Privacy Policy

Last updated: 31 Oct, 2024

Overview

Welcome to Player Gift! We take your privacy seriously. This Privacy Policy (“Policy”) explains how this app (“Player Gift,” “we,” “us,” or “our”) collects, uses, and safeguards your personal information when you interact with our mobile app, website, and related services (collectively referred to as “Services”). By using Player Gift, you are agreeing to the practices described in this Policy.

This Policy is part of our Terms of Use and should be read together with it. Please note, this Policy only applies to your interactions with Player Gift. If you access games or services provided by other developers through our platform (“Game Partners”), their privacy practices will apply to your data as governed by their own privacy policies, which we recommend you review separately.

If you do not agree with any part of this Privacy Policy, we encourage you to stop using our Services immediately.

Data Controller Information

Player Gift is responsible for managing your personal data. Below are our official details:

Company Name: Game Rewards LLC

Company Address: 1401 PENNSYLVANIA AVE. UNIT 105 WILMINGTON, DE 19806 US

Contact Email: [email protected] (Include “Privacy” in the subject line)

Consent and Age Restrictions

By selecting “ACCEPT & CONTINUE” during the account creation process, you acknowledge that you have read, understood, and agree to the terms outlined in this Privacy Policy and our Terms of Use (referred to herein as “User”). If you are under the age of 18 or do not agree to these terms, you are not permitted to create an account or use Player Gift.

This Privacy Policy is integrated into our Terms of Use. By utilizing Player Gift’s services, you agree to comply with both documents. You can access the Terms of Use at any time from the footer of our website or within the mobile app.

Policy Updates

We reserve the right to modify this Privacy Policy at our discretion. Any updates will be reflected by the “Last Updated” date at the top of this Policy. Significant changes will be communicated through notifications within the Player Gift app or via email. Please review this Policy periodically to stay informed about how we protect your privacy. Continued use of our services after any modifications implies your acceptance of the revised terms.

We are committed to collecting and processing your data only for legitimate purposes as outlined in this Policy and in compliance with applicable data protection laws. This approach is designed to safeguard your privacy and ensure responsible data management.

By providing this transparent overview of our data practices, Player Gift aims to build trust and give you control over your personal information. If you have any questions or need further clarification, feel free to contact us using the information provided in this Policy.

Personal Data We Collect

Data Collected Directly by Player Gift

In this section, we outline the types of personal data (“Personal Data”) that we collect when you interact with Player Gift. “Personal Data” refers to any information that can be used to identify you personally, including your name, email address, and other identifiers. This data is collected and maintained securely by us to enhance your experience and comply with legal requirements.

Account Data Collection

When you create an account or engage with Player Gift, we collect various types of information directly from you:

Name: We collect your first and last name to create your Player Gift account.

Age: Providing your age helps us enforce age restrictions and deliver features tailored to different age groups.

Gender (Optional): You may choose to provide gender information, which allows us to personalize recommendations. If you change your mind, you can adjust your account settings to opt-out.

Email or Social Media Account: We use your Google or Facebook account for login purposes. We collect information such as your email address from these platforms to communicate with you regarding updates, promotions, and support.

Profile Picture: If you choose to upload a profile picture or use your Google/Facebook picture, it may be visible in certain areas of the app, such as leaderboards. You can replace it with an avatar or opt-out at any time.

Phone Number: We may collect your phone number to verify your identity via SMS. If you provide explicit consent, we may also send promotional offers via SMS.

FaceID: To protect the integrity of reward redemptions, we may use a “video selfie” verification process to prevent fraudulent activity.

Account Preferences: We collect preferences such as your language settings or notification preferences to customize your experience.

Direct Communication: Any information you share through direct communication, such as customer support inquiries or feedback, is collected to improve our services.

Promotions and Contests: If you participate in a promotion or contest, we may collect additional information, such as your username or email, as per the specific terms and conditions.

Device Data Collection

We also collect information about the devices you use to interact with Player Gift:

IP Address: We collect your IP address to understand your approximate location (at a city or country level) and for security purposes.

Geolocation Data: With your consent, we may collect precise geolocation data to provide location-based services. This data is collected periodically and not on a continuous basis.

Mobile Device Identifier: We collect unique identifiers such as your device’s IMEI or advertising ID for identification and security purposes.

Advertising Identifier: We use identifiers like the Google Advertising ID to serve personalized ads and measure their effectiveness. You can opt-out through your device settings.

Device Information: We collect information about your device, including operating system, device model, and language preferences, to optimize our services for your device.

User Activity and Interaction Data

In addition to the data provided directly by you, we also collect information related to your activities on Player Gift:

Log Data: We collect information about your network connection type and pages you visit within the platform for security and service improvement purposes.

Gameplay Data: We collect data related to your gameplay, such as progress, playtime, and in-game activities. With your consent, and in compliance with Game Partner policies, we may also collect information about in-game purchases and achievements. We encourage you to review the privacy policies of our Game Partners for additional details.

User Audience Segments: We may use collected data (including log data, gameplay data, installed app data, and geolocation data) to create audience segments. This allows us to offer personalized services and promotions tailored to your preferences.

Here’s a revised version of this section for Player Gift, tailored to fit the new app’s context while enhancing clarity and maintaining legal compliance:

Where We Store Personal Data

Data Storage Locations:
Your personal data is securely stored on servers provided by Amazon Web Services (AWS) & Azure Cloud Services, located in [Germany or your relevant region]. However, to facilitate the delivery of Player Gift’s services, your data may be transferred to and processed in other regions, including the United States, where some of our service providers are based.

Data Protection and Associated Risks:
We take strong precautions to ensure your data is protected by selecting reputable service providers and implementing contractual safeguards. However, it’s important to note that the privacy laws in other jurisdictions may differ from those in your home country and may offer less protection. Additionally, in some cases, your information could be accessed by foreign governments under local laws.

GDPR Compliance:
If you are located in the European Economic Area (EEA) or the United Kingdom (UK), your data is securely transferred and stored in compliance with the General Data Protection Regulation (GDPR). We ensure that all transfers outside of the EEA and UK are carried out under legal mechanisms such as Standard Contractual Clauses (SCCs) to maintain adequate data protection standards.

Use of Personal Data

To comply with data protection laws, we must meet specific legal conditions before we can use your personal data as described in this Privacy Policy. Depending on the nature of our activities, we rely on one or more of the following legal bases for processing your personal data:

Consent: You have provided explicit consent for us to process your data.

Legitimate Interests: Processing is necessary for our legitimate business interests or those of a third party, provided it doesn’t override your rights or interests.

Legal Obligation: Processing is required for us to comply with our legal obligations.

Legal Claims: Processing is necessary for the establishment, exercise, or defense of legal claims.

Public Interest: Processing is necessary for reasons of substantial public interest.

Below, we provide more details on the legal bases for collecting and using your personal data. Should we need to use your personal data for any purpose not covered in this Privacy Policy, we will inform you and seek your consent where required by law.

