1.      Introduction

This Privacy Policy (“Policy”) explains how Wwolf Games FZE, a legal entity registered under the Dubai World Trade Centre Free Zone (DWTC), hereinafter referred to as “Wwolf Club” or “Wwolf Games FZE”, collects, uses, stores, and protects personal data in accordance with the UAE Personal Data Protection Law (Federal Decree‑Law No. 45 of 2021) (“PDPL”), its Implementing Regulations, and applicable DWTC Free Zone regulations.

2.      Categories of Personal Data Collected

Wwolf Club may collect and process the following categories of Personal Data:

• Name, phone number, email address, and other contact details

• Demographic information, including gender and date of birth

• Membership applications, participation records, and event attendance

• Communication history (emails, messages, inquiries)

• Website usage analytics, cookies, and device identifiers

• Payment information processed securely by compliant third‑party providers

• Identity verification documents where required for specific programmes

• Photographs or media captured during Wwolf Club events (with consent where applicable)

• Any additional information voluntarily provided by individuals through forms, surveys, or direct communications

3.      Personal Data Processing

Wwolf Club uses Personal Data to:

• Manage and administer membership accounts

• Provide Wwolf Club Services, programmes, and events

• Ensure safety, integrity, and compliance with Wwolf Club policies

• Communicate updates, invitations, and opportunities

• Process payments and maintain financial records

• Enhance user experience and improve the quality of Wwolf Club Services and the functionality of its website and digital platforms

• Protect Wwolf Club’s legitimate interests, including fraud prevention and security

Wwolf Club processes Personal Data only to the extent necessary to fulfil these purposes and does not use Personal Data for purposes incompatible with this Privacy Policy.

4.      Legal Basis for Processing

Wwolf Club processes Personal Data under the following lawful bases:

• Consent – for optional activities, communications, and cookies

• Contractual necessity – to deliver membership services and fulfil related obligations

• Legal obligation – compliance with applicable UAE laws and DWTC Free Zone regulations

• Legitimate interests – security, fraud prevention, operational efficiency, and community engagement

5.      Data Protection and Security

Wwolf Club implements robust technical and organisational measures to safeguard Personal Data, including:

• Secure digital and physical storage practices

• Role‑based access controls

• Encryption and pseudonymisation where appropriate

• Regular internal security checks and vulnerability assessments

• Restricted access to Personal Data on a need‑to‑know basis

Wwolf Club regularly reviews and updates its security measures to maintain an appropriate level of protection in accordance with PDPL requirements.

Wwolf Club does not sell, trade, or rent Personal Data.

6.      Third-Party Service Providers

To deliver its Services, Wwolf Club may engage trusted third‑party service providers. These providers support essential operations and may process Personal Data strictly on behalf of Wwolf Club under contractual confidentiality and data protection obligations.

Categories of third‑party providers include:

• Website hosting and infrastructure providers

• Email and communication platforms

• Membership management and booking tools

• Payment processors (secure transaction handling)

• Cloud storage and backup services

• Analytics and performance monitoring tools

These providers are authorised to process Personal Data only to the extent necessary to perform the contracted services.

Wwolf Club does not permit third‑party providers to use Personal Data for their own marketing or independent purposes. All third‑party processing is governed by PDPL‑compliant agreements.

7.      Photography and Media Processing

Wwolf Club may capture photographs and short video clips during game sessions, events, and activities for the purpose of documenting experiences, celebrating community moments, and promoting future programmes. These materials may be used on Wwolf Club’s official website, digital platforms, social media channels, and marketing platforms.

Members and participants who prefer not to appear in any photos or recordings may notify a Curator or staff member at the start of the event. Wwolf Club will take reasonable steps, within operational constraints, to ensure such individuals are not included in media content. Participants may also request removal of any identifiable image by contacting support@wwolf.club.

Media content is processed in accordance with PDPL requirements and forms part of Wwolf Club’s legitimate interests in community engagement and programme promotion.

8.      Sharing of Personal Data

Wwolf Club may share personal data only with:

• Trusted third-party service providers supporting operational functions (including IT services, payment processors, and analytics platforms)

• Legal or regulatory authorities when required under applicable UAE laws

• Internal staff or authorised contractors bound by confidentiality obligations

Any sharing of personal data is limited to what is necessary for the relevant purpose and is conducted under PDPL‑compliant contractual safeguards.

Wwolf Club does not share personal data with third parties for their own marketing or independent purposes.

