This Privacy Policy for the processing of personal data is prepared in accordance with the requirements of the General Data Protection Regulation (EU) 2016/679 ("GDPR"). It defines the procedures for processing personal data and the measures taken to ensure the security of personal data by WraithDevelopment LTD (hereinafter referred to as the "Operator"). The Operator is the legal owner of websites, services, programs, and other products, including but not limited to those of informational, communicational, advertising, educational, and entertainment nature (collectively referred to as the "Services" and individually as the "Service") accessible online at https://wraith.su/ (hereinafter referred to as the "Website") and individual Internet users (hereinafter referred to as the User) regarding the processing of information about the User, including personal data, during their use of the Services.

This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website https://wraith.su/.

Relations related to the processing of information, including but not limited to the collection, use, storage, dissemination, and protection of information about Website users, are governed by this Policy and the applicable laws of the European Union. Before beginning to use the Services, the User is required to familiarize themselves with this Policy.

By registering, accessing, and/or actually using any of the Services, the User agrees to the terms of this Policy, the privacy policies of the individual Services, as well as the terms, conditions, and rules of the Services they use, which are posted on the pages (in sections) of the respective Services in the versions that were in effect at the time of actual use of such Services.

The purposes of processing the User's personal data include:

• Conclusion, execution, and termination of civil law contracts;
• Formation of a customer base consisting of individuals for the subsequent conclusion and execution of civil law contracts (concerning all collected personal data);
• Sending notifications to the User (concerning all collected personal data);
• Preparation of individualized offers by the Operator (concerning all collected personal data).

The Operator may use personal information for internal purposes, such as auditing, data analysis, and various research activities aimed at improving the Operator's products and services and interacting with Users.

The Operator is also entitled to notify the User about new products and services, special offers, and various events. The User may opt out of receiving informational messages by sending a request to administrator@wraith.su with the subject "Unsubscribe from notifications about new products, services, and special offers."

Anonymized data collected from Users via internet statistics services is used to gather information about Users' actions on the Website, improve the Website's quality, and enhance its content.

• Automated processing of personal data: Processing of personal data employing computer technology;
• Blocking of personal data: Temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data);
• Website: A collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://wraith.su/;
• Information system of personal data: A collection of personal data contained in databases and the information technologies and technical means ensuring their processing;
• Anonymization of personal data: Actions resulting in the impossibility of identifying, without additional information, the specific User or other Subject to whom the personal data pertains;
• Processing of personal data: Any action (operation) or a set of actions (operations) performed with or without the use of automation tools concerning personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, usage, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data;
• Operator: A state authority, municipal authority, legal entity, or individual who independently or jointly with other persons organizes and (or) carries out the processing of personal data, as well as determines the purposes of the processing of personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data;
• Personal data: Any information relating directly or indirectly to a specific or identifiable User of the website https://wraith.su/;
• User (aka Data Subject): Any visitor of the website https://wraith.su/;
• Provision of personal data: Actions aimed at disclosing personal data to a specific person or a specific group of persons;
• Dissemination of personal data: Any actions aimed at disclosing personal data to an undefined group of persons (transfer of personal data) or at making personal data known to an unlimited number of persons, including the publication of personal data in mass media, placement in information and telecommunication networks, or provision of access to personal data in any other way;
• Cross-border transfer of personal data: Transfer of personal data to the territory of a foreign state, to a foreign state authority, a foreign individual, or a foreign legal entity;
• Destruction of personal data: Any actions resulting in the irreversible destruction of personal data with no possibility of further restoration in the personal data information system and/or the destruction of physical media containing personal data.

The information processed by the Operator includes:

• Username;
• Transfers (purchase);
• IP address;
• Browser language;
• Operating system;
• Unique PC identifiers.

The Website also collects and processes anonymized data about visitors (including "Cookies") using internet statistics services.

Cookies are small pieces of data that websites request from a browser on a computer or mobile device. These cookies are stored locally on the User's computer or mobile device. The Operator collects and processes cookies for Users who visit the Website.
The Operator may implement additional security measures to detect unauthorized activity. Specifically, in cases where decompiling, hacking, patching, debugging, or other reverse engineering attempts are detected, the loader may apply additional security measures in the form of account restrictions, etc. This security measure is solely intended to verify and investigate actions associated with cracking the product. It does not affect regular users under normal operation and is only triggered by the aforementioned unauthorized activities.

Information collected via cookies on the User's device may be transferred to and accessed by the Operator and/or third parties specified in section 6 of this Policy, as well as companies owning web analytics services such as Google Analytics, Microsoft Clarity, and/or similar services. The aforementioned data are collectively referred to as Personal Data in this Policy.

The Operator processes the User's personal data only if the User independently fills out and/or submits them through designated forms on the Website https://wraith.su/. By completing these forms and/or submitting their personal data to the Operator, the User agrees to this Policy.

The Operator processes anonymized User data if allowed by the User’s browser settings (for example, if cookies are enabled and JavaScript is used).

