Your privacy and trust are important to Play Spirit.
UPDATED 17 JAN 2022
Please read this Policy carefully and contact us if you have any questions about our privacy practices or your personal information choices. By ticking the “agree” box after your read this Policy, you expressly consent to the information handling practices described in this Policy.
It is important that you check back regularly for updates to this Policy. If we make changes we consider to be important, we will let you know by placing a notice on the relevant Services and/or contact you using other methods such as email.
The information we collect
You may provide to Play Spirit what is generally called “Personal Information”, when you register for a Play Spirit Services, or upload, purchase, view or download certain content or products from the Services, enter contests or sweepstakes, or otherwise use the features and functionality of the Services. “Personal information” means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
Illustratively, we may collect different kinds of Personal Information about you as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Automatically Collected Information:
When you access the Services or open one of our HTML emails, we may automatically record certain information from your system by using cookies and other types of tracking technologies. This “automatically collected” information may include Internet Protocol address (" IP Address "), a unique user ID, device type, device identifiers, browser types and language, referring and exit pages, platform type, version of software installed, system type, the content and pages that you access on the Services, the number of clicks, the amount of time spent on pages, the dates and times that you visit the Services, and other similar information. Depending on the law of your country of residence, your IP address may legally be considered as personal information.
Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you leave cookies active, because they enable you to take advantage the most attractive features of the Services.
Information from Other Sources:
We may obtain information, including personal information, from third parties and sources other than the Services, such as advertisers or social media networks for which you have approved our access to information (e.g., information from your Facebook account provided by the Facebook APIs). When you access the Services through social media networks or when you connect a Services to social media networks, you are authorizing to collect, store and use such information and content in accordance with this Policy. We may also obtain information from third parties such as social entertainment platforms regarding your use of such Services, including about your use of the content you choose to broadcast through the Services. If we combine or associate information from other sources with personal information that we collect through the Services, we will treat the combined information as personal information in accordance with this Policy.
We collect, use, disclose, transfer, and store personal information when needed to provide our Services and for our operational and business purposes as described in this Policy. We want to be clear about our privacy practices so that you can make informed choices about the use of your information, and we encourage you to contact us at any time with questions or concerns.
How we use your information
We will use your information only for these Service- and business-related purposes.
Account setup and administration:
We use personal information such as your name, email address, phone number, and information about your device to set up and administer your account, provide technical and customer support and training, verify your identity, and send important account, subscription, and Service information.
We use personal information to deliver and suggest tailored content such as news, research, reports, and business information and to personalize your experience with our Services. Some of our Services will ask you to share your precise geolocation so we can customize your experience and increase the accuracy of the Service. If you agree to share your precise geolocation with us, you will be able to turn it off at any time by going to the privacy settings on your mobile device or online.
Marketing and events:
We use personal information to deliver marketing and event communications to you across various platforms, such as email, telephone, text messaging, direct mail, and online. If we send you a marketing email, it will include instructions on how to opt out of receiving these emails in the future. We also maintain email preference centers for you to manage your information and marketing preferences. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.
We use your information to allow you to comment on content, and participate in any events, promotions, activities, focus groups, research studies, contests, promotions, polls, surveys or any productions and to communicate with you regarding your attendance thereto.
Research and development:
We use personal information for internal research and development purposes and to improve and test the features and functions of our Services.
Chat rooms, messaging, and community and event forums:
We may be required to use and retain personal information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud. We may also use personal information to meet our internal and external audit requirements, information security purposes, and as we otherwise believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety, or property, or those of other persons.
We may use Automatically Collected information and Cookies information to maintain and improve our Services, including to do the following things: (a) automatically update the applications on your system; (b) remember your information so that you will not have to re-enter it during your visit or the next time you access our Services; (c) provide customized third-party advertisements, content and information, unless it will include instructions on how to opt out of receiving these advertisements, content and information in the future; (d) monitor the effectiveness of third-party marketing campaigns; (e) monitor aggregate site usage metrics such as total number of visitors and pages accessed; and (f) track your entries, submissions, and status in any promotions or other activities.
