Privacy Policy

This Privacy Policy was last updated on October 01, 2019.

This privacy policy (“Policy”) describes the data practices of PLLAY Labs Inc. ("PLLAY") and its subsidiaries (collectively, “Company” “We” “Us” or “Our”), covering its services under its control, including this website, www.PLLAY.me (the “Site”), any products, mobile applications, console or PC applications (collectively "Services"). This Policy will explain what information We collect online, why We collect it, and the choices We offer to you. We hope this will help you make an informed decision about sharing personal information with Us.

1. SCOPE OF PRIVACY POLICY

Please be advised that the practices described in this Privacy Policy apply to information gathered by PLLAY through Your direct and indirect interaction with the Services and through your electronic communications with PLLAY. This Policy does not apply to any information collected by any other method. PLLAY is not responsible for the privacy practices of any third parties, and you should contact such third parties directly to determine their respective privacy policies.

2. ACCEPTANCE OF PRIVACY POLICY/CHANGES TO THIS POLICY

By visiting or accessing the Site, by otherwise using the Services, and/or providing Us with your Personal Information (defined below), you consent to the terms of this Privacy Policy. You further: (i) consent to the transfers and processing of any information you provide to PLLAY and (ii) understand that PLLAY will collect, maintain, use, and disclose your Personal Information in accordance with this Policy and United States law. You hereby waive any claims that may arise under the laws and regulations that apply to you in any other country or jurisdiction. If you do not agree to the terms of this Policy, do not access the Site or otherwise use the Services.

A current version of this Policy will always be made available on Our Site. PLLAY reserves the right to change this Policy at any time without prior notice to you, and any amended Policy is effective upon posting to the Site. If We make what We determine to be material changes to this Policy, We will update the “Date Last Modified” and will notify you via email. Your continued use of the Site and the corresponding Service following such material changes requires your affirmative consent to the changes, which will require you to click on a box which verifies you have read and agree to the Policy. If you do not agree to the changes, your sole remedy is to cease using the Site. It is your responsibility to periodically check and review this Policy for changes.

3. NOTE REGARDING CHILDREN

Our Services are designed for adults (18+). We do not knowingly collect information for any child under the legal age to provide consent to data processing (13 in the US and up to 16 in the EU). If you are the parent of a child under the age required to provide consent and have a concern regarding your child’s information on our Services and/or wish to delete their data, please contact us at the email listed at the bottom of this policy.

4. INFORMATION WE COLLECT

We may collect information about the Services you use and how you use them, such as the selections you make on our Services. We collect PII, DII, and log information about your interactions as described below.

Personally identifiable information (“PII”) is information that can be used to identify or contact you online or offline, such as your name, address, email, phone number, photos or audio data, profile pictures, and payment information. The Service may collect PII when it is provided to us, such as when you use our Services, attempt to contact us or connect with us on social media or one of our partners. For example, you may see a “Log in with…” button from your phone, which means we request PII from a partner to streamline the login process. You will likely be presented with a “request for permission” screen by a third party asking to share your ID, profile picture, and other listed information with us. We may collect users’ government or similar IDs to verify accounts and may share that information with a vendor to conduct those verifications.

We may also create or collect device-identifiable information (“DII”), such as cookies, statistical identifiers, gamertags, device or advertising identifiers, usernames, and similar identifiers that are linkable to a browser, device, or account but which does not directly identify a person. From these platforms, we may also receive other information, such as your IP address, user agent, timestamps, precise and imprecise geolocation, sensor data, apps, fonts, battery life information, and screen size.

Our Services also collect information about your interactions, including navigation paths, search queries, crashes, timestamps, purchases, clicks and shares, and referral URLs. We may combine this data with PII and DII. For efficiency, information about your interactions may be transmitted to our servers while you are not using the app. We may also partner with third parties that collect additional information – please see their privacy policies for more details and see below for your choices regarding these parties.

5. HOW WE USE INFORMATION WE COLLECT

The information collected by Us will be used for a variety of business purposes, including, for example, to operate, maintain and provide you with the features and functionality of the Sites and Services. This may include (but is not limited to):

Please keep in mind that comments sections, forums, and other similar areas of our Services are public.  Any information posted in those areas is viewable and usable by anyone that has access.

6. HOW WE SHARE YOUR INFORMATION

PLLAY is committed to maintaining your trust and We want you to understand when and with whom We may share information collected about you. We never share information We receive from you unless: (i) We have your permission to share that information, e.g., a specific program that you can opt-in or out of at any time; (ii) We have given you prior notice that the information will be shared, and with whom (such as in this Privacy Policy); or (iii) the information is General Information, e.g., aggregate information or other information that does not identify you, which We may use and disclose without limitation.

