Last Updated: January 24, 2022
Papaya Gaming Ltd. (“Papaya”, “we”, “our” or “us”) develops and operates social skill games for mobile environments; "Apps"). We also operate the website www.papayagaming.com, its subdomains, and its related features (“Website”, and together with the Apps – the “Services”).
Specifically, it describes our policy regarding –
1. What types of data do we collect?
2. Tracking Technologies
3. Why do we process your Personal Data?
4. With whom do we share your data?
5. EU residents
5.1. Your rights
5.2. Transfer of data outside the EU
6. California residents
6.1. What information do we process
6.2. Sources of Personal Data
6.3. Sale of Personal Data
6.4. User right under the CCPA
7. How do we protect your data?
10. Updates to this Policy
11. Controlling Version
12. Data Protection Officer
13. Contact Us
We strongly urge you to read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue and avoid using our Services. You have the right to cease using our Services, pursuant to this Policy at any time.
You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the full range or with the best experience of using our Services.
What types of data do we collect?
We collect two types of data from you: Personal Data ("Personal Data") and non-Personal Data. Personal Data means any information which may potentially allow your identification with reasonable means (for example, email address or name). Non-Personal Data, by contrast, can be defined as any information that does not relate to an identified or identifiable natural person. This may include, for example, your aggregated usage information and technical information transmitted by your device (e.g. the device you use, the type of browser and operating system your device uses, language preference, access time, etc.). This section sets out how and when we collect those types of data from you.
1.1 Account Information. If you choose to register an account with our Services, we collect your full name, email address, phone number, birth date, and username. If you choose to log in, access or otherwise connect to the Services through a social networking service (such as Facebook, Twitter, Instagram, etc.), we may collect your user ID and/or username associated with that social networking service, as well as any information you make public using that social networking service or that the social networking service allows us to access.
2.1 Payment Information. When you decide to deposit money in our Apps, you will be required to provide us with your billing information. The information you will need to submit depends on which billing method you choose. For example, if you pay with a credit card, we will collect your card information.
2.2 Usage Information. When you use our Services, we collect technical information about your interaction with our Services. Such information may include geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) as well as other information which relates to your activity in the Services.
2.3 Communication Information. When you send us an email or contact us via the support in our Apps or Website, we collect the Personal Data you provide us. This may include your name, email address and any other information you choose to provide.
2. Tracking Technologies
2.1 What types of Tracking Technologies do we use?
When you use or access our Services, we use the following categories of Tracking Technologies:
Strictly Necessary Tracking Technologies – these Tracking Technologies are automatically placed on your computer or device when you access our Services or take certain actions on our Apps or Websites. These Tracking Technologies are essential to enable you to navigate around and use the features of our Services. We do not need to obtain your consent in order to use these Tracking Technologies;
Tracking and Advertising Tracking Technologies – These Tracking Technologies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The Tracking Technologies remember the websites you visit and that information is shared with other parties such as advertisers and/or publishers. Publishers, advertisers, and third-party ad networks may also utilize Tracking Technologies or similar technologies to deliver ads and monitor the performance of such ads. The collection of information through Tracking Technologies by such third parties will be governed by their own privacy policies/cookies policies and principles, which the Company does not control;
Functionality Tracking Technologies – These Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services;
Performance Tracking Technologies – These Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services), including behavioral data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).
2.2 How and by whom Tracking Technologies are stored on your device?
We store Tracking Technologies on your device when you visit or access our Services (for example, when you are visiting our Website) – these are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example, our analytics service providers, business partners, and advertisers), who run content on our Services – these are called "Third Party Tracking Technologies". Both types of Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits.
There are various ways in which you can manage and control your Tracking Technologies settings. You can change your preferences using our cookie settings tool (however, please note that this tool may only be available in certain jurisdictions). Other methods of managing your Tracking Technology preferences includes: changing your browser settings to send a “Do-Not-Track” signal. In such case, your browser will send us a special signal to stop tracking your activity;. However, please note that certain features of the Website may not work properly or effectively if you delete or disable cookies.