When we share your information
We do not share your personal information with other organizations for their own marketing or promotional uses without your prior express consent. Please be aware, however, that any personal information that you voluntarily choose to display on any publicly available portion of our Services, such as when you publish content, comments or profile information, becomes publicly available and may be collected and used by others.
We may disclose Automatically Collected information and other aggregates non-personal information with interested third parties to assist such parties in understanding the usage and demographic patterns for certain programs, content, Services, advertisements, promotions, or other functionality of our Services.
Play Spirit may make both personal and non-personal information available to subsidiaries and affiliated companies that are under common ownership or controlled within the Play Spirit group, but Play Spirit Limited as the controller will guarantee the subsidiaries and affiliates to assume the obligations as same as Play Spirit assumes as information receiver in this Policy.
We may disclose both personal and non-personal information to Services providers working on our behalf to: provide web site hosting, maintenance, and security Services; fulfil orders; conduct data analysis and create reports; offer certain functionality; and assist Play Spirit in improving the Services and creating new Services features. We require that these parties process such information in compliance with this Policy, we authorize them to use the information only for the purposes for which it is provided to them, and we require these parties to use reasonable confidentiality measures.
We may disclose your information if we believe in good faith that such disclosure is necessary to comply with the applicable laws around the world (for example, in the country of your residence); or respond to a court order, judicial or other government subpoena, or warrant in the manner legally required by the requesting entity.
We also reserve the right to disclose your information that we believe, in good faith and after making reasonable enquiries, is appropriate or necessary to take precautions against liability to Play Spirit; protect Play Spirit from fraudulent, abusive, or unlawful uses; to investigate and defend ourselves against third-party claims or allegations to protect the security or integrity of our Services; or to protect the rights, property, or personal safety of us, our users, or others. We will notify you of these disclosures if we reasonably think we can do so legally and without harming the purpose of the disclosure.
You may, of course, decline to share your personal information with us, in which case we will not be able to provide to you some of the features and functionality found on our Services. If you would like to access, review, correct, update, suppress, or otherwise limit our use of your personal information you have previously provided directly to us, you may contact us as outlined in the last section of this Policy titled "How to contact us "; or using the mechanism provided below. In your request, please include your email address, name, address, and telephone number and specify clearly what information you would like to access, change, update, or suppress. We will try to comply with your request as soon as reasonably practicable and any information you give us will be protected by this Policy.
Where we store and process personal information
Play Spirit is a multinational corporation, and your personal information may be stored and processed outside of your home country. We take steps to ensure that the information we collect is processed according to this Policy and the requirements of applicable law wherever the data is located.
Play Spirit has networks, databases, servers, systems, support, and help desks located throughout our offices around the world. We collaborate with third parties such as cloud hosting services, suppliers, and technology support located around the world to serve the needs of our business, workforce, and customers. We take appropriate steps to ensure that personal information is processed, secured, and transferred according to applicable law. In some cases, we may need to disclose or transfer your personal information within Play Spirit or to third parties in areas outside of your home country. The areas in which these recipients are located will vary from time to time, but may include the United States, Europe, Canada, Asia, Australia, India, and other countries where Play Spirit has a presence or uses contractors. We ensure a similar degree of protection in this Policy is afforded when disclose or transfer your personal information in areas outside of your home country.
Our commitment to data protection
Play Spirit uses commercially reasonable physical, managerial, and technical measures designed to protect the integrity and security of your personal information (for example, making relevant policies and procedures to deal with accident loss and unauthorized access, training our employees and contractors to control risk, limiting access to your personal data to those employees, agents, contractors and other third parties who have a business need to know). However, no security precautions or systems can be completely secure. We cannot therefore ensure or warrant the security of any information you transmit to us, and you do so at your own risk. We cannot guarantee that such information may not be accidentally accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
How long we keep personal information
We retain personal information for as long as we reasonably require it for legal or business purposes. In determining data retention periods, Play Spirit takes into consideration local laws, contractual obligations, the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data, the purposes for which we process personal data and the expectations and requirements of our customers. When we no longer need personal information, we securely delete or destroy it.
