Effective Date: 05 September 2024.
1. SCOPE OF THIS PRIVACY POLICY
This Privacy Policy explains how we collect, process, and safeguard your information when you use one of our mobile games or browse our website (playscope.io). It also outlines your rights and choices regarding your information.
Please read this Privacy Policy carefully. If you disagree with this Privacy Policy’s terms, please do not access the site or use our games.
Our mobile games and website (playscope.io) are governed by our Terms of Use and aresubject to the provisions of this Privacy Policy.
Our games are published on our Google Play Store page.
2. WHO WE ARE
The words “we”, “our”, and “us” refer to PLAYSCOPE LTD, a limited liability company registered by the Department of Registrar of Companies and Intellectual Property of the Republic of Cyprus under the number HE 449513 at Archaias Lidras, 7, Geri, 2200, Nicosia, the Republic of Cyprus (“PLAYSCOPE”).
Unless stated otherwise, we act as the data controller responsible for determining the purposes and methods of processing your personal data following the EU General Data Protection Regulation (EU GDPR) and the UK General Data Protection Regulation (UK GDPR).
3. PROCESSING OF YOUR INFORMATION
When you use our games, we collect and otherwise process your information. This information can come directly from you or other sources and third parties.
Information We process Automatically:
1. Device Information (data about the device you use to play our games): device model, operating system and its version, IP address, language settings, time zone, and unique device identifiers (such as IDFA or GAID), enabled device accessibility features (e.g., display features, hearing features, and physical and motor features),mobile operator and network information; device storage information or version of your device system.
2. Location information: your IP address, which provides an approximate location (not precise), your time zone, or information about your mobile service provider.
3. Usage Data (data about your use of the game), including frequency of use; areas and features of the game that you access or use; payment transaction information (excluding full payment card details) or engagement with particular features, information related to the game performance, including crash or bug reports.
We may use cookies and similar technologies (such as pixels or web beacons) to collect this and other information. (Cookies are small text files stored on your device (like your computer, smartphone, or tablet) when you visit our website or use our games.
Information You provide us Directly:
When you contact us via email or our support form (for example, to ask about our game or request support), we may collect and use the contact information you provide, such as your name, email address, and any details in your messages or attachments.
4. WHY WE PROCESS YOUR INFORMATION
We process your information for the following purposes:
| Purpose of processing | Legal basis of processing |
| Game Functionality: To ensure the game operates correctly, such as saving game progress, managing in-game purchases, and providing personalized experiences. | Contract, Legitimate Interest. |
| Support: To assist you with technical issues, respond to inquiries, and provide customer support or troubleshooting. | Contract, Legitimate Interest. |
| Analytics and Improvement: To analyze how you interact with the game, track gameplay patterns, and identify areas for improvement to enhance the overall gaming experience. | Legitimate Interest. |
| User Communication: To send you important updates, notifications, or messages related to the game. | Legitimate Interest. |
| Advertising and Marketing: To deliver targeted advertisements, promotions, and offers based on your behavior and interests, and to measure the effectiveness of marketing campaigns. | Your consent (permission). |
| Security: To protect the game and its users from fraud, unauthorized access, and other security threats. | Legitimate Interest. |
| Compliance: To meet legal and regulatory requirements, including data protection laws and other relevant regulations. | Legitimate Interest. |
5. HOW WE SHARE YOUR INFORMATION
We may share your personal data with third parties, but only in the circumstances outlined below and in compliance with applicable laws:
Service Providers: We may share your information with third-party service providers who assist in delivering our services, including hosting providers, payment processors, analytics services, and customer support. These providers are contractually required to handle your data securely and only for the purposes outlined in our agreement, in compliance with applicable data protection laws.
Advertising and Analytics Partners: We may share limited personal data, such as device identifiers or anonymized usage data, with third-party advertising networks or analytics providers to help us deliver targeted advertisements, measure their effectiveness, and improve our services. These third parties may use cookies or similar technologies for tracking purposes.
