Privacy Policy

Last updated on 12/8/2022.
This privacy policy (Privacy Policy) sets out the manner in which we may collect, use, disclose or otherwise process the data, whether true or not, about an individual who can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access (Personal Data) in accordance with the Personal Data Protection Act 2012 (Act 26 of 2012) of Singapore, as may be amended from time to time (PDPA). This Privacy Policy applies to all users of our website (Website).

1. Collection of information

Halfwish is a PvP Roguelite Play-to-Earn game. We provide the game and the platform. In order for us to provide the products and give you a complete experience, it is necessary for us to collect and use certain Personal Data.
While the specific types of Personal Data you submit through our Website may vary depending on the products you use, and whether you maintain an account with us, there are 7 broad categories of Personal Data which are collected by us and/or our Affiliates:
(a) Name.
(b) Identity Data, which includes your country of residence, job title, age, marital status and/or gender.
(c) Contact Data, which includes your email address, fax and/or telephone number.
(d) Transaction Data, which includes your credit card details, your billing address, your mailing address or the mailing address of the intended recipient of your order, payments and orders to and from you, and other details of products and services that you have supplied to or purchased from us.
(e) Usage Data, which includes information about how you use our Website (including the time you visit our Website, the duration of your Visit, the types of products and/or services you are searching for and/or how you are searching for such products and/or services).
(f) Marketing and Communications Data, which includes your interests, feedback, survey responses, preferences in receiving marketing materials from us and your communication preferences, as well as your preferences for particular products or services.
(g) Technical Data, which includes your Internet Protocol (IP) address, the internet device identity or media access control address of your device, information regarding the manufacturer, model or operating system of the device that you use and/or information about the web browser that you use to access our Website.
How we collect your Personal Data
We collect your Personal Data:
(a) Directly from you. You may give us your Identity, Contact, Profile and Transaction Data when you do any of the following (whether on your own behalf or on behalf of your organisation):
(i) use our Website;
(ii) create an account on our Website;
(iii) enter into a contract with us or purchase our products;
(iv) apply for or enquire about our Website or products;
(v) participate in a promotion, survey, event or other marketing campaign organised by us;
(vi) subscribe to our newsletters or alerts;
(vii) request marketing materials to be sent to you; or
(viii) contact us -- for example, if you get in touch to give us some feedback.
(b) From your authorised representatives. We may also collect your Identity, Contact, Profile and Transaction Data from your authorised representatives. These include persons whom you have authorised and persons who have been validly identified as acting on your behalf pursuant to our security procedures.
(c) When you interact with our Website. As you interact with our Website, we may automatically collect your Technical Data. We may collect such personal data by using website cookies.
(d) Third parties or publicly available sources. We may receive your Personal Data from third parties which are located in various countries. These include:
(i) Technical Data from analytics providers such as Google, advertising networks and social media platforms such as Discord, Twitter, Instagram and Facebook; and
(ii) Contact and Transaction Data from providers of technical, payment and delivery services.

2. Use of information

We may collect and use your Personal Data for any or all of the following purposes:
(a) To register you as a new customer.
(b) To verify your identity.
(c) To process and deliver your order(s).
(d) To manage your account, including managing payments, fees and charges and collecting and recovering money owed to us.
(e) To manage our relationship with you.
(f) To administer, operate, provide, maintain and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, as well as ensuring that unauthorised users do not access the information on our Website).
(g) To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve you.
(h) To make suggestions and recommendations to you about products or services that may be of interest to you.
(i) To send you relevant information about our events, news announcements or promotions.
(j) To enable you to complete a survey or participate in a promotion, survey, event or other marketing campaign organised by us.
(k) To contact you in relation to all of the above.
(l) To comply with any applicable laws, regulations, codes of practice, guidelines or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority.
(m) Any other purposes for which you have provided the information.
(n) Any other incidental business purposes related to or in connection with the above.
The purposes listed above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

Promotional offers and marketing

If you supply us with your Contact Data, you may receive periodic mailings, calls or faxes from us with information about new products and services or upcoming events. We will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your Personal Data to any third party for such marketing.
If you do not wish to receive such mailings or calls, you may “opt out” by logging into our Website and updating your preferences under “My Account”, or e-mailing us at the address listed below:


We use cookies to provide visitors with a personalised experience on our Website. Cookies are pieces of information that a website transfers to the memory or hard drive of a visitor’s computer for record-keeping purposes. We use cookies to allow access without re-entering the visitor’s User ID, to make improvements, and to better tailor our Website to our visitors’ needs. We also use this information to verify that visitors meet the criteria required to process their requests.
Most browsers used by visitors have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. However, if you disable or refuse cookies, please note that some parts of our Website may become inaccessible or not function properly. In addition, you can delete your Halfwish cookies from your browser program at any time.

Change of purpose

We will only process your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If there is any change in the purposes for which we collect your Personal Data, we will inform you of such change by way of a notice email. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at [email protected]. If we need to use your Personal Data for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do so as well as obtain your consent to the use of your Personal Data for such purpose where we are required to do so by law.

3. Disclosure of information

We may disclose your Personal Data to our Affiliates and third parties in limited circumstances as set out below:
(a) We may share your Personal Data with our suppliers, agents or contractors in connection with services they perform for us or pursuant to agreements with our suppliers.
(b) We may share your Personal Data with third parties to comply with a legal obligation, when we believe in good faith that an applicable law requires it, at the request of government authorities conducting an investigation, to verify or enforce our contractual rights or other applicable policies, to detect and protect against fraud or any technical or security vulnerabilities, to respond to an emergency, or otherwise to protect the rights, property, safety or security of third parties and visitors to our website or the public.
(c) As we continue to develop our business, we may sell or purchase assets. If another entity acquires or merges with us, your Personal Data will be disclosed to such entity.
(d) Also, if any bankruptcy or reorganisation proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible they will be sold or transferred to third parties.
We do not disclose your Personal Data to unaffiliated third parties for their independent use unless we have obtained your express consent to do so and pursuant to executing confidentiality agreements with such unaffiliated third parties. We also require all third parties to respect the security of your Personal Data and to treat it in accordance with the law.

4. Retention of information

We only retain your Personal Data for as long as is necessary for us to process your Personal Data as described above. However, please be advised that we may retain some of your Personal Data after you cease to use our services, for instance if the data is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.
In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

5. International transfers of information

We generally do not transfer your Personal Data to countries outside of Singapore. However, if we do so, we will take steps to ensure that your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the PDPA. For example, we will always ensure that there is a proper legal agreement that covers the data transfer.

6. Security

Our management and their teams take commercially reasonable precautions to keep all information obtained from our online visitors secure against unauthorised access (e.g. data breach) and use and we periodically review our security measures. Although there is no way that any Website can absolutely guarantee the security of your Personal Data, Halfwish is committed to employing reasonable security measures, regularly reviewing our security practices (security risk assessments / audits), and providing regular awareness training. You are responsible for keeping your login information and passwords confidential. Halfwish uses a Secure Sockets Layer (SSL) certificate, which allows you to view our Website through an HTTPS connection for its Website security certificates. Please be aware that these protection tools do not protect information that is not collected through our Website, such as information provided to us by e-mail.

7. Collection of information from children

Halfwish does not knowingly collect personal data from children under the age of 13. If you are under the age of 13, please do not provide personal data of any kind whatsoever.
If a child under the age of 13 provides us with personal data, a parent or guardian of that child may have this information deleted from our records by contacting us through [email protected].

8. Making changes to your Personal Data

You can access and edit any of the personal data that you have provided by logging into our Website and updating your preferences under “My Account”, or by contacting us through [email protected].
Our Website may contain links to other sites. These sites are not covered by this Privacy Policy, and we are not responsible for the privacy practices or the content of those other sites.

10. Changes to the Privacy Policy

We reserve the right to modify this Privacy Policy and related business practices at any time by posting updated text on this page. Please check this page periodically for updates. Your continued use of our Website and Services constitutes your acknowledgement and acceptance of such changes.

11. Contact us

If you have any comments, questions or complaints about our Privacy Policy, please contact our Data Protection Officer through [email protected].

[AA1]This means that your third party service providers must be bound by the PDPA when transferring information overseas.