Your right to access and control your personal information
Under certain circumstances, you have the following rights in relation to your personal data:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, you can use the “Contact Us” option within the relevant Service or via email to contact us at firstname.lastname@example.org
We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your personal information. However, we may require you to provide sufficient proof to verify your identity before your modification request. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. You may also have the right to request deletion of your personal information; however, this is not always possible due to legal requirements and other obligations and factors.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
Connecting via social networks
You may choose to use your own social networking logins from, for example, Facebook, Twitter, Wechat or Paypal, to log into some of our Services. If you choose to connect using a social networking or similar service, we may receive and store authentication information from that service to enable you to log in and other information that you may choose to share when you connect with these services. These services may collect information such as the web pages you visited and IP addresses, and may set cookies to enable features to function properly. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy policies applicable to the third-party services you connect to, use, or access. If you do not want your personal information shared with your social media account provider or other users of the social media service, please do not connect your social media account with your account for the Services and do not participate in social sharing on the Services.
Friends and Other Players
Our Services allow you to interact with your friends, and if you use a social network account to register a game account with us, your friends may be able to see your name, profile picture and game activity. Other players may be able to view certain public information associated with your social network profile.
When you purchase virtual currency or items, or get cash prize in our Services, we and our business partner responsible for processing payments will collect the billing information needed to process your charges or drawing. This may include financial information like your Paypal accounts, credit card accounts, or billing address.
Our policy towards children
Our Services usually have minimum age requirement of users and are not directed to children, and we do not knowingly collect data relating to children. If you become aware that your child has provided us with Personal Information without your consent, please email to email@example.com
In the Event of Merger or Sale
In the event that Play Spirit or some or all assets related to the Services are acquired by or merged with a third-party entity, we reserve the right, in any of these circumstances, to transfer or assign the information that we have collected from you as part of that merger, acquisition, sale, or other change of control.
Further Privacy Notice for EU Residents (“GDPR Notice”)
Scope of GDPR Notice
This GDPR Notice provides additional information about how we collect, use, disclose and otherwise process Personal Information of individual residents of the European Union, United Kingdom, Lichtenstein, Norway, or Iceland (for the purpose of this GDPR Notice, “EU”), either online or offline, within the scope of the GDPR and applies solely to individual residents of the EU.
Lawful Basis for Processing Personal Information
The lawful basis for processing your information includes: i) performance of a contract with you; ii) necessary to comply with a legal obligation; and iii) necessary for our legitimate interests (including but not limited to recover debts due to us; keep our records updated and to study how customers use our products/services; study how customers use our products/services, to develop them and grow our business; run our business, provide administration and IT services, network security, prevent fraud; define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
Legal basis for each processing purpose provided in Section 2 of this Policy are:
Account setup and administration: the legal basis for this processing is Art. 6(1)(b) GDPR.
Personalization: the legal basis for this processing is your consent according to Art. 6(1)(a) GDPR.
Marketing and events: the legal basis for this processing is Art. 6(1)(f) GDPR.
Communication: the legal basis for this processing is Art. 6(1)(b) or (f) GDPR.
Payments: the legal basis for this processing is Art. 6(1)(b) GDPR.
Research and development: the legal basis for this processing is Art. 6(1)(f) GDPR.
Chat rooms, messaging, and community and event forums: the legal basis for this processing is Art. 6(1)(f) GDPR.
Legal obligations: the legal basis for this processing is Art. 6(1)(c) GDPR or Art. 6(1)(f) GDPR.
Cookies are small data files of information that a website or mobile application transfers to your hard drive or mobile device to store and sometimes track information about you. Although cookies do identify a user’s device, cookies do not personally identify users.
Types of cookies we may use:
Strictly necessary cookies: these are cookies that are required for the operation of a website and App, such as to enable you to log into secure areas.