Legal Compliance: We may disclose your personal data when required by law, such as to comply with legal obligations, respond to lawful requests from public authorities, or defend against legal claims.
Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the involved parties as part of the transaction. We will ensure that your data continues to be protected in line with this Privacy Policy.
We ensure that any third parties who receive your personal data are subject to appropriate data protection and security obligations.
Please note that when integrating external services, we carefully select third parties committed to implementing the necessary technical and organizational measures to protect user personal data. However, we cannot guarantee the security of information once it is transmitted to these third parties. We are not responsible for any accidental loss or unauthorized access to your personal data caused by third-party actions beyond our control.
Please note that we do not sell your personal data to third parties. However, we may share data collected from cookies, log files, device identifiers, and location information with third-party companies that provide automated processing technologies for our games.
The following categories of recipients, including third-party providers and advertising partners, may be involved in processing your information for various business purposes. These purposes include providing the necessary infrastructure for the operation and enhancement of our game, as well as performing services related to the games:
• Adjust GmbH (analytics), location: Germany [privacy policy];
• AdMob (Google LLC) (ad management), location: U.S.A. [privacy policy];
• AppLovin Corporation (analytics, ad management), location: U.S.A. [privacy policy];
• IronSource Mobile Ltd (analytics, ad management), location: Israel [privacy policy];
• Meta Platforms, Inc. (analytics, ad management), location: U.S.A. [privacy policy];
• UnityAds (ad management), location: U.S.A. [privacy policy].
Our games may include integrations or links to third-party websites or services. When you engage with these third parties, any information you provide will be directly shared with them, and they are responsible for how they handle your data. Please be aware that we do not control or take responsibility for the privacy practices of these third parties or any entities we do not own or manage. Visit the websites and privacy policies of the respective recipients above for more details about the services, privacy options, and opt-out choices.
6. INTERNATIONAL DATA TRANSFERS
We are based in the Republic of Cyprus (EU). However, your personal information may be transferred and processed outside the EU.
We may transfer your personal information to countries or regions where EU standards do not consider data protection laws adequate. In such cases, we will implement approved safeguards to ensure your data receives the same level of protection as it does within the EU.
In certain cases, we may transfer your personal information to countries without an adequacy decision or appropriate safeguards if allowed under specific exceptions, known as ‘derogations’. These exceptions may apply in situations such as when you have explicitly consented to the transfer or when the transfer is necessary to perform a contract with you.
7. HOW LONG WE PROCESS YOUR INFORMATION
We typically retain your personal data only as long as needed to operate our games and website and to comply with legal requirements. You can request deletion to stop us from using your data. However, certain information may be kept for a limited time if required by law (e.g., for taxation, accounting, or auditing purposes) to maintain data backups and security, prevent fraud, or address other security issues.
8. SECURITY OF YOUR DATA
We use standard security technologies, procedures, and organizational measures to protect your data. This includes safeguarding your information from unauthorized access, use, or disclosure and ensuring its integrity and confidentiality.
9. MINORS
For details about age limitations for our games and website, please refer to our Terms of Use. We do not knowingly collect personal data from children without parental consent. If you are a parent or guardian and believe we have collected your child’s information violatingapplicable laws, such as GDPR or COPPA, please contact us at privacy@playscope.io. We will take immediate action to remove the information following applicable law.
10. YOUR RIGHTS
Data protection laws grant you specific rights regarding your personal information. You have the following options concerning the personal information we have collected:
If you are located in the European Union (EU), the European Economic Area (EEA), or the United Kingdom (UK), you have specific rights concerning your personal data under the EU GDPR and UK GDPR. These rights are detailed below:
Right to Access: You can request access to the personal data we hold about you.
Right to Rectification: You can request that we correct or update any inaccurate or incomplete personal data.
