Privacy Notice
Last Updated: December 7, 2022
Effective Date: January 7, 2023
Previous versions of this notice can be found here.
This Privacy Notice provides important information about how Playco Global Inc. (“Playco”, “we”, “us”, or “our”) collects, uses, discloses, and otherwise processes your information through Playco’s websites, mobile applications, games, platforms, technology, software, and any other products, services, and features we make available to you (collectively, the Service”).
By using or interacting with us through the Service, you acknowledge that we can collect, use, disclose, or otherwise process your information as described in this Privacy Notice. Your access and activity of the Service is also subject to the Playco Terms of Service. Playco Global Inc. is the “data controller” of information collected through the Service. Our mailing address is 421 Castro Street, Mountain View, CA 94041.
PLEASE READ THIS PRIVACY NOTICE CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY NOTICE, PLEASE DO NOT USE THE SERVICE.
- Information we collect
- Use of information we collect
- Legal basis for processing
- Disclosure of your information
- Social networking platforms
- Children’s information
- Your rights and choices
- Data retention
- Security
- International data transfers
- Changes to this Privacy Notice
- Information for California residents
- Contacting us
This Privacy Notice does not apply to any third-party websites, products, or services that you may be able to access through the Service or that link to the Service. We suggest contacting those sites directly for information on their privacy practices.
1. Information we collect
When you interact with our Service, we may collect information about you or information about your use of the Service. The categories of information we collect are:
Information you provide to us, such as:
- Account information. We collect information about you when you connect a platform account, register for access, or log in to the Service. Depending on the specific products, services, or features you use or the games you play, this information may include your name, email address, phone number, username / handle, or online identifiers such as a player ID.
- Your connections. If you connect a platform account to the Service, we may receive information about your connections or contacts in that platform when authorized.
- Information related to engagement with our teams or communities. We collect information about you when you communicate with Playco team members (such as customer support staff or community managers); participate in community forums, events, or promotions; fill in forms or surveys; or otherwise share your experience with us. This may include contact information such as your name, email address, or social media handle, as well as any content you post, send, or otherwise share with us or in our community.
- Purchase information. If you make a purchase on the Service, we may receive related information (such as date and payment method). We use this information to facilitate and implement your purchase and to prevent fraud.
- Public blockchain information. Public blockchains provide transparency into digital assets and transactions that are stored, recorded, or take place on the blockchain. As such, the contents of blockchain asset wallets are public. We may collect or receive this information in connection with your use of the Service’s blockchain-related features, such as when you sign up for or participate in minting or using non-fungible tokens.
Information we collect automatically:
- Technical and network information, including device information and related identifiers. We also may collect certain information from and about the device, browser, or network you use to access the Service or view Playco content, including (for example) your IP address, device type, operating system and version, or other similar information.
- Cookies: We may collect information via cookies and similar technologies on your browser. These cookies help provide additional functionality to the Service, such as analyzing usage of the Service more accurately. Please refer to your web browser’s help section for information on how to receive notifications about cookies and how to manage cookies. Turning off cookies may make certain Service functionality unavailable (for example, retrieving your game progress). For more information about how we use cookies, please see the Playco Cookie Notice.
- Geolocation information. We use IP addresses to estimate your approximate location (e.g., city and country) to provide certain functionality on our Service or to measure analytics.
- Usage information. We collect information about how you use our Service, such as how you interact with our games. We use this information to operate and improve the Service.
Information we collect from other parties:
We may receive information from third-party websites, platforms, or services that we work with or that you use in conjunction with the Service. For example:
- When you log into our Service using a third-party platform account, we receive information associated with that platform account, such as your user ID, name, and email address.
- When you “like,” “follow,” or otherwise engage with us on Discord, Facebook, Twitter, or other social media sites and services, we may collect some information associated with your use of that social media service, such as your handle, name, and any comments or content you post relevant to us. We also collect your information if you sign up for one of our promotions or submit information directly to us through social media.
- If you connect your wallet to mint or purchase an NFT through the Service, the third party which manages your wallet may pass your wallet address to us upon your instructions.
Additional information may be provided in disclosures specific to those third parties or by the third parties themselves to you upon information collection.