User accounts and other data are not disclosed to any third parties except as expressly provided by this Policy, other relevant rules, or applicable laws. The Operator may share User accounts and other data with third parties in accordance with the purposes and legal bases outlined in this Policy. Such third parties may include:

• Individuals providing services for placing and displaying information to Users (including offers relevant to User interests) regarding the Operator’s services through programs, products, or services owned or controlled by these individuals (e.g., website and application owners, advertising networks, etc.).
• Individuals who have legal grounds to process the User’s account and other data, such as when the User consents to the transfer of their data, or when the data are necessary to deliver a service or fulfill an agreement with the User (for example, mobile operators and technology partners acting as intermediaries between the Operator and mobile operators). These individuals may also include the Operator’s partners and affiliates whose data processing is covered by the terms of this Policy.
• Third parties to whom rights or obligations have been transferred, or novation has been made under the relevant agreement.
• Any government or local authority that, under applicable law, the Operator is obligated to provide information to upon an official request.

The Operator processes personal data, meaning operations performed with or without the use of automation tools, including the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (provision, access), anonymization, blocking, deletion, and destruction of personal data.

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of the applicable legislation in the field of personal data protection.

The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to it.

The term of personal data processing is valid during the term of validity of the account on the Website. It is terminated in case of withdrawal of consent or deletion of the account.

The User may at any time revoke their consent to the processing of personal data and/or delete their account by sending a request to the Operator at administrator@wraith.su with the subject line "Deleting an account and revoking consent to the processing of personal data".

The personal data being processed are subject to destruction or anonymization upon the achievement of the processing purposes, upon revocation of the Personal Data Subject's consent to the processing of personal data, or in case of loss of necessity and achievement of these purposes, unless otherwise provided for by the Personal Data Law. Data shall be destroyed by complete destruction of the physical medium or by deletion of data on electronic storage.

In processing personal data, the Operator takes necessary legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, and dissemination, as well as from other unlawful actions concerning personal data. The Operator shall take the following measures:

• Guarantees that all personal data is handled in strict compliance with confidentiality requirements and implements the highest security standards to prevent unauthorized or malicious access;
• Regularly reviews and identifies potential vulnerabilities or risks in the personal data systems to proactively address possible threats to data security;
• Evaluates the effectiveness of implemented security protocols prior to deploying any new personal data information systems;
• Maintains a detailed inventory of all data storage media, ensuring that access is tightly controlled and monitored;
• Consistently audits access logs and incident reports, promptly addressing any detected unauthorized attempts to access or misuse personal data.

The Operator may transfer the Subject's Personal Data to its employees for Personal Data Processing. With the Subject's explicit consent, the Operator may also transfer the Subject's personal data to its affiliates, including other companies within the same group as the Operator, as well as to parties with whom civil law contracts are concluded, which include mandatory obligations regarding the non-disclosure of personal data and liability measures for their disclosure.

The measures to ensure the security of Personal Data implemented within the framework of the Personal Data Protection system include:

• Verifying the identity of all individuals accessing personal data systems and ensuring only authorized personnel have appropriate clearance levels;
• Establishing strict access control mechanisms that prevent unauthorized users from interacting with sensitive data;
• Safeguarding all electronic storage devices used for personal data, including encryption and restricted physical access measures;
• Maintaining a comprehensive log of all security-related events, enabling continuous monitoring and early detection of suspicious activity;
• Implementing a robust antivirus defense strategy that regularly scans and eliminates potential threats;
• Deploying advanced intrusion prevention systems to detect and block malicious activities before they compromise personal data integrity;
• Conducting routine security assessments and system integrity checks to identify and resolve weaknesses in the data protection framework;
• Ensuring that all data systems and communication channels remain operational and accessible only to authorized users during both normal and emergency conditions;
• Isolating and securing virtual environments to prevent data leaks or unauthorized access across shared platforms;
• Implementing stringent protective measures for all technical equipment, ensuring that both physical and digital access points are secure;
• Constantly monitoring network traffic and data transmissions, swiftly addressing any anomalies or threats that might endanger personal data security;
• Establishing rapid response protocols for incidents that could disrupt the information system or threaten the security of personal data, ensuring timely resolution and minimizing impact.

The Operator shall not be liable for the disclosure and dissemination of information about the User by other Users or other Internet users if such persons have gained access to the said information in accordance with the privacy level settings selected by the User, or in the event of a breach by the User of the security of their login and/or password or other data necessary for authorization.

The User may obtain any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator at administrator@wraith.su.

This Policy, and any amendments thereto, may be made by the Operator with notice to the User, including by posting a new version of the amended Policy on the Website. Any changes made by the Operator to the Policy will come into effect the day after the new version of the Policy is posted on the Website. The User is obligated to independently review this Policy for any changes. Failure by the User to review the Policy cannot serve as grounds for the User's non-compliance with their obligations or the restrictions outlined in this Agreement.

The processing of personal data may be terminated upon the achievement of the purposes for which it is processed, the expiration of the consent's validity period, or the withdrawal of consent by the personal data subject, as well as upon the identification of unlawful processing of personal data.

Any changes to the Operator's personal data processing policy will be reflected in this document.

This Policy remains in force indefinitely until replaced by a new version.

The current version of the Policy is freely available online at https://wraith.su/privacy.

Information

For appeals to delete accounts, please contact the project administrator mail ( administrator@wraith.su ) form for emails is arbitrary, indicating account data (username, registration date, subscription payments, HWID and etc.)

Legal info

WraithDevelopment LTD

Official email: 
administrator@wraith.su

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