9.      Cross-Border Transfers

Where Personal Data is transferred outside the United Arab Emirates, Wwolf Club ensures that such transfers comply with PDPL requirements. This includes:

• Implementing adequate protection measures to safeguard Personal Data

• Using PDPL‑compliant contractual safeguards, including data transfer agreements where required

• Transferring Personal Data only to jurisdictions with appropriate data protection standards or recognised adequacy frameworks

• Engaging secure, PDPL‑compliant service providers that offer reliable technical and organisational protections

Cross‑border transfers are conducted only when necessary for the provision of Wwolf Club Services, the performance of contractual obligations, or other lawful bases permitted under PDPL.

10. International Participants

Wwolf Club welcomes participants from diverse international backgrounds. All Personal Data collected during in‑person or digital interactions within the United Arab Emirates is processed in accordance with PDPL, regardless of an individual’s citizenship.

Where Wwolf Club processes Personal Data of individuals located outside the UAE, such processing will be carried out in accordance with the applicable data protection requirements of those jurisdictions to the extent required by law.

11. Data Subject Rights

Individuals have the following rights to:

• request a copy of the information Wwolf Club holds about them

• update or amend inaccurate or incomplete details

• request removal of their information where legally permissible

• limit certain types of processing in specific circumstances

• opt out of non‑essential processing at any time

• receive their information in a structured, commonly used format where applicable

• raise concerns with the UAE Data Office

Wwolf Club may request identity verification to ensure the security of rights requests.

12. Cookies and Digital Tracking

Wwolf Club’s website uses cookies and similar technologies to:

• Support essential functionality and performance

• Analyse usage patterns and improve digital services

• Personalise and enhance the browsing experience

Details on the types of cookies used, their purposes, and available controls are provided in the Wwolf Club Cookies Policy, available on our website.

Website visitors may disable cookies through their browser settings. Certain website features may function sub‑optimally if cookies are disabled.

13. Data Retention and Deletion

Wwolf Club retains Personal Data only for as long as necessary to:

• Provide Services and manage membership

• Meet legal, regulatory, and accounting obligations

• Support operational needs and dispute resolution

Retention periods vary by data category:

• Game sessions and event participation records: up to 3 years after the event, unless a longer period is required for safety or compliance

• Communication history: up to 3 years for service quality, dispute resolution, and operational reference

• Payment and transaction data: a minimum of 5 years, and longer where required for audit or regulatory purposes

• Identification and contact records: for the duration of the relationship and up to 5 years thereafter for legal and accounting purposes

• Website analytics and cookies: up to 24 months

• Media content (photos/videos): retained while relevant to Wwolf Club’s activities, unless removal is requested or operational needs change

Certain retention periods may be extended where necessary to establish, exercise, or defend legal claims or to comply with regulatory requirements.

Certain data may remain in secure backups for limited periods until overwritten.

When retention periods expire, Personal Data is securely deleted, anonymised, or archived in accordance with PDPL and DWTC requirements.

14. Breach Response and Notification

Wwolf Club is committed to maintaining the security and confidentiality of Personal Data. In the event of a Personal Data breach that is likely to pose a risk to individuals’ rights, privacy, or security, Wwolf Club will, without undue delay:

• Take immediate steps to contain, assess, and investigate the breach

• Notify the UAE Data Office when required under PDPL

• Inform affected individuals when the breach is likely to result in harm or requires user action

• Provide clear guidance on protective measures

• Document the incident, maintain breach records, and implement corrective and preventive actions

15. Minors’ Data

Wwolf Club applies enhanced safeguards when processing Personal Data of individuals under 18, in alignment with PDPL and UAE youth‑protection standards.

Personal Data of minors may be collected for programme participation, event attendance, and membership, with processing strictly limited to administration, safety, and essential communication.

Age verification measures may be applied where necessary to ensure compliance.

Wwolf Club does not knowingly collect Personal Data from children under 14 outside designated youth programmes or without verified parental or guardian consent.

16. Marketing Communications

Wwolf Club may send Members, Participants, and subscribed contacts updates about events, programmes, opportunities, and relevant Wwolf Club news. Marketing communications are sent only:

• With the individual’s explicit consent, or

• Where permitted under applicable UAE law for existing Members or Participants

Recipients may withdraw consent or opt out at any time by using the unsubscribe link or by contacting support@wwolf.club. Opting out of marketing communications does not affect essential service notifications or operational messages.

17. Updates to This Policy

This Privacy Policy may be updated from time to time. Significant changes will be communicated through the website or official communication channels.

Updated versions become effective upon publication unless otherwise stated.

18. Contact Information

For privacy inquiries, data requests, or rights exercises, please contact us at support@wwolf.club or via the contact form available at https://wwolf.club/contact.

Version 1.0 - Effective Date: 16/10/2026