We share PII with companies, outside organizations, and individuals for limited reasons, outlined below:

We use DII to operate our Services and manage user sessions, including analyzing usage of our Services, preventing malicious behavioral and fraud, improving the content, to link your identity across devices and browsers in order to provide you with a more seamless experience online, and helping third parties provide relevant advertising and related metrics. We share DII with third parties primarily for advertising and analytics purposes, for external processing, and for security purposes.

7. THIRD PARTIES

The Service may contain advertising and links to external third party sites that We do not own or operate. This may include links from advertisers, sponsors and/or partners that may use Our logo(s) as part of a co-branding or co-marketing agreement. While we strive to work with reputable companies with good privacy practices, this Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you on the Services. For further information, please see the relevant privacy policies for each third party and industry codes of conduct.

We also do not control the privacy policies and your privacy settings with third-parties, including social networks and ad networks. We have no control of the use or protection of information provided by you or collected by those applications or sites. You understand the consequences of posting any information are your sole responsibility. For example, once such information is posted to a social network, it will be subject to the policies, terms and conditions of that provider. You should familiarize yourself with the privacy policy provided by that party. Links to any third party sites or applications do not constitute or imply an endorsement or recommendation by PLLAY of the linked sites or applications. You agree that PLLAY shall not be responsible or liable for any loss or damage of any sort incurred by You as a result of Your dealings with any third party.

8. LEGAL BASES FOR PROCESSING

The data we process may qualify for multiple legal bases for processing under Article 6 of the General Data Protection Regulation (and similar laws that specify legal bases for processing). Below are our primary legal bases for each type of data for users covered under such laws:

It is contractually necessary and a legitimate interest to process your username, email, password, cookie data, IP address, account numbers on various platforms (e.g., your XBox or Steam ID), game information (including wins/losses, scores, and screenshots), device models, operating systems versions, and similar information to fulfill our obligations in the terms of service to provide you with and market our high quality products and services.

We obtain consent for the processing of data necessary for any optional profile information, such as your profile picture, your description, gender, birthday, and general location (e.g., state and country). Where users login with social media accounts, those companies have obtained consent on our behalf to use that data as described above.

We have a contractual necessity and a legitimate interest in collecting our users’ game activities for the purpose of tracking users’ game usage and stats, including to be used in leaderboards, to determine the winners of matches, and to help market our services to existing and new users.

We have a legitimate interest and a contractual necessity in processing and storing payment information in order to facilitate transactions between our users and ourselves. It’s a legitimate interest and we obtain consent to process your government-issued identifiers, such as driver’s licenses. This is used in order to verify our users’ identities and to prevent fraudulent users when dealing with payments.

It’s a contractual necessity and a legitimate interest to process your social data, such as teams, friends, friend requests, blocked users, chats, and direct messages. In some instances as necessary, we may obtain consent for such data.

We have a legitimate interest in processing users’ purchase history for the purpose of providing users help in fixing purchase and payment issues.

e have a legitimate interest in conducting analytics, measuring usage and conversions, detecting fraudulent users, implementing data security measures, and analyzing game telemetrics to improve our services. We and our processors have measures in place to protect your privacy.

We have a legitimate interest in enabling third-party ads and data collection on our sites and apps to help provide a more customized ad experience for our users and site visitors. We may also use ad mediation services that help us organize our vendors, who may also receive and transfer data from these ad partners. Our reputable partners provide measures to protect your privacy, such as pseudonymization and opt-outs. In some cases as appropriate, we or our partners obtain consent.

We have a legitimate interest in sending periodic emails and direct marketing to inform registered users of updates and offers. We make clear disclosures when users sign up and offer opt outs to anyone not interested.

For HR and internal operations, we rely on contractual necessity and legitimate interests to process the data of applicants and staff, such as for resumes and applications, payroll, internal chat and communications, and project management.

We have a legitimate interest in processing users’ personal data to provide customer support, debug problems, and answer sales questions, including data such as emails, names, and other details as necessary to answer user questions. Similarly, we have a legitimate interest in processing personal data (e.g., names, social media profile data, and chat data/metadata) for the purpose of responding to questions and messages on our social media accounts, including through automated bots.

9. CHOICE

If you wish to cancel your account, you can do so by accessing our Site or contacting us at support@pllay.me for assistance with the process. Additionally, if you do not wish to receive promotional marketing from Us, you can turn this off within the Site. Campaign Monitor will also remove you at your request. To make such a request You should contact us at support@pllay.me, with the subject heading “Opt-Out.” Please note that even if you opt-out or unsubscribe from promotional offers or other marketing messages, We still may need to share your PII or send communications relating to your use of the Services including, without limitation, responding to an inquiry initiated by you or for other legitimate non-marketing reasons.