2. Use of information we collect
We use the information we collect to provide, operate, improve, and develop the Service, including to:
- Facilitate your use of the Service
- Communicate with you in connection with your use of the Service
- Understand trends in usage of the Service (e.g., analytics, research)
- Enable you to participate in the Playco community with other users
- Improve the content, functionality, and user experience of the Service (such as by remembering your gameplay progress)
- Customize content and preferences on the Service
- Detect, diagnose, or fix technical issues
- Promote community safety and integrity
- Prevent fraud, criminal activities, or misuse of the Service and ensure the security and safety of the Service’s IT systems, architecture, and networks
- Comply with legal obligations and legal process
We may also aggregate, de-identify, and/or anonymize any information collected through the Service in such a way that we cannot reasonably link information to you or your device. We may use such aggregate, de-identified, or anonymous information for any purpose, including (for example) research and marketing.
3. Legal basis for processing
Under applicable data protection law (such as the General Data Protection Regulation), companies must have a legal basis to process your “personal data” (as defined by applicable law). Where those laws apply, our legal basis for processing the personal data described above will depend on the personal data and the specific context in which we collect it. This can include:
- Contract. Where we use your information because you’ve entered into an agreement with us, such as processing your information to comply with our Terms of Service, or to honor other agreements we have with you. For example, when you buy Virtual Items from us, we use some of your information to validate the purchase and deliver your items. Or, when you connect a platform account to us, we use information from that platform to power the feature, like enabling you to play a Playco game or participate in a Playco community on Discord.
- Legitimate Interest. Where your information is necessary for our legitimate interests or the legitimate interests of others. For example, we process your information to:
- Operate and improve our business and the Service
- Identify and fix any issues with the Service
- Provide security for the Service
- Learn more about how our customers use the Service
- Perform internal analytics concerning the Service
- Improve the Service and users’ experiences with the Service
- Provide you with information about new products or other information that you may find interesting
- Comply with legal requirements and defend our legal rights
- Prevent fraud
- To know the customer to whom the Service is provided
- Legal Obligation. We may be required to use your personal information to comply with the law, like when we need to respond to valid legal process.
- Consent. In some cases, we’ll ask for your consent to use certain information for specific purposes. In these cases, we’ll provide the ability to revoke your consent through our Service (or device permissions, if applicable).
4. Disclosure of your information
Where permissible and under applicable law, information about you may be shared with others.
- Vendors and service providers: We may contract with other companies to perform certain functions such as maintaining databases; securing, hosting, and operating the Service, such as by enabling gameplay; confirming or facilitating your transactions; and processing payments.
- Related companies: We may share your information with our subsidiaries and corporate affiliates for purposes consistent with this Privacy Notice.
- Business transfers: In the event we are involved in a corporate sale, merger, reorganization, dissolution, or similar event, or due diligence related to such event, your information may be part of the transferred assets.
- Legal requirements and harm prevention: We may disclose your information if required to do so by law or in the good faith belief that it is necessary to comply with a legal obligation, respond to valid legal process or government requests, protect and defend the rights or property of Playco or any other person or entity, act in urgent circumstances to protect the personal safety of users of the Service or the public, or protect against legal liability.
- Third-party integrations: The Service may offer you an opportunity to integrate with third-party partners or services to enjoy certain features, products, events, or promotions. For example, you may choose to use Social Networking Platforms (as described below). The information you provide in connection with such third-party integrations may be collected directly by, or shared with, the third party. These third parties will use your information in accordance with their own privacy policies.
- Blockchain information: Certain transactions that take place in our Service, such as minting or using NFTs, are confirmed and managed via the applicable blockchain (e.g., Ethereum). Additionally, if you import information stored on the blockchain to another product or service, that product or service will receive that information subject to its privacy policy.
- Your consent: Where applicable, we will share your information with third parties consistent with your consent.