Consent

We ask for your informed and affirmative consent to use your personal data as outlined in this Privacy Policy when you use the Platform. If you do not consent, please refrain from using the Platform and its Services.

No Sale of Personal Data:

We do not sell personal data in a way that directly identifies individuals.

Marketing and Promotions:

If you have provided consent, we may send you marketing communications about Player Gift’s services, products, promotions, and special offers. You may be contacted via mail, email, phone, or electronic notifications based on your chosen preferences. Additionally, with your consent, we may share your information with our affiliates for marketing purposes. You can modify your marketing preferences at any time in your account settings.

Withdrawing Consent:

You may withdraw your consent at any time. However, doing so may affect your ability to access certain features or services on the Platform. Withdrawal of consent does not affect the legality of processing based on prior consent, nor does it impact the processing of personal data on grounds other than consent.

For more information on how to withdraw your consent, please refer to the “Withdrawal of Consent to Collect Personal Information” section of this Privacy Policy.

Legitimate Interest

In some cases, we may rely on our legitimate interests to collect and use your personal data without requiring your explicit consent. Our legitimate interests allow us to operate the Player Gift platform effectively, enhance user experiences, and maintain the integrity of our services.

Before processing your data under legitimate interests, we conduct a balancing test to ensure our interests do not override your fundamental rights and freedoms. This test evaluates the necessity of using your personal data (for example, to provide platform access) against your individual rights (such as your rights under applicable data protection laws, including the Delaware Online Privacy and Protection Act, GDPR, or other regulations).

We always take reasonable steps to consider your interests and ensure your data is processed fairly. The key legitimate interests for which we process your personal data include:

Personalized User Experience:

We use collected data to tailor your experience on Player Gift, offering game and feature recommendations based on your preferences.

Rewarding Engagement:

When you actively engage with the games available through the platform, we utilize data to track your activity and allocate rewards through the Player Gift program.

Service Optimization:

Your data helps us monitor game installations, manage gift card redemptions, and enhance your overall experience on the platform.

Marketing and Promotion:

We may use your data to promote our services and offerings, ensuring that marketing efforts are strategically aligned with user interests and preferences.

Participation in Events:

Your data may be used to facilitate your participation in contests, sweepstakes, and other events, helping us select winners and ensure a smooth experience.

Operational Efficiency:

Accurate data collection allows us to manage reward programs and attribute game installs effectively, ensuring the platform operates efficiently.

Security and Fraud Prevention:

Data is crucial for safeguarding the platform, preventing fraudulent activity, and maintaining the integrity of the reward system.

Face Verification for Security:

For security purposes, we use face verification technology to ensure legitimate user registration, prevent fraudulent activity, and secure rewards. This involves capturing a short video selfie to create a unique identifier, encrypted and securely transmitted for processing. This helps to:

Ensure unique user registrations to prevent duplicate accounts.

Prevent fraud by detecting bots or unauthorized software.

Protect rewards by ensuring they are issued to legitimate, verified users.

Product Development and Innovation:

Insights from user data drive the creation of new features and improvements to existing services.

Data-Driven Insights:

Aggregated and anonymized data helps us generate reports that optimize various aspects of the platform.

Effective Communication:

Understanding user preferences allows us to deliver more relevant and personalized communications.

Machine Learning for Personalization:

We utilize data to develop machine learning models that further enhance the personalization of content and recommendations.

Contractual Performance

By using the Player Gift platform, you enter into a contractual relationship with us as outlined in our Terms of Use. This relationship forms the legal basis for processing your personal data. We collect, use, and store your personal information to fulfill our contractual obligations and facilitate your use of the platform. This includes managing your account, tracking your gameplay and rewards, and providing customer support. Without processing your data, we cannot provide the services outlined in our Terms of Use, which you accept by accessing the platform.

Legal Obligations and Legal Claims

We are obligated to process your personal data when required to comply with legal requirements, such as tax, accounting, or regulatory obligations. Additionally, we may process your data to pursue or defend legal claims if necessary.

We may also disclose your personal data to third parties without your consent when we have a reasonable belief that such disclosure is necessary to:

Identify, contact, or take legal action against individuals or entities causing harm or interference with our rights, property, or users of the platform.

Protect the rights or property of Player Gift, its users, or other third parties who could be harmed by these actions.

Comply with legal requirements or respond to lawful requests by public authorities, including meeting national security or law enforcement requirements.

This data will only be shared when we believe, in good faith, that such disclosure is legally required.

Substantial Public Interest

In certain cases, we may process your personal data for reasons of substantial public interest. This would occur under the specific provisions of applicable data protection laws, which ensure that such processing is carried out fairly and responsibly to protect public interest while respecting your individual rights.

DATA PROCESSING ACTIVITIES REQUIRING YOUR SPECIAL ATTENTION

Automatic Collection:

Certain information listed in the section titled “Personal Data We Collect” is automatically collected when accessing and using our services, such as:

Aggregated usage information

Session ID

Access time and date

Device data

This automatic data collection helps us provide, maintain, and improve our services.

Push Notifications:

Player Gift may send push notifications to users to achieve the purposes outlined in this Privacy Policy. Users can typically opt out of receiving push notifications by adjusting their device settings, such as the notification settings for mobile phones, and modifying those settings for this application or for all apps on their device. However, disabling push notifications may impact the utility and experience of using Player Gift.

Children’s Data Privacy Protection:

Player Gift is committed to protecting the privacy of children. We do not knowingly collect personal data from anyone under 18 years of age. By using the platform, you confirm that you are at least 18 years old. If we discover that personal data from users under the age of 18 has been collected due to a misrepresentation of their age during registration, we will deactivate the account and take immediate steps to delete the data from our records. If you become aware that we have inadvertently collected personal information from a minor under 18, please contact us at [email protected].

Important points to remember:

This Privacy Policy does not apply to the data practices of third-party games or platforms accessed through Player Gift.

Children under 18 are not permitted to use the platform.

Player Gift retains data for legal purposes, as long as the user actively engages with the service or as required to fulfill the original purpose of data collection.

Information about cookie usage and other tracking technologies can be found in our separate Cookie Notice.

External Links:

Our services may direct you to external websites or applications, such as the Google Play Store, which are controlled by third parties. These external sites have their own privacy policies, which are not governed by Player Gift. Please review their privacy policies to understand how your data may be processed.

Withdrawal of Consent to Collect Personal Information:

If you wish to withdraw consent for the collection of personal information, you can submit a written request to [email protected]. Upon receipt, we will:

Stop Processing: Cease processing your personal information within a reasonable time.

Effects of Withdrawal: Please note that withdrawing consent may affect your ability to use the services, including forfeiting loyalty points or other benefits. Withdrawal will not affect the legality of any data processing that occurred before the withdrawal, nor will it affect processing that relies on lawful grounds other than consent.

Account Deletion: You may request account deletion at any time. Upon account deletion, any unredeemed loyalty points will be forfeited, and we will confirm deletion via email (refer to the Data Retention section above).