To learn more about how can manage your cookies, below is a list of useful links that can provide you with more information on how to manage your cookies:
You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third-party webpages:
You can withdraw your consent to personalized advertising experience on your device at any time by using your device settings as follows:
On iOS, depending on the applicable iOS version, you may withdraw consent across all apps by either enabling the “Limit Ad Tracking” setting or disabling the “Allow Apps to Request to Track” permission in your iOS device settings. Depending on the applicable iOS version, instead of withdrawing consent on a device-wide basis, you may also have the option of withdrawing consent on a per-app basis by disabling tracking permissions for specific apps that appear under the “Allow Apps to Request to Track” setting in your iOS device settings (precise directions may differ depending on the applicable iOS version.)
On Android devices, you may withdraw your consent in the Google Ads settings within your Android settings by enabling the “Opt-out of Ads Personalization” setting (precise directions and the name of the setting may differ depending on the applicable Android versions and device manufacturer).
3. Why do we process your Personal Data?
This section explains for what purposes we use your Personal Data and outlines the legal bases that underlie our usage.
Providing users with a fair, balanced, and competitive experience on our Services is extremely important to us. Therefore, we strictly enforce prohibitions against cheating, hacking, account stealing, and any other unauthorized or fraudulent activity. When you create an account, play our games, or otherwise interact with our Services, we may use a variety of anti-cheat and fraud prevention technologies to help us identify and prevent malicious activity. These services may collect and analyze data about the game binary or your computer to detect cheating, and may be provided by us or by third-party service providers.
4. With whom do we share your data?
We may share your Personal Data as described below:
Affiliated companies: we may share Personal Data internally within our family of companies, for the purposes described in this Policy.
Payment processors: we share your payment information with third-party payment processors, for the purpose of facilitating your payments when using our Services. These third parties may have access to your Personal Data so that they may perform these tasks on our behalf.
Service providers: we work with service providers that work on our behalf that may need access to certain personal data in order to provide their services to us. These companies include those we have hired to provide customer service support, operate the technical infrastructure that we need to provide the services, and cloud storage vendors.
Third-party advertisers: we may partner with third parties to either display advertising on our Services or to manage our advertising on other websites or apps. Our third-party advertisers may use Tracking Technologies to gather information about your activities on our Services and other websites and apps in order to provide you advertising based upon your browsing activities and interests. For more information, please visit our partner's privacy policies in the following links: AppLovin and Unity.
Third-Party Integrations: the Services allow you to integrate with certain third-party services, such as in order to connect your Facebook or Apple account to our Apps or to place purchases, in which case you will be bound by the terms and conditions and privacy notices of said third parties (e.g., Apple, Google or Facebook) – so please make sure that you read and accept them in advance. We do not receive or store your passwords for any of these third-party services.
Compliance with laws and law enforcement entities: we may disclose any data about you to the government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal procedures (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
Auditors and advisers: we may share your data with our external auditors, advisors, and professional service providers (e.g. lawyers, accountants, insurers, etc.) for ensuring our compliance with regulatory requirements and industry standards.
Mergers and acquisitions: We may share your data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Policy. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail and/or a prominent notice on our Services.
5. Marketing and Advertising
We may use your Personal Data ourselves or by using our third-party subcontractors for the purpose of providing you with promotional materials, concerning the Services as well as products, services, websites, and applications which relate to: (i) affiliated companies or Company's business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you.
You may at any time decline receiving further marketing offers from us or from our business partners and Marketing Affiliates by contacting us at email@example.com
Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
6. EU residents
6.1 Your rights
This section addresses the specific rights applying to residents of the EU or residents of other jurisdictions that grant the below rights.
You may request to:
Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used, and machine-readable format.
Request rectification of your Personal Data that is in our control.
Request erasure of your Personal Data.
Object to the processing of Personal Data by us.
Request to restrict processing of your Personal Data by us.
Please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. You are welcome to contact us for any questions or requests through our contact details below.
We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.
