Windwalk Games Corp.Online Privacy Policy

Effective Date: May 5, 2023
Last Modified: June 15, 2023

Welcome to Windwalk

Windwalk Games Corp. describes itself as committed to “forging relationships rooted in trust and transparency.” The policy applies to website visitors, community members, clients, job applicants, and business partners engaging with their platforms (windwalk.com and harbor.gg) and Discord communities.

Services Offered: Community strategy, engagement initiatives, content creation, partnership establishment, moderation, growth tracking, and customized website/application design.

Data Collection

Data You Provide Directly

Website visits: Contact forms, social media links, Discord server participation
Services usage: Client data during sign-up; usage metrics for gamification, amplification, and community management
Community engagement: Discord activity, rewards unlocked, linked social media accounts
Events: Name, email, billing information
Job applications: Resume, employment history, educational background, references, citizenship status, salary expectations
Partnerships: Name, email, phone, job title, company name, business address

Automatically Collected Data

Device and usage information (IP address, device type, browser type, operating system)
Log data and engagement metrics
Cookies (essential, performance, functional)
Click-through analytics from social media links

Age Requirements

Services target adults. Communities are “not intended for children under the age of 13.” The company requests children under 13 not submit personal data and commits to removing inadvertently collected child data “as quickly as possible.”

Data Processing

Legal Bases for Processing

The company processes data under CCPA and GDPR frameworks, relying on:

Consent: Email marketing, cookies, social media integration
Contractual necessity: Service provision, purchases, giveaways
Legitimate interests: Responding to inquiries, preventing fraud, analytics
Legal obligations: Tax and accounting compliance
Vital/public interests: Rare cases protecting vital interests

Data Management Matrix

Data Subject	Information Type	Purpose	Basis
Website visitors	Contact information, online activity	Respond to inquiries; improve functionality	Legitimate interest
Discord members	Account identifiers, activity details, crypto wallet addresses	Community engagement; virtual transactions	Consent; contractual obligation
Harbor clients	Contact, financial, and contractual details	Client support; fulfill contracts	Contractual obligation; legitimate interest
Employees/contractors	Demographic, employment, and special category data	Manage employment; process payroll; evaluate applications	Legal obligation; legitimate interest
Business partners	Contact, financial, and partnership information	Facilitate collaboration; process payments	Contractual obligation; legitimate interest

Data Purposes

Communication, service provision, gamification, amplification, content creation, community management, employment evaluation, and legal compliance.

Data Disclosures

Disclosure Events

With explicit consent
To protect Windwalk or others (law enforcement, legal process)
During merger, sale, or bankruptcy
To authorized agents (with verification)

Recipient Categories

Clients and business partners
Vendors and service providers
Law enforcement and courts
Government bodies as required by law

Data Storage & Security

Storage Location

Data is “generally collected by us directly and processed in the United States.”

Retention

Data retained “as long as necessary to provide our services” with potential extension for legal/operational reasons. De-identification and anonymization applied where possible.

Security Measures

Multifactor authentication
Database encryption
Secure API transport
Cloud-hosted network segmentation
Access controls
Regular security examination and refinement

Limitation: “No security measure is entirely foolproof.” Company not responsible for unauthorized access or data theft.

Rights & Controls

User Rights

Authorized agents: Can represent users (with verification)
Right to be informed: Know what data is collected and how
Right of access: Obtain personal data held
Right to rectification: Correct inaccurate data
Right to data portability: Receive data in machine-readable format
Right to erasure: Delete data in certain circumstances
Right to object: Opt-out of processing or automated decision-making
Right to restrict processing: Limit data use pending accuracy disputes

User Controls

Account settings: Windwalk and third-party platform controls
Email opt-out: Unsubscribe links in marketing emails
Do Not Track: Not honored by company
Advertising preferences: Contact company or use platform tools
Cookie management: Browser controls available (though some site features may not work)

Third-Party Links

Advertising Opt-Outs

General Provisions

Policy Updates

Changes announced via prominent notices or direct notification. Last updated date revised accordingly.

Contact Information

Data Protection Team
Attention: Data Protection Team
Windwalk Games Corp (Windwalk)
210 Lavaca Street, Unit 2304
Austin, TX 78703
USA
Email: privacy@windwalk.com

EU Representative

IT Governance Europe Limited
Email: eurep@itgovernance.eu
Address: Third Floor, The Boyne Tower, Bull Ring, Lagavooren, Drogheda, Co. Louth, A92 F682

DPA Contact Options

California: Attorney General of California
Europe: DPA Directory (EDPB members list)