Promotional Communications:

If you have provided explicit consent, we may send you promotional communications. You may opt out of receiving these communications at any time by following the unsubscribe instructions included in each message. Please note that even if you opt-out of promotional emails, you may still receive essential non-promotional communications regarding your account, services you’ve requested, or our ongoing business relationship.

SERVICE PROVIDERS PROCESSING PERSONAL DATA ON OUR BEHALF

We may engage third-party contractors and service providers to process the personal information collected from you, as outlined in this Privacy Policy. These service providers assist us in delivering and maintaining our services. We ensure that these providers are contractually obligated to keep your personal data secure and confidential. They are not permitted to disclose your data without our explicit authorization, nor are they allowed to use your data for purposes other than those described in this Privacy Policy. However, if you maintain an independent relationship with any of these service providers, their privacy policies will apply to that relationship.

Advertising:

We may use advertising services to utilize User Data for communication and marketing purposes. These communications may appear in the form of banners or other advertisements within the Player Gift platform and may be tailored to reflect User interests. Please note that not all personal data is used for these purposes, and detailed information on how your data is processed can be found below.

Some of the advertising services may utilize trackers to identify users or employ behavioral retargeting techniques, which display advertisements based on your interests and behaviors both within and outside of Player Gift. For more detailed information on how these services work, please refer to the privacy policies of the relevant advertising service providers.

In addition to any opt-out features provided by these services, users may opt out of certain advertising-related data collection by visiting the Network Advertising Initiative’s opt-out page. Users can also manage and opt out of certain advertising features through their device settings, such as mobile device advertising settings or general ad preferences.

AdMob (Google Ireland Limited): AdMob is an advertising service provided by Google Ireland Limited. To understand Google’s use of Data, consult Google’s partner policy.
Place of processing: Ireland – Privacy Policy – Opt Out.

Adgem: In addition to personal information that we may receive from you, AdGem may collect other information from Users using the following technologies:

Cookies. “Cookies” are small bits of information that the Platform places on the hard drive of your computer. Cookies remember information about your activities on the Platform to make your visits to the Platform more enjoyable and valuable to you by providing a customized experience and recognizing your preferences when you visit the Platform. If you’ve chosen to disable cookies on your browser, some of the functionality of the Platform may be lost. Certain Services provided by AdGem, require that cookies be enabled in your browser and cannot be used when you have disabled cookies in your browser.

Web Server Logs. Web server logs are records of activity created by the computer that delivers the web pages you request to your browser. For example, a web server log may record the search term you entered or the link you clicked to bring you to a webpage. The web server log also may record information about your browser, such as your IP address and the cookies set on your browser by the server.

Device Information. We may collect information about the mobile device or computer you use to access the Platform, including without limitation the hardware model, operating system and version, browser type, unique device identifiers, and mobile network information.

SDK Information. We may collect information from a Software Development Kit (SDK) that our Customers integrate into their applications allowing them to provide end users with advertising. By downloading and using the Customer’s application, end users are permitted to share information collected by the SDK with AdGem under this Privacy Policy.

Facebook Audience Network (Facebook Ireland Ltd): Facebook Audience Network is an advertising service provided by Facebook Ireland Ltd To understand Facebook’s use of Data, consult Facebook’s data policy. This Application may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User’s ad preferences. The User can control this in the Facebook ad settings.

Users may opt out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones, or by following the instructions in other Audience Network-related sections of this privacy policy, if available.

Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.

Adjust (Adjust GmbH): Adjust is an advertising service provided by Adjust GmbH.

Personal Data processed: Tracker; Usage Data.
Place of processing: Germany – Privacy Policy – Opt out.

AdColony (AdColony, Inc.): AdColony is an advertising service provided by AdColony, Inc.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy – Opt out.

Tapjoy (Tapjoy, Inc.): Tapjoy is an advertising service provided by Tapjoy, Inc.

Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.

Liftoff (Liftoff Mobile, Inc.): Liftoff is an advertising service provided by Liftoff Mobile, Inc.

Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.

PubMatic (PubMatic, Inc.): PubMatic is an advertising service provided by PubMatic, Inc.

Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.

Smaato (Smaato, Inc.): Smaato is an advertising service provided by Smaato, Inc.

Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.

TripleLift (TripleLift, Inc.): TripleLift is an advertising service provided by TripleLift, Inc.

Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.

Unruly (Unruly Group Ltd): Unruly is an advertising service provided by Unruly Group Ltd.

Personal Data processed: Tracker; Usage Data.
Place of processing: United Kingdom – Privacy Policy – Opt out.

InMobi: InMobi is an advertising service.

Personal Data processed: Tracker; Usage Data.
Place of processing: India – Privacy Policy – Opt out.

Mintegral (Mintegral International Ltd.): Mintegral is an advertising service provided by Mintegral International Ltd.

Personal Data processed: Tracker; Usage Data.
Place of processing: China – Privacy Policy – Opt out.

AppLovin (AppLovin Corporation): AppLovin is an advertising service provided by AppLovin Corporation.

Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.

myTarget (MGL MY.COM (CYPRUS) LIMITED): myTarget is an advertising service provided by MGL MY.COM (CYPRUS) LIMITED.

Personal Data processed: Tracker; Usage Data.
Place of processing: Russia – Privacy Policy – Opt out.

DT Exchange (Digital Turbine Inc.): DT Exchange is an advertising service provided by Digital Turbine Inc.

Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.

Pangle (Bytedance Pte. Ltd.): Pangle is an advertising service provided by Bytedance Pte. Ltd.

Personal Data processed: Tracker; Usage Data.
Place of processing: Singapore – Privacy Policy – Opt out.

Google Ad Manager (Google Ireland Limited): Google Ad Manager is an advertising service provided by Google Ireland Limited that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner unless otherwise specified in this document, has no direct relationship with. To opt out of being tracked by various advertising networks, Users may make use of Youronlinechoices. To understand Google’s use of data, consult Google’s partner policy. This service uses the “DoubleClick” Cookie, which tracks the use of this Application and User behavior concerning ads, products, and services offered.

Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.

Google AdSense (Google Ireland Limited): Google AdSense is an advertising service provided by Google Ireland Limited. This service uses the “DoubleClick” Cookie, which tracks the use of this Application and User behavior concerning ads, products, and services offered. Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings – Opt Out.

Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.

Unity Ads (Unity Technologies ApS): Unity Ads is an advertising service provided by Unity Technologies ApS.

Personal Data processed: Tracker; Usage Data.
Place of processing: Denmark – Privacy Policy – Opt out.

Aarki (Aarki Inc.) Aarki is an advertising service provided by Aarki Inc.

Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.

Fluct (Fluct Inc.) : Fluct is an advertising service provided by Fluct Inc.

Personal Data processed: Tracker; Usage Data.
Place of processing: Japan – Privacy Policy – Opt out.

Vungle: Vungle is an advertising service.

Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.

Chartboost (Chartboost Inc.): Chartboost is an advertising service provided by Chartboost Inc.

Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.

Ironsource (Ironsource Mobile Ltd.): Ironsource is an advertising service provided by Ironsource Mobile Ltd.