5. Social networking platforms
Certain parts of the Service may allow you to enable or log in to the Service via various Social Networking Platforms, which can make your online experiences richer and more personalized. When you add a Social Networking Platform account to the Service or log into the Service using your Social Networking Platform account, we will collect relevant information necessary to enable the Service to access that Social Networking Platform and your data contained within that Social Networking Platform. As part of such integration, the Social Networking Platform will provide us with access to certain information that you have provided to the Social Networking Platform, and we will use, store, and disclose such information in accordance with this Privacy Notice. However, please remember that how Social Networking Platforms use, store, and disclose your information is governed by the policies of such third parties. Playco has no liability or responsibility for the privacy practices or other actions of any Social Networking Platforms that may be enabled within the Service.
You may also have the option of posting your activities on the Service to Social Networking Platforms (for example, you may post to Facebook that you performed an activity in one of our games). If you choose to use this feature, your friends, followers, or subscribers on the relevant Social Networking Platform may be able to view such activity, consistent with your settings on that Social Networking Platform.
We may message you about the Service using features provided by Social Networking Platforms (e.g., messenger bots or similar messaging features). You may be able to manage notifications through the Social Networking Platform.
6. Children’s information
We do not knowingly collect information from children under the age of 13 or, where applicable laws impose a higher age threshold, from children under the relevant age in those territories. (“Child” or “Children”). Children are not allowed to use our Service. We encourage parents and legal guardians to monitor their Children’s Internet usage. If you have reason to believe that a Child has provided personal information through the Service, please contact us, and we will endeavor to delete that information from our databases.
7. Your rights and choices
Depending on the applicable privacy law in your region, you may have rights relating to your personal information. These may include the rights to:
- Request access or a copy of your personal information.
- Correct or update your personal information where it’s inaccurate.
- Delete your information.
- Object to processing of your personal information or ask us to restrict processing of your personal information.
- Where applicable, withdraw your consent, without affecting the processing already undertaken before your withdrawal or the processing of your personal information under other lawful grounds.
- Complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
- Opt-out of marketing communications we may send you by following any instructions included within the applicable marketing communications, such as by clicking “unsubscribe” or “opt-out” in any marketing emails.
You can exercise any of the above rights by submitting a request through the “Contacting us” channels below. We may need to request specific information from you to help us confirm your identity and verify your request.
If you are a resident of the European Economic Area or the UK, please include “EU Data Subject Request” in the subject line.
8. Data retention
We retain personal information in accordance with our data retention policy, or where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested; to comply with applicable legal, tax, or accounting requirements; for security and fraud detection or prevention; or in connection with secure backup processes).
9. Security
We take steps to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet transmission is ever fully secure or error free. Please keep this in mind when disclosing any information to Playco or to any third party via the Internet.
10. International data transfers
Playco operates across the United States, Japan, and the Republic of Korea, and our partners and service providers may be in various countries around the world. Your personal data may be transferred to, and processed in, these countries, which may be different from the territory in which you reside. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). However, we have taken appropriate safeguards to require that your personal data will remain protected in accordance with this Privacy Notice.
Where we transfer personal data to countries that the European Commission or the UK government (as applicable) consider to provide adequate level of protection for EEA/UK personal information, we rely on such adequacy decisions for Japan, Korea, and the UK. Where there is no adequacy decision, we enter into agreements ensuring appropriate and suitable safeguards with our related companies and any third parties in non-adequate third countries. The safeguards we use are the European Commission’s Standard Contractual Clauses, including the UK Addendum for transfers of Personal Information from the UK. If you would like more information, please contact us.
11. Changes to this Privacy Notice
We reserve the right to amend this Privacy Notice at any time. We will make the revised Privacy Notice accessible through the Service, so you should review the Privacy Notice periodically. You can know if the Privacy Notice has changed since the last time you reviewed it by checking the “Last Updated” date at the beginning of this Privacy Notice. When we update this Privacy Notice, we will post the changes on this page and will indicate the date this Privacy Notice was last revised. By continuing to use the Service, you are confirming that you have read and understood the latest version of this Privacy Notice.
12. Information for California residents
California residents may learn more about their rights in our California Notice.
13. Contacting us
If you wish to exercise any of your privacy rights, have any questions about this Privacy Notice or the information practices of the Service, or wish to lodge a concern or complaint, please contact us directly at privacy@play.co.