Performance cookies: these types of cookies recognize and count the number of visitors to a website and users of an App and to see how users move around in each. This information is used to improve the way the website and App work.
Functionality cookies: these cookies recognize when you return to a website or App, enable personalized content and recognize and remember your preferences.
Targeting cookies: these cookies record your visit to a website or App, including the individual pages visited and the links followed.
Generally, the strictly necessary cookies and some performance and functionality cookies only last for the duration of your visit to a website or expire when you close an App; the functionality cookies and some targeting and performance cookies may last for a longer period of time.
Some of the cookies used by our website and App may be set by us, and some are set by third parties who are delivering services on our behalf. For example, we use Google Analytics to track what users do on the App so we can improve the design and functionality.
Most websites, mobile devices and apps automatically accept cookies but, if you prefer, you can change your browser, device or app settings to prevent that or to notify you each time a cookie is set. Please note however, that (as with other websites and apps) by blocking or deleting cookies used on our website or App you may not be able to take full advantage of our Services.
Access our Services through Facebook Connect
You may have the opportunity to connect to our Services through Facebook Connect when you register for Services or after you have registered for Services. If you connect to Services through Facebook Connect, we will collect, store, and use in accordance with this Policy any and all information you agreed that Facebook could provide to us through its API. This process links our Services to your Facebook profile and we may access, collect and store the following information, among other information, as allowed by you, Facebook’s API, and your Facebook privacy settings:
your Facebook name;
your profile picture;
your email address;
the names and pictures of your Facebook friends;
your interests and affinity networks;
other information you make publicly available via Facebook
Google Firebase Authentication
We may use Google Firebase Authentication to make your authentication easier and more convenient. This service provider has access to Personal Information required to perform its tasks. Google Firebase may not use them for other purposes. In addition, Google Firebase is required to treat the information in accordance with the applicable data protection laws.
Payment Method PayPal
If you choose to pay our Services via PayPal, the information you provide will be sent to PayPal for payment at sign-up. PayPal may not use them for other purposes. In addition, PayPal is required to treat the information in accordance with the applicable data protection laws.
We may use this technology to make our website more interesting for you and to optimize its functionality. The purpose of the processing is our legitimate interest in improving our Services. If you only wish to accept our own cookies, but not those of our service providers and partners, you can select the setting in your browser "Block third party cookies", or contact us via email at firstname.lastname@example.org
Amazon Web Services
Your Personal Information may be stored on our behalf on third-party infrastructure provider Amazon Web Services. Amazon may not use the data for other purposes. In addition, Amazon is obliged to treat the information in accordance with the relevant data protection laws.
We may use Adjust to analyze data provided by you. We may use this technology to make our Services more interesting for you and to provide better customized Services. Adjust may not use the data for other purposes. In addition, Adjust is obliged to treat the information in accordance with the relevant data protection laws.
The Facebook “Like” Button
We may integrate the Facebook "Like" button on our Services. Regardless of whether you are logged in to your Facebook account or not, the plugin establishes a direct connection between your browser and the Facebook server and sends Facebook the information that you have visited our website using your IP address. If you are logged into your Facebook account while visiting our website, you can link our content to your Facebook account by clicking the "Like" button.
We may include a Twitter plugin in our Services that allows you to link the content of our Services to your Twitter account. If you are logged into your Twitter account while using our Services, a link will be established. The exact content of the data transmitted to Twitter and how Twitter uses it is beyond our knowledge.
We may include an Instagram plugin in our Services that allows you to link the content of our Services to your Instagram account. The exact content of the data transmitted to Instagram in this way and how it is used by Instagram is beyond our knowledge.
Minors Under Age 16
We do not knowingly collect or solicit Personal Information from anyone in the EU under the age of 16. If you are under 16, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Information, please contact us at email@example.com.