Personal Data processed: Tracker; Usage Data.
Place of processing: Israel – Privacy Policy – Opt out.

Analytics:

The services listed in this section allow Player Gift to monitor and analyze web traffic, as well as track user behavior to improve the app’s functionality and overall user experience. These analytics services collect and process data that help us understand how users interact with the platform, identify trends, and make informed decisions about future updates and improvements.

The personal data collected through these services may include usage data, device information, and interaction data, which are aggregated and anonymized where possible to safeguard your privacy. However, if you wish to opt-out of certain analytics services, you may do so by adjusting your device settings or using any available opt-out mechanisms provided by the specific analytics service.

Please refer to the privacy policies of the relevant analytics providers for more details on the data they collect and how they process it.

Google Analytics for Firebase (Google Ireland Limited): Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google Ireland Limited. To understand Google’s use of Data, consult Google’s partner policy. Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.

This Application uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.

Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.

Personal Data processed: Application opens; Application updates; device information; geography/region; In-app purchases; launches; number of sessions; number of Users ; operating systems; session duration; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

Place of processing: Ireland – Privacy Policy.

Flurry Analytics (Flurry, Inc.) :Flurry Analytics is an analytics service provided by Yahoo! Inc. This service is designed for mobile apps analytics and can collect various information about your phone, highlighted in the Flurry Analytics privacy policy. If the User chooses to opt-out, Flurry will stop tracking data for the device identified by the provided MAC address and/or device identifier going forward. The analytics service tracking will stop across all applications within the Flurry network.

Personal Data processed: Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy – Opt Out.

Facebook Analytics for Apps (Facebook Ireland Ltd): Facebook Analytics for Apps is an analytics service provided by Facebook Ireland Ltd

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.

Unity Analytics (Unity Technologies ApS): Unity Analytics is an analytics service provided by Unity Technologies ApS.

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Denmark – Privacy Policy.

Yandex Metrica (YANDEX, LLC) :Yandex Metrica is an analytics and heat mapping service provided by YANDEX, LLC. Yandex Metrica is used to display the areas of this Application that Users interact with most frequently. This shows where the points of interest are.

Personal Data processed: Tracker; Usage Data.
Place of processing: Russian Federation – Privacy Policy.

Facebook Ads conversion tracking (Facebook pixel) (Facebook Ireland Ltd): Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook Ireland Ltd that connects data from the Facebook advertising network with actions performed on this Application. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.

Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.

Beta Testing

This type of service makes it possible to manage User access to this Application, or parts of it, for the purpose of testing a certain feature or the entire Application. The service provider may automatically collect data related to crashes and statistics related to the User’s use of this Application in a personally identifiable form.

Google Play Beta Testing (Google Ireland Limited): Google Play Beta Testing is a beta testing service provided by Google Ireland Limited.

Personal Data processed: country; device information; device logs; Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.

TestFlight (Apple Inc.): TestFlight is a beta testing service provided by Apple Inc.

Personal Data processed: app information; country; device logs; Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.

Content Performance and Features Testing (A/B Testing):

The services listed in this section allow Player Gift to track and analyze user responses to changes in the app’s design, content, structure, or features. By running A/B tests, we can evaluate user behavior and preferences to optimize the app’s functionality and user experience. These services help us determine which variations of the app perform better, ensuring we deliver the best possible experience to our users.

The personal data processed during A/B testing may include usage data and interaction data. This data is aggregated and anonymized to protect your privacy while helping us make informed decisions on improvements.

For more detailed information on the specific A/B testing services we use, please refer to the privacy policies of the relevant service providers.

Firebase Remote Config (Google Ireland Limited) : Firebase Remote Config is an A/B testing and configuration service provided by Google Ireland Limited.

Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.

Applovin (Applovin Corporation): Applovin is an analytics and marketing service provided by Applovin Corporation.

Personal Data Processed: country; device information; device logs; Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States –Privacy Policy.

Appsflyer (AppsFlyer Limited): Appsflyer is an analytics and marketing service provided by AppsFlyer Limited.

Personal Data Processed: country; device information; device logs; Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Handling Payments:

Unless otherwise specified, Player Gift processes payments via external payment service providers. These may include credit card payments, bank transfers, or other payment methods. Users are generally required to provide their payment information and personal details directly to the payment service provider, as Player Gift does not collect or process payment details.

We only receive a confirmation from the relevant payment service provider once your payment has been successfully completed. For information on how your payment data is collected and processed, please refer to the privacy policies of the respective payment service providers.

RevenueCat (RevenueCat, Inc.): RevenueCat is a payment service provided by RevenueCat, Inc. The service allows the Owner to monitor and analyze the User and their purchase history and can be used to keep track of User behavior.

Personal Data processed: Application opens; device information; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.

Payments are processed via the Apple App Store (Apple Inc.): This Application uses a payment service provided by Apple Inc. that allows the Owner to offer the purchase of the app itself or in-app purchases.

Personal Data processed to complete the purchases are processed by Apple, as described in the privacy policy for the App Store.

Personal Data processed: payment info.
Place of processing: United States – Privacy Policy.

Payments processed via the Google Play Store (Google Ireland Limited): This Application uses a payment service provided by Google Ireland Limited that allows the Owner to offer the purchase of the app itself or in-app purchases.

Personal Data processed to complete the purchases are processed by Google, as described in the privacy policy for the Google Play store.

Personal Data processed: payment info.
Place of processing: Ireland – Privacy Policy.

Payments processed via Paypal (Paypal Holdings, Inc.): Our Services use a payment service provided by Paypal Holdings, Inc. that allows us to offer in-app purchases.

Personal Data processed to complete the purchases are processed by Paypal, as described in their Privacy Policy.

Personal Data processed: payment info.

Place of processing: United States – Privacy Policy.

Hosting and Backend Infrastructure:

These services are used to host data and files that enable Player Gift to function, be distributed, and provide the necessary infrastructure to run various features of the app. Hosting and backend infrastructure services ensure that Player Gift operates smoothly and efficiently.

Some of the services listed below may operate through geographically distributed servers, which can make it difficult to determine the exact physical location where your personal data is stored. However, all service providers we use are required to comply with applicable data protection laws to ensure your information is secure.

For more details on the specific hosting and backend services used by Player Gift and their respective data handling practices, please refer to their privacy policies.

Amazon Web Services (AWS) (Amazon Web Services, Inc.): Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Azure Cloud Services )(Microsoft): Azure Cloud Services is a hosting and backend service provided by Microsoft.

Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.

Infrastructure Monitoring:

Infrastructure monitoring services allow Player Gift to monitor the use and performance of its components, ensuring that the app operates smoothly and efficiently. These services help improve the app’s performance, facilitate maintenance, and assist in troubleshooting any issues that arise.

The specific personal data processed by these services depend on how they are implemented and their respective features. These services work by filtering the activities within Player Gift to identify issues, optimize functionality, and enhance the overall user experience.

For more information on the specific infrastructure monitoring services we use, and how they process data, please refer to the privacy policies of the relevant service providers.