Like many other companies, We do not honor DNT flags but instead, offer other choices with respect to third parties. Many third parties participate in self-regulation to offer you a choice regarding receiving targeted ads. Please note that you’ll still see generic ads after opting out, but they won’t be based on your activities online. On the web, you can opt out of participating companies by visiting the following sites:

If you wish to similarly opt out of cross-app advertising on mobile devices, you can enable the Limit Ad Tracking flag on the device. Enabling Limit Ad Tracking sends a flag to third parties that you wish to opt out of targeted advertising on that device, and major mobile platforms require companies to honor this flag. Screenshots on how to find these options on various devices are available here: http://www.networkadvertising.org/mobile-choices. For options on other platforms or devices, please see their respective privacy policies to learn about the choices they offer.

Users covered under the EU General Data Protection Regulation (or similar laws) have the right to access their data, rectify mistakes, erase their data, restrict certain processing (i.e., opt-out), export their data, withdraw consent, and lodge a complaint with a supervisory authority. Before using these rights, we may ask you to verify your identity to ensure that only you can use these rights on your own account.

10. PERSONAL INFORMATION HELD ON SERVERS WITHIN THE UNITED STATES

All data that is entered into the Services by you, or automatically imported on your instruction, is transferred to PLLAY’s servers as a function of transmission across the Internet. By accessing the Site and using the Services, you consent to such data being transferred to and stored, if applicable, on Our servers as set out in this Privacy Policy. Currently Our servers are located within the United States. If the location of Our servers change in the future, We will update this Privacy Policy.

11. ACCESSING AND UPDATING YOUR INFORMATION

We aim to provide you with a reasonable opportunity to access, update, and delete to your PII. We urge you to review your PII regularly to ensure that it is correct and complete. If you would like to review your PII or if you believe that any of your information is incorrect or has changed, please email Us at support@pllay.me . When updating your information, We may ask you to verify your identity before We can act on your request.

We will process your request as soon as reasonably practicable, provided We are not otherwise prevented from doing so on legal grounds, or your identity cannot be verified. If We are unable to meet your request, We will let you know why. For example, it may be necessary for Us to deny your request if it would have an unreasonable impact on the privacy or affairs of other individuals, or if it is not reasonable and practicable for Us to process your request in the manner you have requested.

12. HOW LONG USER INFORMATION IS KEPT

We will only keep your PII for as long as We require it for the purposes of operating the Site and providing you with the Services. We may keep a copy of your PII in Our archives for as long as We reasonably need it. We may alter this practice according to changing requirements. For example, We may delete some data if needed to free up storage space. We may keep other data for longer periods if applicable law requires.

Please note that PLLAY may need to retain some information about you in order to satisfy legal and security obligations. In addition, you should be aware that it is not always possible to completely remove or delete all of your information from databases without some residual data because of backups and other reasons.

13. INFORMATION SECURITY

We work hard to protect our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold and undertake reasonable security measures with appropriate confidentiality, integrity, and availability protections. However, since no software or storage system is 100% secure, we cannot guarantee for the security of your information associated with the Services, or any other service for that matter. You can help protect your account information by using unique and hard-to-guess passwords.

PRIVACY SHIELD

If we transfer personal information from the European Union to the United States, we will comply with the EU-U.S. Privacy Shield Framework and the Swiss - U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

For any questions or complaints regarding our compliance with either the EU-U.S. Privacy Shield Framework and the Swiss - U.S. Privacy Shield Framework, please contact us at the email listed at the bottom of this document. If we do not resolve your complaint, you may submit your complaint free of charge to the dispute resolution panel set forth by the data protection authorities, our designated independent dispute resolution provider (a panel established by the EU data protection authorities). Swiss users should refer complaints to the Swiss Federal Data Protection and Information Commissioner (FDPIC). Under certain conditions specified by the principles of the EU-U.S. and the Swiss - U.S. Privacy Shield Frameworks, respectively, you may also be able to invoke binding arbitration to resolve your complaint. We are also subject to the investigatory and enforcement powers of the US Federal Trade Commission. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. We may be legally obligated to disclose personal information to authorities to meet national security, law enforcement, or other legal requirements.

14. CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits residents of the State of California to request from certain businesses with whom the California resident has an established business relationship a list of all third parties to which the business, during the immediately preceding calendar year, has disclosed certain personally identifiable information for direct marketing purposes. We are only required to respond to a customer request once during any calendar year. To make such a request you should email Us at info@pllay.me with the subject heading “California Privacy Rights.” In your request, please attest to the fact that you are a California resident and provide a current California address for Our response. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information sharing that is covered will be included in Our response. We reserve the right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

15. SEVERABILITY

If any part of this Policy is held invalid or unenforceable, that portion shall be interpreted in a manner consistent with applicable law to reflect, as nearly as possible, Our original intentions, and the remaining portions shall remain in full force and effect.

16. CONTACT US

If you would like to contact Us for any reason about this Privacy Policy or Our privacy procedures and practices, please contact us at support@pllay.me. PLLAY is committed to your privacy.