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, it describes our policy regarding –
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 two types of data from you: Personal Data ("Personal Data") and non-Personal Data. Personal Data means any information which may potentially allow your identification with reasonable means (for example, email address or name). Non-Personal Data, by contrast, can be defined as any information that does not relate to an identified or identifiable natural person. This may include, for example, your aggregated usage information and technical information transmitted by your device (e.g. the device you use, the type of browser and operating system your device uses, language preference, access time, etc.). This section sets out how and when we collect those types of data from you.
1.1 Account Information. If you choose to register an account with our Services, we collect your full name, email address, phone number, birthdate and username. If you choose to log in, access or otherwise connect to the Services through a social networking service (such as Facebook, Twitter, Instagram, etc.), we may collect your user ID and/or username associated with that social networking service, as well as any information you make public using that social networking service or that the social networking service allows us to access.
1.2 Payment Information. When you decide to deposit money in our Apps, you will be required to provide use with your billing information. The information you will need to submit depends on which billing method you choose. For example, if you pay with a credit card, we will collect your card information.
1.3 Usage Information. When you use our Services, we collect technical information about your interaction with our Services. Such information may include geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) as well as other information which relates to your activity in the Services.
1.4 Communication Information. When you send us an email or contact us via the support in our Apps or Website, we collect the Personal Data you provide us. This may include your name, email address and any other information you choose to provide.
2.1 What types of Tracking Technologies do we use?
When you use or access our Services, we use the following categories of Tracking Technologies:
(a) Strictly Necessary Tracking Technologies – these Tracking Technologies are automatically placed on your computer or device when you access our Services or take certain actions on our Apps or Websites. These Tracking Technologies are essential to enable you to navigate around and use the features of our Services. We do not need to obtain your consent in order to use these Tracking Technologies;
(b) Tracking and Advertising Tracking Technologies – these Tracking Technologies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The Tracking Technologies remember the websites you visit and that information is shared with other parties such as advertisers and/or publishers. Publishers, advertisers, and third-party ad networks may also utilize Tracking Technologies or similar technologies to deliver ads and monitor the performance of such ads. The collection of information through Tracking Technologies by such third parties will be governed by their own privacy policies/cookies policies and principles, which the Company does not control;
(c) Functionality Tracking Technologies – these Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services;
(d) Performance Tracking Technologies – these Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services), including behavioral data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).
2.1 How and by whom Tracking Technologies are stored on your device?
We store Tracking Technologies on your device when you visit or access our Services (for example, when you are visiting our Website) – these are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example, our analytics service providers, business partners, and advertisers), who run content on our Services – these are called "Third Party Tracking Technologies". Both types of Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits.
There are various ways in which you can manage and control your Tracking Technologies settings. You can change your preferences using our cookie settings tool (however, please note that this tool may only be available in certain jurisdictions). Other methods of managing your Tracking Technology preferences includes: changing your browser settings to send a “Do-Not-Track” signal. In such case, your browser will send us a special signal to stop tracking your activity;. However, please note that certain features of the Website may not work properly or effectively if you delete or disable cookies.
To learn more about how can manage your cookies, below is a list of useful links that can provide you with more information on how to manage your cookies:
You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third party webpages:
You can withdraw your consent to personalized advertising experience on your device at any time by using your device settings as follows:
Providing users with a fair, balanced, and competitive experience on our Services is extremely important to us. Therefore, we strictly enforce prohibitions against cheating, hacking, account stealing, and any other unauthorized or fraudulent activity. When you create an account, play our games, or otherwise interact with our Services, we may use a variety of anti-cheat and fraud prevention technologies to help us identify and prevent malicious activity. These services may collect and analyze data about the game binary or your computer to detect cheating, and may be provided by us or by third party service providers.
We may share your Personal Data as described below:
We may use your Personal Data ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning the Services as well as products, services, websites and applications which relate to: (i) affiliated companies or Company's business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you.