Firebase Performance Monitoring (Google Ireland Limited): Firebase Performance Monitoring is a monitoring service provided by Google Ireland Limited.

Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.

Crashlytics (Google Ireland Limited): Crashlytics is a monitoring service provided by Google Ireland Limited.

Personal Data processed: crash data; device information; Universally unique identifier (UUID).
Place of processing: Ireland – Privacy Policy.

Managing Contacts and Sending Messages:

This type of service enables Player Gift to manage databases of email addresses, phone numbers, or other contact details in order to communicate with users. These services allow us to send important notifications, updates, or promotional messages to users.

In addition, these services may collect data related to message interaction, such as the date and time a message was viewed by the user, or when a user clicked on any links included in the message. This data helps us measure the effectiveness of our communications and improve future messaging.

For more information on how your contact information is handled, and details on the specific services used for managing and sending messages, please refer to the privacy policies of the relevant service providers.

Firebase Notifications (Google Ireland Limited): Firebase Notifications is a message-sending service provided by Google Ireland Limited. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events.

Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.

Platform Services and Hosting:

Platform services and hosting solutions are essential for running and maintaining key components of Player Gift. These services allow the app to function by providing a unified platform that supports a variety of tools, such as analytics, user registration, database management, e-commerce, and payment processing. As a result, these services involve the collection and handling of personal data.

Some platform services operate through geographically distributed servers, which may make it difficult to pinpoint the exact location where personal data is stored. However, all platform and hosting services we use are required to comply with data protection regulations to ensure the security and privacy of your personal data.

For more information on how your data is managed and where it may be processed, please refer to the privacy policies of the relevant platform service providers.

Apple App Store (Apple Inc.): This Application is distributed on Apple’s App Store, a platform for the distribution of mobile apps, provided by Apple Inc.

By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enable the Owner to view usage analytics data and measure the performance of this Application. Much of this information is processed on an opt-in basis.

Users may opt out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.

Google Play Store (Google Ireland Limited) :This Application is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google Ireland Limited.

By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.

Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

Personal Data processed: Usage Data.
Place of processing: Ireland – Privacy Policy.

Social features

Firebase Dynamic Links (Google Ireland Limited) :Firebase Dynamic Links is a social feature provided by Google Ireland Limited. Dynamic Links are tracked within Firebase or Google Analytics for Firebase, which informs the Owner about the details of the User journey to and within this Application.

Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.

Firebase Invites (Google Ireland Limited) Firebase Invites is a social feature provided by Google Ireland Limited that enables Users to share this Application. The sharing may contain referral codes, or content from within this Application and may be done via email or SMS. Sharing is tracked with Google Analytics for Firebase, which informs the Owner that the User has opened or installed this Application via invite.

Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.

Further information about Personal Data

Push notifications This Application may send push notifications to the User to achieve the purposes outlined in this privacy policy. Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device. Users must be aware that disabling push notifications may negatively affect the utility of this Application.

DELETION AND RETENTION

We will retain your personal data for as long as necessary to fulfill the purpose for which it was collected and for a reasonable period thereafter to comply with audit, contractual, or legal requirements, or where we have a legitimate business interest in doing so. We will also retain and use your information as needed to comply with legal obligations, resolve disputes, and enforce our agreements.

Deletion: We securely delete your data by shredding physical documents and irreversibly deleting electronic records. Inactive accounts may be terminated after one year, with all associated data destroyed.

Retention: Player Gift will retain personal data for as long as required by law, as long as you continue to use the services, or as long as necessary to fulfill the original purposes for which it was collected. After account deletion, we may retain your data for an additional twelve (12) months for administrative purposes. We may also anonymize data and reserve the right to use anonymized information for legitimate business purposes, such as compliance with applicable tax laws.

Request to Delete: You may request to delete your account by contacting us using the communication details provided in this Privacy Policy. Please note that by deleting your account, any loyalty points or rewards that have not been redeemed will also be deleted. If we choose to retain anonymized information, we will do so in a way that ensures it remains de-identified, without attempting to re-identify you. To delete personal data held by third-party partners or game providers, you will need to contact them directly according to their privacy policies.

DISCLOSURE OF YOUR PERSONAL DATA

While your personal data is fundamental to the operations of Player Gift, there are instances where controlled sharing of your information occurs. Below are the key scenarios where data may be shared. For a more detailed understanding of how we share and process your data, and who we share it with, please refer to the “Use of Personal Data” section of this Privacy Policy.

Corporate Affiliates and Transaction Parties:

When necessary, personal data may be shared with subsidiaries, affiliates, or third parties involved in corporate transactions, such as mergers, acquisitions, or asset sales, in compliance with legal agreements and applicable data protection regulations.

Legal and Security Considerations:

Player Gift may disclose personal data to protect the legal rights of the company, its users, or third parties, to prevent fraud or manage risks, or to comply with legal obligations. Any such disclosure is made responsibly and within the limits of the law.

Service Providers:

We work with a trusted network of service providers to perform essential tasks such as customer support, technical infrastructure, reward management, system security, and marketing. These service providers are contractually obligated to protect your personal data in accordance with the same data protection standards we adhere to. In some cases, they may combine the data we share with them with other data they independently collect about you.

Advertising and Marketing:

In collaboration with advertising platforms and networks, we may share personal data such as device IDs and IP addresses to display targeted ads, manage advertising analytics, and optimize our advertising presence on other platforms. This data sharing helps ensure that ads align with your preferences and limit the number of times you see the same ad.

Marketing Vendors:

We work with marketing vendors to run campaigns, conduct surveys, organize user events, and test new features, all while respecting your rights under applicable laws. If you choose to participate in any of these activities, your personal data may be disclosed to these vendors, always in accordance with legal requirements.

Analytics Insights:

We collaborate with analytics providers to gain insights into user behavior, trends, and preferences. These insights help us improve our services, optimize sales, and develop new features, while adhering to data protection laws.

Game Partners:

To enhance your experience, provide personalized content, assist with marketing, and track game installs, we may share data with partnering game developers and their mobile measurement partners. This data sharing is subject to the privacy policies of our Game Partners. When you access games through Player Gift, your data may be shared with the respective Game Partner.

DATA SECURITY

The security of your personal data is a top priority for Player Gift. We use commercially reasonable efforts to store and maintain your personal data in a secure environment. Our security measures include technical, contractual, administrative, and physical safeguards designed to protect your data from unauthorized access, alteration, or destruction. We have implemented internal procedures to ensure that only authorized personnel, who are required to perform their duties, have access to your personal data in line with the purposes communicated in this Privacy Policy.

Your Responsibility:

You also play an important role in protecting your personal data. Please ensure that you never share your login credentials and always maintain the security of the devices you use to access our services. You are responsible for safeguarding the security of your personal computing device when using Player Gift.

Limitations of Liability:

We take extensive precautions to protect your data, but we cannot be held liable for data disclosures caused by transmission errors, unauthorized access by third parties, or events beyond our reasonable control. While we employ robust security measures, we cannot guarantee that your personal data will not be compromised by malicious individuals or systems that circumvent our safeguards.