6.2 Transfer of data outside the EU
Any information that we collect (including your Personal Data) may be stored and processed in various jurisdictions around the world, for the purposes detailed in this Policy. However, we will only transfer your data to data recipients (i) located in the European Economic Area (the “EEA”), (ii) located in non-EEA countries which have been approved by the European Commission as providing an adequate level of data protection, or (iii) who entered into legal agreements ensuring an adequate level of data protection.
7. California residents
7.1 What information do we process
In the preceding 12 months, we have collected, and or disclosed the following categories of Personal Data:
7.2 Sources of Personal Data
In the 12 preceding months, we have collected the above-mentioned categories of Personal Data from the following categories of sources:
7.3 Sale of Personal Data
We do not "sell" Personal Information about our users as most people would typically understand that term. However, we do allow certain third-party advertising partners to collect information about consumers through our Services for purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for ad fraud detection and reporting. Please see our "Cookies and Tracking Technologies" section above for more information.
7.4 User right under the CCPA
The CCPA provides consumers with specific rights regarding their Personal Data. This section describes your CCPA rights and explains how to exercise those rights.
Access to Personal Data
You may request, up to two times each year, that we disclose to you the categories and specific pieces of Personal Data that we have collected about you, the categories of sources from which your Personal Data is collected, the business or commercial purpose for collecting your Personal Data, the categories of Personal Data that we disclosed for a business purpose, any categories of Personal Data about you that we sold, the categories of third parties with whom we have shared your Personal Data, and the business or commercial purpose for selling your Personal Information, if applicable.
You have the right to request that we delete any Personal Data collected from you and retained unless an exception applies.
Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your Personal Data, unless an exception applies.
Right to Opt-Out of the Sale of Personal Information
In the event that we sell your Personal Data, you have the right to submit a request to opt out of the sale of your Personal Data. You may change your decision at any time and permit us to sell your Personal Data.
After you opt-out, we may continue to share some Personal Data with our partners (who will function as our service providers in such instance) to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services is working correctly and securely, providing aggregate statistics and analytics and/or preventing fraud.
Right to non-discrimination
You have the right to be free from any discrimination for exercising your rights under the CCPA. Should you exercise any of your rights under the CCPA, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request. However, in some circumstances, for example where you have requested or consented to our Services that use your Personal Data to provide the service, we may not be able to provide a service if you choose to delete your Personal Data
Exercising Your Rights
You can exercise your rights by submitting a verifiable consumer request to our physical address (as written below in the "How to contact us" section) or to our email address: firstname.lastname@example.org.
Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Data.
The request must:
Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative.
Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
You can designate an authorized agent to make a request under the CCPA on your behalf if:
The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
You sign a written declaration that you authorize the authorized agent to act on your behalf.
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
8. How do we protect your data?
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. Such breaches can lead to things such as reputational harm, fraud or identity theft. Therefore, we encourage you to exercise discretion regarding the Personal Data you choose to disclose. If you feel that your privacy was treated not in accordance with our Policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly via our contact details available below.
We do not knowingly collect or solicit Personal Data from anyone under the age of consent (as determined under the applicable laws where the individual resides; “Age of Consent”). By accessing, using or interacting with our Services, you certify to us that you are not under the Age of Consent. In the event that we learn that we have collected Personal Data from an individual under the Age of Consent without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Consent, then please contact us through the contact details available below.
We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.
11. Updates to this Policy
We reserve the right to change this Policy at any time. The most current version will always be posted on our Services (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.
12. Controlling Version
13. Data Protection Officer
The Company has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. If you have any questions about this Policy, please contact our Data Protection Officer (the contact details are available in the "Contact Us" section).
14. Contact Us
If you have any further questions, please contact us by email at: email@example.com.
Papaya Gaming Ltd.
22 Isserles St.
If you reside in the EU, you may also contact our EU representative:
European Data Protection Office
via form: here
Attn: EDPO, Avenue Huart Hamoir 71, 1030 Brussels, Belgium.
If you reside in the UK, you may also contact our UK representative:
EDPO UK Ltd.
via form: here
Attn: EDPO UK, 8 Northumberland Avenue, London WC2N 5BY, United Kingdom