You may at any time decline receiving further marketing offers from us or from our business partners and Marketing Affiliates by contacting us at email@example.com
Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
6.1 Your rights
This section addresses the specific rights applying to residents of the EU or resident of other jurisdictions that grant the below rights.
You may request to:
Please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. You are welcome to contact us for any questions or requests through our contact details below.
We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.
6.2 Transfer of data outside the EU
Any information that we collect (including your Personal Data) may be stored and processed in various jurisdictions around the world, for the purposes detailed in this Policy. However, we will only transfer your data to data recipients (i) located in the European Economic Area (the “EEA”), (ii) located in non-EEA countries which have been approved by the European Commission as providing adequate level of data protection, or (iii) who entered into legal agreements ensuring an adequate level of data protection.
7.1 What information we process
In the preceding 12 months, we have collected, and or disclosed the following categories of Personal Data:
7.1 Sources of Personal Data
In the 12 preceding months, we have collected the above-mentioned categories of Personal Data from the following categories of sources:
7.3 Sale of Personal Data
We do not "sell" Personal Information about our users as most people would typically understand that term. However, we do allow certain third-party advertising partners to collect information about consumers through our Services for purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for ad fraud detection and reporting. Please see our "Cookies and Tracking Technologies" section above for more information.
7.4 User right under the CCPA
The CCPA provides consumers with specific rights regarding their Personal Data. This section describes your CCPA rights and explains how to exercise those rights.
Access to Personal Data
You may request, up to two times each year, that we disclose to you the categories and specific pieces of Personal Data that we have collected about you, the categories of sources from which your Personal Data is collected, the business or commercial purpose for collecting your Personal Data, the categories of Personal Data that we disclosed for a business purpose, any categories of Personal Data about you that we sold, the categories of third-parties with whom we have shared your Personal Data, and the business or commercial purpose for selling your Personal Information, if applicable.
You have the right to request that we delete any Personal Data collected from you and retained, unless an exception applies.
Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your Personal Data, unless an exception applies.
Right to Opt-Out of the Sale of Personal Information
In the event that we sell your Personal Data, you have the right to submit a request to opt-out of the sale of your Personal Data. You may change your decision at any time and permit us to sell your Personal Data.
After you opt-out, we may continue to share some Personal Data with our partners (who will function as our service providers in such instance) to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services is working correctly and securely, providing aggregate statistics and analytics and/or preventing fraud.
Right to non-discrimination
You have the right to be free from any discrimination for exercising your rights under the CCPA. Should you exercise any of your rights under the CCPA, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request. However, in some circumstances, for example where you have requested or consented to our Services that use your Personal Data to provide the service, we may not be able to provide a service if you choose to delete your Personal Data
Exercising Your Rights
You can exercise your rights by submitting a verifiable consumer request to our physical address (as written below in the "How to contact us" section) or to our email address: firstname.lastname@example.org.
Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Data.
The request must:
You can designate an authorized agent to make a request under the CCPA on your behalf if:
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. Such breaches can lead to things such as reputational harm, fraud or identity theft. Therefore, we encourage you to exercise discretion regarding the Personal Data you choose to disclose. If you feel that your privacy was treated not in accordance with our Policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly via our contact details available below.
We do not knowingly collect or solicit Personal Data from anyone under the age of consent (as determined under the applicable laws where the individual resides; “Age of Consent”). By accessing, using or interacting with our Services, you certify to us that you are not under the Age of Consent. In the event that we learn that we have collected Personal Data from an individual under the Age of Consent without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Consent, then please contact us through the contact details available below.
We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.
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. 22 Isserles St. Tel Aviv-Yafo, Israel, 6701457
If you reside in the EU, you may also contact our EU representative:
European Data Protection Office via form: here via mail: 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 via mail:
Attn: EDPO UK, 8 Northumberland Avenue, London WC2N 5BY, United Kingdom