Notification of Breaches:

In the event of a security breach that could expose your personal data in an unauthorized manner, we will notify you promptly through email or other communication channels, if feasible. We may also post a notice on our platform to keep you informed.

Security Measures in Place:

Access Control: Our database servers are accessible only through trusted network locations. Only authorized personnel can access personal data, and this access is strictly controlled by non-disclosure and confidentiality agreements, even after employees leave the company.

Password Protection: All mobile devices and external storage (e.g., laptops, USB sticks, portable hard drives) are password protected.

Firewall Protection: Our web servers and database servers are protected by firewalls to prevent unauthorized access.

Data Storage: All data stored on the Player Gift platform is secured with encryption wherever possible, and all data transmissions are protected with the highest level of encryption supported by the platform.

Session Control: We prevent multiple users from logging into the platform using the same browser to safeguard individual sessions.

AWS S3 & Microsoft Azure Storage: We securely store data on AWS S3 and Microsoft Azure with private access permissions, ensuring that only authorized personnel can access sensitive information.

Database Security: We use PostgreSQL databases with row-level security policies in place, ensuring that only designated individuals or invitees can view specific data.

Rate Limiting: We enforce rate limits for requests from the same IP address to mitigate security risks.

Penetration Testing: We regularly collaborate with external security service providers to conduct penetration tests and strengthen our protection against unauthorized access.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

As a user of Player Gift, you have certain rights that empower you to make informed decisions about your personal data. These rights include:

Opting Out of Marketing Communications:

You have the right to opt-out of receiving marketing messages from Player Gift. If you choose to opt-out, you will no longer receive promotional communications, though you may still receive essential service-related notifications.

Withdrawing Consent:

You can withdraw your consent for the collection and processing of your personal data at any time. Please note that this is applicable only to data processed based on your consent (e.g., optional data like gender). The withdrawal of consent will not affect the legality of any processing carried out before the withdrawal, nor will it affect processing based on lawful grounds other than consent.

Request Information on the Processing of Your Data:

You have the right to request information about whether any specific data is being processed. You may also request further details on the nature and purposes of the processing of your personal data as described in this Privacy Policy.

Deletion of Your Data:

You have the right to request the deletion of your personal data or the closure of your account. However, please be aware that Player Gift may be required by law to retain some of your data, meaning we may not be able to fully comply with your request in certain cases.

Correction of Your Data:

If you believe any personal data we have collected is incorrect, incomplete, or inaccurate, you have the right to request that we correct this information.

Objecting to Data Processing:

You have the right to object to the processing of your personal data for specific purposes, or to challenge decisions based on automated processing.

If you have any questions or requests regarding your rights under this policy, please contact us using the details provided in this Privacy Policy. We are here to address your concerns about data privacy and will handle them in accordance with applicable data protection laws.

SUPPLEMENTAL PROVISIONS FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA AND THE UNITED KINGDOM (EEA & UK)

Data Transfer Outside the EU

Player Gift uses servers located within the European Union, specifically in Germany, to store personal data. This ensures that your data is kept within the EU. However, there may be instances where we need to transfer personal data to third countries (i.e., countries outside the EU). In such cases, these transfers will only occur if a specific legal basis permits it. Below are the legal bases on which such transfers may occur:

Adequacy Decision:

Personal data may be transferred to a third country that has been declared by the European Commission as offering an adequate level of protection. In such cases, data transfers are treated similarly to those within the EU, without the need for additional safeguards. This means that transferring data to an ‘adequate’ third country ensures a comparable level of protection to data transfers within the EU.

Standard Contractual Clauses:

If the transfer is based on this legal basis, Player Gift will transfer personal data to third countries using the “standard contractual clauses” provided by the European Commission. This ensures that data recipients in third countries are contractually obliged to process personal data in compliance with EU data protection laws. For more information on this mechanism, users can contact us using the details provided in this Privacy Policy.

Code of Conduct or Certification Mechanism:

In some cases, data transfers may occur when the recipient in a third country adheres to a code of conduct or certification mechanism. These mechanisms are combined with enforceable commitments by the recipient to provide the necessary safeguards to protect the transferred data, in line with European Commission standards.

Explicit Consent:

Data may be transferred to third countries based on your explicit consent after being informed about the risks associated with the transfer. By accepting this Privacy Policy, you acknowledge that you have been informed of these risks and give your explicit consent for the data transfer.

If you have any inquiries regarding which legal basis applies to specific data transfers, feel free to contact us using the information provided in this Privacy Policy.

Your Rights under the GDPR

Player Gift is committed to respecting the confidentiality of your personal data and ensuring that you can exercise your rights under the General Data Protection Regulation (GDPR), the Swiss Federal Act on Data Protection, and UK data protection laws. We process your data to fulfill contractual obligations (e.g., creating your account), based on legitimate interests (e.g., fraud prevention), or to comply with legal obligations (e.g., tax requirements). If you are located within the EEA, Switzerland, or the UK, you have the following rights:

Right to Access: You have the right to access, update, or delete the personal information we hold about you. Where possible, you can manage your personal data directly through your account settings. If this is not possible, please contact us for assistance. This also includes the right to request a copy of the personal data we hold about you.

Right to Correction: You have the right to request the correction of any incomplete or inaccurate information we hold about you.

Right to Object: You have the right to object to our processing of your personal data when it is based on legitimate interests, especially if there is something about your particular situation that makes you want to object. You also have the right to object to the processing of your personal data for direct marketing purposes.

Right to Erasure: You can request that we delete or remove your personal data when there is no valid reason for us to continue processing it.

Right to Data Portability: You have the right to request the transfer of your personal data to a third party in a structured, commonly used, and machine-readable format. This applies to data processed by automated means or with your consent. We will provide your data to you, or directly to a third-party controller you have chosen, in this format.

Right to Withdraw Consent: If you have given consent for the processing of your personal data, you have the right to withdraw that consent at any time. Please note that withdrawing your consent may prevent us from providing you with access to certain functionalities of the service.

Exercising Your GDPR Data Protection Rights

You can exercise your rights of access, rectification, erasure, or objection by contacting us through the details provided in this Privacy Policy. To ensure your identity, we may request additional verification before processing your request. We will make every effort to respond to your request as quickly as possible.

You also have the right to lodge a complaint with your local Data Protection Authority regarding the collection and use of your personal data. If you are located within the EEA, please contact your local authority for more information.

SUPPLEMENTAL PROVISIONS FOR RESIDENTS OF THE STATE OF CALIFORNIA, USA

Under the California Consumer Privacy Act (CCPA), residents of California have enhanced rights and control over their personal data. Below is a summary of these rights and what they mean for you:

Right to Know and Delete:

In accordance with the CCPA, we are transparent about how we share your personal data with third parties. As a California resident, you have the right to know which specific personal data we have shared with third parties, who those parties are, and the purpose of sharing.

You may request, up to twice a year and free of charge, details about your personal information that has been disclosed or sold, including the categories of data shared.