Transfer Personal Information out of European Union
When we transfer Personal Information from the European Union to other countries in which applicable laws do not offer the same level of data privacy protection as in your home country, we take measures to provide an appropriate level of data privacy protection. In other words, your rights and protections remain with your data. For example, we use approved contractual clauses, multiparty data transfer agreements, intragroup agreements, and other measures designed to ensure that the recipients of your Personal Information protect it. If you would like to know more about our data transfer practices, please contact us at any time.
Further Privacy Notice for California Residents (“CCPA Notice”)
Scope of CCPA Notice
This CCPA Notice provides additional information about how we collect, use, disclose and otherwise process Personal Information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 ("CCPA") and applies solely to individual residents of the State of California.
Your CCPA Rights
Right to Access Specific Information and Date Portability Rights
If you are a California resident, you may submit, free of charge, but no more than twice in a 12-month period, a verifiable request for the following information:
The categories of Personal Information we collected about you;
The categories of sources for the Personal Information we collected about you;
Our business purpose for collecting that Personal Information;
The categories of third parties with whom we share that Personal Information;
The specific pieces of Personal Information we collected about you (also called a data portability request); and
If we disclosed your Personal Information for a business purpose, disclosures of which will be for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Right to Delete
If you are a California resident, you may submit a verifiable request for us to delete the Personal Information we have collected about you. We may retain Personal Information necessary to: (a) protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality, (c) necessary for us, or others, to exercise their free speech or other rights, (d) comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations.
Right to Opt-Out
California residents have the right to opt out of the sale of Personal Information, which is defined in a way that may include the transfer of data to third parties to personalize ads for you. If you opt out of the ‘sale’ of your information, we will not sell your information, including to our advertising partners, but you may continue to receive ads from our Services, which may not be as tailored to your interests.
You do not need to create an account with us to exercise your right to opt-out. However, we may ask you to provide additional Personal Information so that we can properly identify you in our dataset and to track compliance with your opt-out request. We will only use Personal Information provided in an opt-out request to review and comply with the request. If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems and authenticate you as authorized to receive the information.
Once you make an opt out request, you may change your mind and opt back in to Personal Information sales at any time by contacting us at firstname.lastname@example.org
Right to be Free from Discrimination
We may not discriminate against you because you have exercised your rights, including, for example, by denying you access to our online services or charging you different rates or prices for the same online services, unless that difference is reasonably related to the value provided by your data.
If you would like to designate an authorized agent to make a request on your behalf, please be sure the agent can (i) demonstrate you have provided written permission for the agent to submit the request on your behalf, and (ii) provide proof of his or her own identity. If the agent does not satisfy these requirements, we will deny the request.
Exercising Your CCPA Rights
To exercise your CCPA rights described above, please submit your request to us by either:
Mailing your request to Play Spirit Compliance Team, 7 Straits View, Marina One East Tower,
#05-01, Singapore 018936
Emailing us at email@example.com
A verifiable consumer request should provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative (e.g. first name, last name, account name, email address, state of residence, etc.); and should describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it (e.g. what kinds of CCPA rights you want to exercise, what kinds of Personal Information you are looking for, etc.).
If we need additional information to verify your identity and/or understand your request, we will contact you to request more information, which may include Personal Information about you or information about your past purchases or use of Play Spirit’s products or services. If we deny your request, even if only in part, we will explain the reason in our response.
We may offer incentives in exchange for the retention or sale of Personal Information. We offer nominal in-game currency and rewards to users when they choose to watch in-game video advertisements or connect their Facebook account. When a user chooses to receive the in-game currency and rewards, Play Spirit and its advertising partners use the information collected to serve the user with more relevant ads. Video and other relevant advertisements help support the game’s operation. A user can choose not to receive the in-game rewards and currency by electing not to watch in-game advertisements or by disconnecting their Facebook account through Facebook’s user settings.
How to contact us
If you have any concerns, questions or complaints regarding our Policy or privacy practice, please feel free to contact us at:
Attn: Play Spirit Compliance Team
Address: 7 Straits View, Marina One East Tower, #05-01, Singapore 018936