Last revised: 8th of April 2026

 

PRIVACY POLICY

 

1. WHO WE ARE

This Privacy Policy applies to One Way Eleven, a collaborative brand operated by Wowsystems Informática, Lda., a  company registered in Portugal (“Company”, “we”, “us”, “our”), with registered office at Rua da Queimada de Cima n.33, 1º, 9000-065 Funchal, VAT Number (NIPC): PT511281897.

Wowsystems Informática, Lda. acts as the data controller for the personal data described in this policy.

For any data protection matters, you can contact us at:

info@onewayeleven.com

(this inbox is managed by Wowsystems Informática, Lda.)

 

2. INFORMATION WE COLLECT

2.1 Personal Data You Provide

We may collect personal data that you voluntarily provide, including:

• Name (or first name)
• Email address
• Any information you include in messages or job applications (e.g. CV, experience, portfolio)

 

Please provide accurate and up-to-date information when submitting your personal data.

 

2.2 Automatically Collected Data

 When you use our website, we may automatically collect:

• IP address
• Browser and device information
• Operating system
• Pages visited and interactions
• Approximate location (based on IP)

This data is collected for security, analytics, and performance purposes.

Providing personal data is voluntary. However, failure to provide certain information may prevent us from responding to your enquiry or processing your request.

 

3. HOW WE USE YOUR DATA (PURPOSES & LEGAL BASES)

 We process your personal data under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) based on the following purposes and legal bases:

 

3.1 Communication

• Responding to messages or enquiries

Legal Basis: Legitimate interest (to respond to user enquiries and maintain communication with potential clients, partners, or users)

 

3.2 Newsletter & Marketing

• Sending news, updates, exclusive content, digital rewards, and downloadable content related to our games

Legal Basis: Consent

 

3.3 Recruitment

• Managing spontaneous job applications

Legal Basis: Pre-contractual measures; Legitimate interest (to evaluate candidates and manage recruitment opportunities)

 

3.4 Website Operation & Security

• Ensuring proper functioning and security
• Preventing fraud and abuse

Legal Basis: Legitimate interest (to ensure the security and reliability of our services)

 

3.5 Analytics

• Understanding how users interact with our website

Legal Basis: Consent (where required for cookies)

We use services such as Google Analytics to understand website usage. Google Analytics is configured to anonymize IP addresses and does not allow us to directly identify individual users. Cookies for analytics are used only with consent when required.

 

3.6 Business Communications

• Handling incoming business-related emails, proposals, and service offers

Legal Basis: Legitimate interest (to manage business relationships and evaluate potential partnerships or services)

 

Where we rely on legitimate interest, we ensure that such interests are not overridden by your rights and freedoms.

You have the right to object to processing based on legitimate interest at any time.

 

4. NEWSLETTER

When you subscribe to our newsletter, we collect:

• Email address
• First name (optional)
• IP address and subscription timestamp (for consent verification and security purposes)

 

We use this data to send occasional:

• News
• Updates
• Exclusive content related to our games

Our communications may include promotional content related to our games.

Emails are sent from team@onewayeleven.com.

We use MailerLite to manage subscriptions.

You can withdraw your consent at any time by:

 

• Clicking the unsubscribe link in the footer of any email
• Contacting us at info@onewayeleven.com for questions regarding your personal data, access requests, or deletion requests

 

The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. 

 

5. JOB APPLICATIONS

 We may receive spontaneous job applications via email.

In this context, we may process:

• Name
• Email
• CV
• Professional Experience
• Portfolio
• Any additional information you provide

 

Legal basis:

• Pre-contractual measures
• Legitimate interest

 

Retention:

 We retain candidate data for up to 12 months, unless:

• A longer period is required by law
• You consent to future opportunities

You may request deletion at any time.

 

6. COOKIES

 We use cookies and similar technologies to ensure website functionality and, where required, for analytics.

• Essential cookies: Necessary for the website to function correctly (e.g. newsletter forms).
• Analytic cookies: Services such as Google Analytics are used to understand website usage and interactions. These cookies are only activated after you provide consent through our cookie banner. Google Analytics is configured to anonymize IP addresses and does not allow us to directly identify individual users.

You can manage cookies through your browser settings or cookie banner.

Third-party services such as Google Analytics may set cookies, and their own privacy policies apply.

 

7. SHARING YOUR DATA

 We may share data with trusted service providers (data processors), such as:

• Website hosting
• Email service provider
• Newsletter providers
• Analytics services

These providers process data on our behalf under contractual agreements.

We may also share data if required by law.

 

8. THIRD-PARTY LINKS

 Our website may contain links to external platforms. Their own privacy policies apply, and we are not responsible for their data practices.

Participation in these platforms is voluntary.

Our games may be distributed via third-party platforms. Any purchases or interactions on such platforms are governed by their respective privacy policies.

 

9. INTERNATIONAL DATA TRANSFERS

Some of our service providers may process data outside the European Economic Area (EEA).

When this happens, we ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses approved by the European Commission.

 

This Privacy Policy applies to all users of our Services, regardless of their location.

 

10. DATA RETENTION

We retain personal data only as long as necessary for the purposes described in this policy:

 

• Newsletter data/marketing communications: until you unsubscribe
• Contact emails: retained for as long as necessary to handle the request and maintain relevant communications, and for a reasonable period thereafter, depending on the nature of the interaction
• Job applications: up to 12 months, unless you consent to future opportunities
• Technical / log data: up to 12 months

 

In all cases, we ensure that personal data is not kept longer than necessary and is periodically reviewed.

 

11. YOUR RIGHTS

Under GDPR, you have the right to:

• Access your data
• Rectify inaccurate data
• Request deletion
• Restrict processing
• Data portability
• Object to processing
• Withdraw consent at any time

 

The withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

 

To exercise your rights, contact:

 info@onewayeleven.com

 

12. COMPLAINTS

If you believe your data is being processed unlawfully, you have the right to lodge a complaint with:

Comissão Nacional de Proteção de Dados (CNPD)

Website: https://www.cnpd.pt

 

13. DATA SECURITY

We implement appropriate technical and organisational measures to protect your data. However, no system is completely secure, and transmission of data is at your own risk.

 

14. CHILDREN

We do not knowingly collect personal data from children under 16 without  parental consent.

If we become aware of such collection, we will delete the data promptly.

 

15. CHANGES TO THIS POLICY

Updates will be posted with a revised date.

 

16. CONTACT

If you have questions about this policy, please include “Privacy” in the subject line of your email:

info@onewayeleven.com

Address: Rua da Queimada de Cima n.33, 1º, 9000-065 Funchal, Portugal