Additionally, you may request information on how your personal data has been processed, provided in a clear and easily understandable format.

You have the right to ask us to delete your personal data from our platform. Depending on your preference, we will either delete your information entirely or add you to a “do not contact” list for a specific period.

Requests Timeline:

We will respond to your requests to know or delete your personal data within 45 days. If additional time is required, we will inform you of the extension and the reason for the delay.

Authorized Agents:

You may designate an authorized agent, registered with the California Secretary of State, to submit disclosure or deletion requests on your behalf under the CCPA. We will process such requests if you provide written authorization for the agent, and we are able to verify both your identity and the agent’s proof of authorization.

Collection, Usage, and Disclosure Chart:

The chart below details the categories of personal information we may collect, the sources of that information, and the purposes for which it is collected, used, and disclosed. These categories are in line with the definitions provided in CCPA Section 1798.140(o).

CATEGORY	DESCRIPTION	SOURCES	BUSINESS USE	COMMERCIAL USE
A	Identifiers – name, email, postal and IP address, unique personal identifier, online identifier, Internet Protocol address, account name	User provided on registration and upon redeeming points using the online shop, customer service inquiries and claim forms; related and 3rd party sources to verify user-supplied information, selfie in video format	Operational purposes including customer service; fraud & security incidence detection; website improvement; award prize winners	None
B	Protected classification characteristics under California or federal law	Age and Gender	Recommend suitable Games	None
C	Internet or similar network activity -browsing and search history, information on a consumer’s interaction with a website, application, or advertisement	To determine the performance of media content and analytics purposes	User provided on registration and upon redeeming points using online shop, customer service inquiries and claim forms; related and 3rd party sources to verify user-supplied information, selfie in video format	None
D	Geolocation data	Country Identified using IP Address	Recommend Games for Country	None
E	Inferences are drawn from other personal information	Profile reflecting a person’s preferences	Recommend Games based on preference	None

Data Use and Disclosure:

While we have collected and disclosed personal information for business purposes in the last year, we do not sell your personal information. However, some sharing of personal data may be considered a “sale” under California law. Please note that we do not knowingly collect or share personal data from users under 16 years old.

Data Retention:

We retain personal data as long as necessary to provide our services, comply with legal obligations, or meet the intended purpose of data collection. Inactive accounts with no usage for one year may be automatically terminated, and the data will be deleted as outlined in our Terms of Use.

California Incentive and Your Rights:

Our Rewards Program may be considered a financial incentive under California law. The program provides benefits that are balanced against the value we receive from user data insights and analytics. Participation is voluntary, and you can opt out at any time by following the procedures outlined in our Terms of Use.

Your Data Privacy Rights at Player Gift:

As a California resident, the CCPA grants you the following rights regarding your personal data:

Right to Know: You have the right to know what personal data we collect, the reasons for its collection, and to whom it is shared.

Right to Delete: You may request the deletion of your personal data, subject to certain legal exceptions.

Right to Correct: You can request the correction of any inaccuracies in your personal data.

Right to Opt-Out: You have the right to opt out of data sales, sharing, or cross-context behavioral advertising.

Right to Limit Use/Disclosure: You can limit the use and disclosure of your sensitive personal information for specific purposes.

Right to Non-Discrimination: You will not be discriminated against for exercising your rights under the CCPA.

To opt out of data sales, sharing, or limit the use of sensitive information, you can email us at [email protected]. We also honor opt-out requests via privacy signals, such as the Global Privacy Control (GPC).

Submit your requests to know, delete, or correct data by following the instructions in this Privacy Policy. Include “Personal Information Privacy Request” in the subject line and provide your name, address, email, and service used. If requesting deletion, indicate whether you want data removed or added to a “do not contact” list. We will respond within 45 days, with an option for a time extension if necessary.

California residents may also appoint authorized agents to submit CCPA requests on their behalf. We will verify the identity and authorization before processing such requests.

Non-Discrimination Assurance:

Player Gift will not discriminate against you for exercising your rights under the CCPA.

Do Not Track Signals:

The California Online Privacy Protection Act (CalOPPA) requires us to inform you that Player Gift, like many other websites, does not recognize or respond to “Do Not Track” (DNT) signals set by browsers.

SUPPLEMENTAL PROVISIONS FOR RESIDENTS OF THE STATES OF COLORADO, CONNECTICUT, AND VIRGINIA IN USA

If you are a resident of Colorado, Connecticut, or Virginia, this section supplements the main Privacy Policy. For details regarding data collection, usage, sharing, and third-party disclosures, please refer to the sections titled “Use of Personal Data,” “Disclosure of Your Personal Data,” and “Types of Data Collected.” Please note that sharing data for marketing or advertising purposes may be considered “sales” or “targeted advertising” under state law.

Based on your location, you may have certain rights concerning your personal data, which include:

Access:

You have the right to request confirmation and access to the personal data we have collected about you.

Data Portability:

You may request a copy of your data in a readily usable format, allowing you to transfer it to another service provider.

Correction:

You have the right to request correction of any inaccuracies in your personal data.

Deletion:

You may request that we delete your personal data from our systems.

Opt Out of Sales/Targeted Advertising:

You have the right to opt out of the processing of your data for the purpose of sales or targeted advertising.

Opt Out of Profiling:

You have the right to opt out of the processing of your data for profiling purposes, especially if such profiling has a legal or significant impact on your rights.

To exercise any of these rights, please follow the methods outlined in this Privacy Policy. Be sure to include “Personal Information Privacy Request” in the subject line and specify the service you are inquiring about. Additionally, provide your name, address, and email. If you are requesting deletion, please specify whether you want your data completely removed or placed on a “do not contact” list.

You may appeal any refusal to comply with your request as outlined in this Privacy Policy. Additionally, residents of these states may appoint an authorized agent to submit requests on their behalf. In such cases, we will follow the outlined verification process to confirm both your identity and the agent’s authority.

SUPPLEMENTAL PROVISIONS FOR RESIDENTS OF KOREA

If you are accessing our services from Korea, please be aware that we may need to transfer your personal information to locations outside of Korea. In such cases, we will ensure that the transfer complies with the privacy requirements outlined in the Korean Personal Information Protection Act (PIPA) and the Network Act. This includes using a secure communication network to safeguard your personal data during the transfer.

Your personal information will be retained and used only for the purposes for which it was collected. Once those purposes are fulfilled, your data will be securely deleted or anonymized, in compliance with Korean data protection laws.