Right to Erasure: You may ask us to delete your personal data under certain conditions, such as when it is no longer necessary for the purposes for which it was collected.
Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data in certain situations.
Right to Data Portability: You can request a copy of your personal data in a structured, commonly used, and machine-readable format and to have it transferred to another organization.
Right to Object: You have the right to object to processing your personal data, including for direct marketing purposes, at any time. Once you object, we will cease processing your data unless we can demonstrate compelling, legitimate grounds for the processing that override your interests, rights, and freedoms or if it is necessary to establish, exercise, or defend legal claims.
Right to Withdraw Consent: If we process your personal data based on your consent, you may withdraw your consent at any time.
Right to Lodge a Complaint. You have the right to file a complaint with a data protection authority if you believe your rights under the EU GDPR or UK GDPR have been violated. You can do this in the Member State where you live, work, or where the issue occurred. For more information on how to make a complaint, please contact us or visit the relevant data protection authority’s website.
If you are a California resident, the California Consumer Privacy Act of 2018 (CCPA) grants you specific rights regarding your personal information. These rights allow you to request access to the personal information we hold, ask for the deletion of your personal information, and opt out of any sale of your personal information.
Under the California Consumer Privacy Act of 2018 (CCPA), California residents have the right to request:
• Categories of Personal Information: The categories of personal information we process.
• Sources of Personal Information: The sources from which we obtain personal information.
• Purpose of Processing: The purposes for which we process your personal data.
• Third Parties: The categories of third parties with whom we may share your personal information.
• Specific Pieces of Personal Information: The specific pieces of personal information we have collected about you, provided the data you supply is sufficient to verify your identity.
To exercise any of these rights, please email us at privacy@playscope.io. We will respond to your request according to applicable data protection laws.
If you are not a resident of the European Union (EU), the European Economic Area (EEA), the United Kingdom (UK), or California, you may still be able to request access to, correction of, or deletion of certain personal information we hold about you, depending on your location. We may require proof of identity and residency before processing such requests for your protection. To make a request, please contact us at privacy@playscope.io. Please note that if we change or delete your personal information, or if you choose not to share certain information, some game features and functionality may no longer be available to you. We will honor these requests as allowed by applicable law.
11. OPT-OUT
Push Notifications
We may send you push notifications through our games to keep you updated. You can manage or opt-out of these notifications by adjusting your device settings.
Opt-out of targeted advertising
• For iOS devices:
You can opt out of interest-based advertising in our games by adjusting your iOS device’s privacy settings. Go to Settings > Privacy & Security > Tracking and turn off ‘Allow Apps to Request to Track’ to prevent games from accessing your device’s Advertising Identifier (For more details, visit Apple’s support page).
To disable Apple’s ad targeting, go to Settings > Privacy & Security > Apple Advertising and turn off ‘Personalized Ads.’ (For more details, visit https://support.apple.com/en-us/HT202074).
• For Android devices:
If you prefer not to have third-party service providers use your data to personalize ads based on your interests, go to Settings > Google > Ads on your Android device and select ‘Opt out of Ad Personalization.’ For more information, you can visit Google’s help page.
You can also opt-out of personalized in-game offers through the options provided in the game settings (where applicable).
Please note that opting out of personalized ads does not mean you will stop seeing ads altogether. You may still receive contextual ads based on non-personal information. These ads are not tailored to your interests but are based on our games’ general content or functionality.
12. UPDATES TO THIS PRIVACY POLICY
We may update this Privacy Policy occasionally to reflect changes in our practices, legal requirements, or other operational reasons. When we make significant changes, we will notify you by one or more of the following methods: through a notice within our games or by posting a notification on our website.
We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of our games or website following any changes to this Privacy Policy will signify your acceptance of those changes.
13. CONTACT US
If you have any questions or concerns about your privacy, contact us at privacy@playscope.io or our Data Protection Officer (DPO) at dpo@playscope.io.