Papaya Gaming Ltd. (“Papaya”, “we”, “our” or “us”) develops and operates social skill games for mobile environments; "Apps"). We also operate the website www.papaya.com, its subdomains and its related features (“Website”, and together with the Apps – the “Services”).
Specifically, this Policy describes –
We strongly urge you to read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue and avoid using our Services. You have the right to cease using our Services, pursuant to this Policy, at any time.
You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the full range or with the best experience of using our Services.
We collect Personal Data about you, meaning any information which potentially allows your identification with reasonable means (for example, email address or name, collectively "Personal Data"). This section sets out how and when we collect and process Personal Data about you.
Communication Information. When you send us an email or contact us via the support in our Apps or Website, we collect the Personal Data you provide us. This may include your name, email address and any other information you choose to provide.
When you use or access our Services, we use the following categories of Tracking Technologies:
We store Tracking Technologies on your device when you visit or access our Services (for example, when you are visiting our Website) – these are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example, our analytics service providers, business partners, and advertisers), who run content on our Services – these are called "Third Party Tracking Technologies". Both types of Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits.
There are various ways in which you can manage and control your Tracking Technologies settings. You can change your preferences using our cookie settings tool (however, please note that this tool may only be available in certain jurisdictions). Other methods of managing your Tracking Technology preferences include: changing your browser settings to send a “Do-Not-Track” signal. In such case, your browser will send us a special signal to stop tracking your activity. However, please note that certain features of the Website may not work properly or effectively if you delete or disable cookies.
To learn more about how you can manage your cookies, below is a list of useful links that can provide you with more information:
You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third-party webpages:
You can withdraw your consent to personalized advertising experience on your device at any time by using your device settings as follows:
Providing users with a fair, balanced, and competitive experience on our Services is extremely important to us. Therefore, we strictly enforce prohibitions against cheating, hacking, account stealing, and any other unauthorized or fraudulent activity. When you create an account, play our games, or otherwise interact with our Services, we may use a variety of anti-cheat and fraud prevention technologies to help us identify and prevent malicious activity. These services may collect and analyse data about the game binary or your computer to detect cheating, and may be provided by us or by third party service providers.
We may share, sell and disclose your Personal Data as described below:
In the 12 preceding months, we have collected and/or disclosed the following categories of Personal Data:
Sources of Personal Data
In the 12 preceding months, we have collected the above-mentioned categories of Personal Data from the following categories of sources:
We may use your Personal Data ourselves or by using our third-party subcontractors for the purpose of providing you with promotional materials concerning the Services as well as products, services, websites and applications which relate to: (i) affiliated companies or Papaya's business partners and affiliates (collectively, “Marketing Affiliates”), which we believe may interest you.
You may at any time decline receiving further marketing offers from us or from our business partners and Marketing Affiliates by contacting us at firstname.lastname@example.org
Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
Depending on the jurisdiction in which you reside, you may have certain rights under relevant applicable laws regarding the collection and processing of your Personal Data. To the extent these rights apply and concern you, you can contact us via the contact details available below and ask to exercise the following rights.
You have the right to receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
You have the right to request us to move, copy and transfer your Personal Data easily from one IT environment to another, in a safe and secure way, without affecting its usability.
You have the right to request rectification of your Personal Data in our control in the event that you believe the Personal Data held by Papaya is inaccurate, incomplete or outdated.
You have the right to request that Papaya erases or deletes Personal Data held about you at any time.
You have the right to request that Papaya restricts or ceases to conduct certain Personal Data processes at any time.
To the extent we process Personal Data on the basis of your consent, you have the right to withdraw your given consent at any time.
You have the right to request to limit the collection of your sensitive Personal Data, to that use which is necessary to perform our Services.
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly effects to you.
In the event that we sell or share your Personal Data for behavioral advertising purposes, you have the right to submit a request to opt-out of the sale or share of your Personal Data. After you opt-out, we may continue disclosing some Personal Data to our partners to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services are working correctly and securely, providing aggregate statistics and analytics and preventing fraud.
You have the right to be free from any discrimination for exercising your rights, such as offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request.
Please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. You are welcome to contact us for any questions or requests through our contact details below.
We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.
i) The authorized agent is a natural person or a business entity; and
ii) You sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request to exercise your right, please provide us with a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.
i) Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Data or an authorized agent. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you; and
ii) Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
We operate globally, thus any information that we collect, disclose or share, including your Personal Data, can be stored and processed in various jurisdictions around the world, including (but not limited to) the European Economic Area, United Kingdom and United States, for the purposes detailed in this Policy.
To the extent that the GDPR or UK GDPR are applicable, we will only transfer or share your Personal Data to data recipients:
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. Such breaches can lead to things such as reputational harm, fraud or identity theft. Therefore, we encourage you to exercise discretion regarding the Personal Data you choose to disclose. If you feel that your privacy was treated not in accordance with our Policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly via our contact details available below.
We do not knowingly collect or solicit Personal Data from anyone under the age of consent (as determined under the applicable laws where the individual resides; “Age of Consent”). By accessing, using or interacting with our Services, you certify to us that you are not under the Age of Consent. In the event we learn that we have collected Personal Data from an individual under the Age of Consent without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Consent, then please contact us through the contact details available below.
We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.
We reserve the right to change this Policy at any time. The most current version will always be posted on our Services (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.
The Company has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. If you have any questions about this Policy, please contact our Data Protection Officer (the contact details are available in the "Contact Us" section).
If you have any further questions, please contact us by email at: email@example.com.
Papaya Gaming Ltd.
35 Hamasger St.
If you reside in the EU, you may also contact our EU representative:
European Data Protection Office
via form: here
Attn: EDPO, Avenue Huart Hamoir 71, 1030 Brussels, Belgium.
If you reside in the UK, you may also contact our UK representative:
EDPO UK Ltd.
via form: here
Attn: EDPO UK, 8 Northumberland Avenue, London WC2N 5BY, United Kingdom