and performance diagnostics
2.5 Communications Data
Messages sent to our support team
Email correspondence
Marketing email list subscription status, email engagement data (opens, clicks), and any tags or segments applied via Kit (our email marketing platform)
3. Legal Basis for Processing
Under GDPR, we must have a lawful basis for each type of processing:
Processing Activity | Legal Basis |
|---|---|
Creating and managing your account | Performance of a contract (Art. 6(1)(b)) |
Processing deposits, wagers, and payouts via PayPal | Performance of a contract (Art. 6(1)(b)) |
Age verification using date of birth | Legal obligation (Art. 6(1)(c)) |
Fraud prevention and fair play enforcement | Legitimate interests (Art. 6(1)(f)) |
Anti-money laundering (AML) and KYC compliance | Legal obligation (Art. 6(1)(c)) |
Sending transactional emails (match results, payouts) | Performance of a contract (Art. 6(1)(b)) |
Sending promotional communications via Kit (email marketing) | Consent (Art. 6(1)(a)) — you may opt out at any time via unsubscribe link |
Analytics and platform improvement (Firebase) | Legitimate interests (Art. 6(1)(f)) |
Advertising attribution and retargeting (Meta App Events) | Consent (Art. 6(1)(a)) |
Complying with legal requests from authorities | Legal obligation (Art. 6(1)(c)) |
4. How We Use Your Data
To register and maintain your Wagerfy account
To verify your age and eligibility to participate in real-money wagering
To process deposits, match wagers, and payouts via PayPal
To facilitate matchmaking and record match outcomes
To detect and prevent cheating, fraud, and abuse
To send you service communications (match confirmations, payment receipts)
To send you marketing emails, where you have given consent
To analyse platform usage and improve our services
To comply with applicable laws and regulations, including AML and KYC requirements
To attribute app installs and in-app events for advertising purposes (with your consent)
5. Third-Party Processors and Data Sharing
We work with trusted third-party service providers who process data on our behalf. By using Wagerfy, you acknowledge that your data may be shared with the following categories of parties:
5.1 Named Sub-Processors
Provider | Purpose | Location | Transfer Mechanism |
|---|---|---|---|
Supabase | Database, authentication, and backend infrastructure | United States | EU Standard Contractual Clauses (SCCs) |
PayPal | Payment processing (deposits, withdrawals, payouts) | United States | EU Standard Contractual Clauses (SCCs) |
Meta Platforms (Facebook/Instagram) | Advertising attribution and retargeting via Meta App Events SDK | United States | EU Standard Contractual Clauses (SCCs) |
Google Firebase | Push notifications (FCM) and crash/error reporting (Crashlytics) | United States | EU Standard Contractual Clauses (SCCs) |
Kit (formerly ConvertKit) | Email marketing list management and campaign delivery | United States | EU Standard Contractual Clauses (SCCs) |
5.2 Other Sharing
Legal authorities: We may disclose your data to law enforcement or regulatory bodies when required by law or to protect the rights, property, or safety of Wagerfy, our users, or others.
Business transfers: In the event of a merger, acquisition, or asset sale, your data may be transferred to the acquiring entity. You will be notified of any such change.
We do not sell your personal data to third parties.
6. International Data Transfers
Wagerfy is based in the Netherlands (EU). Several of our sub-processors are based in the United States, which is outside the European Economic Area (EEA).
Where data is transferred outside the EEA, we ensure appropriate safeguards are in place, specifically EU Standard Contractual Clauses (SCCs) as approved by the European Commission, in accordance with GDPR Article 46.