COMPANY NAME	COUNTRY	CONTACT OF EMPLOYEE OR DEPARTMENT RESPONSIBLE FOR MANAGING PERSONAL INFORMATION AND LINK TO PRIVACY POLICY	DATE AND TIME OF TRANSFER	PURPOSE OF TRANSFER	PERSONAL INFORMATION ITEMS TO BE TRANSFERRED
Amazon Web Services, Inc.	U.S.A	Amazon.Com	Upon accessing and using Player Gift services	Hosting and data security and management services for the personal data that we store. Also used for analytics to monitor and track the reliability of the Services	CONTACT OF EMPLOYEE OR DEPARTMENT RESPONSIBLE FOR MANAGING PERSONAL INFORMATION AND LINK TO THE PRIVACY POLICY
Azure Cloud Services	U.S.A	Microsoft.Com	Upon accessing and using Player Gift services	Hosting and data security and management services for the personal data that we store. Also used for analytics to monitor and track the reliability of the Services	CONTACT OF EMPLOYEE OR DEPARTMENT RESPONSIBLE FOR MANAGING PERSONAL INFORMATION AND LINK TO THE PRIVACY POLICY
Adjust	U.S.A	Email Adjust.Com	Upon accessing and using Player Gift services	Advertising, rewards, and fraud detection	Mobile application Google Ad ID, IP address, age, device model, OS version
Facebook	U.S.A	Facebook.Com	Upon accessing and using Player Gift services	Used for business analytics to better understand how users interact with Player Gift Services	Google Advertising ID
Google	U.S.A	Google.Com	Upon accessing and using Player Gift services	Used for business analytics to better understand how users interact with Player Gift Services	Google Advertising ID
AdGate	Canada	Adgatemedia.com	Upon accessing and using Player Gift services	Advertising, and rewards	IP address, user agent
Adjoe	Germany	Adjoe.zone	Upon accessing and using Player Gift services	Playtime (adjoe) is a third feature that is integrated with our app. Playtime allows users to earn in-app currency by playing third-party games and collects devices’ application usage from users. The processing of the data is necessary to recommend, via system messages, the installation of the app available in Playtime that matches users’ interests and calculates the bonuses acquired as a result of users’ use of the corresponding apps. For more information, please refer to Playtime (adjoe) Data Privacy.	IP address, user agent, usage access data
Player Gift Analytics	U.S.A	Player Gift – Privacy Policy	Upon accessing and using Player Gift services	Player Gift Analytics is a feature that is integrated with our app. Player Gift Analytics allows users to earn in-app currency by playing games and collects devices’ application usage from users. The processing of the data is necessary for fraud prevention, users’ security & privacy. It is also required to recommend, via system messages, the installation of the app available in the app that matches users’ interests and calculates the bonuses acquired as a result of users’ use of the corresponding apps.	Approximate Location, Device ID, Device Model, Operating System, Usage Access Data, Mail, Phone Number

SUPPLEMENTAL PROVISIONS FOR RESIDENTS OF BRAZIL

This section applies to all users in Brazil and is governed by the “Lei Geral de Proteção de Dados” (LGPD). It supersedes any conflicting information in the general privacy policy. We use the term “personal information” as defined by the LGPD.

Grounds for Processing Personal Information

We process your personal information only if there is a legal basis under the LGPD, such as your consent. For more details on the specific legal basis, you can contact us using the information provided in this Privacy Policy.

Categories of Personal Information Processed

Refer to the “Types of Data Collected” section of this Privacy Policy to review the categories of personal information that we process.

Disclosure of Your Personal Information

Refer to the “Disclosure of Your Personal Data” and “Use of Personal Data” sections of this Privacy Policy to see who your personal information is shared with and for what purposes.

Purpose of Processing Personal Information

Refer to the “Use of Personal Data” section of this Privacy Policy to understand the specific purposes for processing your personal information.

Your Data Privacy Rights

Under the LGPD, you have the following rights concerning your personal information:

Obtain confirmation on whether your personal information is being processed.

Access your personal information.

Request correction of incomplete, inaccurate, or outdated personal information.

Request the anonymization, blocking, or deletion of personal information that is unnecessary, excessive, or not processed in compliance with the LGPD.

Obtain information about the option of providing or denying consent and its consequences.

Learn about third parties with whom we share your personal information.

Request the portability of your personal information to another service or product provider, safeguarding our commercial and industrial secrets.

Request deletion of personal information processed based on your consent, except in cases where exceptions in Article 16 of the LGPD apply.

Revoke your consent at any time.

Lodge a complaint with the ANPD (National Data Protection Authority) or consumer protection bodies.

Oppose processing activities that are not compliant with the law.

Request clear information on the criteria and procedures for automated decisions.

Request a review of decisions made solely based on automated processing, particularly when such decisions affect your interests, including personal, professional, consumer, or credit profiles or other personality aspects.

You will not be discriminated against or penalized for exercising your rights under the LGPD.

How to File a Request

You or your legal representative can file a request to exercise your rights at no cost by contacting us using the details provided in this Privacy Policy. We will strive to respond promptly, and if we cannot comply immediately, we will explain the reasons. If we do not process your personal information, we will refer you to the appropriate party, if possible.

For access or confirmation requests, please specify if you prefer to receive your personal information electronically or in print, and if you require an immediate simplified response or a complete disclosure. For complete disclosures, we will respond within 15 days, providing information about the origin of your data, records, processing criteria, and purposes, while protecting our commercial and industrial secrets.

For requests involving rectification, deletion, anonymization, or blocking, we will notify third parties with whom we have shared your data, except where it is impossible or would involve disproportionate effort.

Transfer of Personal Information Outside of Brazil

We may transfer your personal information outside of Brazil in accordance with the LGPD. For more information regarding international transfers, please contact us using the details provided in this Privacy Policy.

SUPPLEMENTAL PROVISIONS FOR RESIDENTS OF TÜRKİYE; LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER KVKK

If you are a resident of Türkiye, the following provisions apply to the processing of your personal data under the Law on the Protection of Personal Data No. 6698 (KVKK).

What Kind of Personal Information Do We Collect?

We collect the following types of personal data:

Contact Information: This may include your email address, first name, and last name (if your username contains your name).

User Picture or Avatar: If it contains personally identifiable information.

Correspondence Details: Any information you provide to us in your correspondence.

Technical Information: This includes your Internet Protocol (IP) address used to connect your device to the internet, login information, browser type and version, screen resolution, flash version, time zone setting, browser plug-in types and versions, operating system, platform, traffic data, cookies data, web logs, and other communication data. Additionally, it includes details of the resources you access and session records collected when you use the platform.

Other Information: Any other personal data you voluntarily provide to us.

For more details, please refer to the sections in this Privacy Policy titled “Types of Data Collected Directly By Player Gift,” “Types of Data Collected from Third-Party Social Networks,” and “Service Providers Processing Personal Data on Our Behalf.”

What Lawful Reasons Do We Have to Process Personal Data?

We collect and process your personal data based on one or more of the following lawful reasons:

Contractual Obligations:

We may process your personal data to fulfill our contractual obligations to you or your employer, particularly in relation to providing the services you’ve requested.

Consent:

We may rely on your freely given consent at the time you provide your personal data to us. For example, when you sign up for certain services or features on the platform.

Legitimate Interests:

We may process your personal data based on our legitimate interests, provided that we have assessed that the processing is fair, reasonable, and balanced. These legitimate interests may include improving our services, enhancing user experience, ensuring platform security, and preventing fraud.

For further information on the processing of personal data, please contact us using the details provided in this Privacy Policy.