7. Advertising and Tracking Technologies (Meta App Events)
We use Meta App Events (Facebook/Instagram SDK) to measure the effectiveness of our advertising campaigns. This involves:
Sending specific in-app events (e.g., app install, account registration, deposit made) to Meta Platforms
Matching these events to Meta ad campaigns to optimise our advertising
This may involve the use of your device's advertising identifier (IDFA on iOS, GAID on Android)
We only do this with your consent. You will be asked for permission via the App Tracking Transparency (ATT) prompt on iOS. You can withdraw consent at any time through your device settings:
iOS: Settings → Privacy & Security → Tracking → Wagerfy
Android: Settings → Google → Ads → Delete advertising ID
8. Cookies and Analytics
Cookies
Our website (wagerfy.co) uses cookies to ensure functionality and improve user experience. You can manage cookie preferences through your browser settings or our cookie consent tool.
Firebase (FCM & Crashlytics)
Our mobile app uses Google Firebase for two purposes:
Firebase Cloud Messaging (FCM): To deliver push notifications to your device (e.g. match alerts, payout confirmations).
Firebase Crashlytics: To capture crash reports and error logs when the app encounters a technical issue. This helps us identify and fix bugs. Crashlytics collects anonymised technical diagnostics and does not use advertising identifiers.
For more information, see Google's Privacy Policy.
9. Data Retention
We retain your personal data for as long as your account is active, and for a period thereafter as required by applicable law:
Data Type | Retention Period |
|---|---|
Account data (name, email, DOB) | Duration of account + 5 years after closure |
Financial transaction records | 7 years (Dutch financial record-keeping law) |
Match and gaming history | Duration of account + 2 years |
Communications with support | 3 years |
Device / technical logs | 12 months |
Marketing consent records | Until consent is withdrawn + 3 years |
Upon account deletion, we will delete or anonymise your personal data within 30 days, except where we are required to retain it by law.
10. Your Rights Under GDPR
As a user based in the EEA, you have the following rights:
Right of access (Art. 15): Request a copy of the personal data we hold about you.
Right to rectification (Art. 16): Request correction of inaccurate or incomplete data.
Right to erasure (Art. 17): Request deletion of your data ("right to be forgotten"), subject to legal retention obligations.
Right to restrict processing (Art. 18): Request that we limit how we use your data in certain circumstances.
Right to data portability (Art. 20): Receive your data in a structured, machine-readable format and transfer it to another controller.
Right to object (Art. 21): Object to processing based on legitimate interests or for direct marketing purposes.
Right to withdraw consent (Art. 7(3)): Where processing is based on consent (e.g. marketing emails, advertising tracking), you may withdraw that consent at any time without affecting the lawfulness of prior processing.
Rights related to automated decision-making (Art. 22): We do not make solely automated decisions that produce legal or significant effects on you.
To exercise any of these rights, contact us at hello@wagerfy.co. We will respond within 30 days.
11. Right to Lodge a Complaint
If you believe we are not handling your data in accordance with applicable law, you have the right to lodge a complaint with the Dutch Data Protection Authority:
Autoriteit Persoonsgegevens Website: www.autoriteitpersoonsgegevens.nl Phone: +31 70 888 8500
12. Children and Age Restrictions
Wagerfy is strictly for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. If we become aware that a user is under 18, we will immediately suspend their account and delete their data.
If you believe a minor has registered on our platform, please contact us at hello@wagerfy.co.
13. Data Security
We implement appropriate technical and organisational security measures to protect your personal data, including:
Encrypted data transmission (TLS/HTTPS)
Secure database infrastructure via Supabase with access controls
Two-factor authentication options for account access
Regular security reviews and access auditing
No system is entirely secure. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and inform affected users without undue delay, in accordance with GDPR Article 33–34.
14. Changes to This Policy
We may update this Privacy Policy from time to time. When we make material changes, we will:
Update the "Last Updated" date at the top of this page
Notify you via email or in-app notification for significant changes
Continued use of Wagerfy after changes take effect constitutes acceptance of the updated policy.
15. Contact Us
For any questions, data requests, or privacy concerns:
Email: hello@wagerfy.co
Address: Wagerfy, 1102, Amsterdam, Netherlands
KVK: 97387606