PRIVACY POLICY

Last Updated: September, 2022

PLAYSIMPLE GAMES PRIVATE LIMITED

Playsimple Games Private Limited (“Playsimple,” “we,” “us,” or “our”) is dedicated to protecting the privacy rights of our Users (“User,” “your,” or “you”) whose information is collected, processed, and stored while using our Platforms. This Privacy Policy (the “Privacy Policy”) describes how we collect, store, use, disclose, safeguard, and manage your data, including data that you provide or we collect when you use our gaming platforms (individually the “Platform” and collectively the “Platforms”) through our Website at http://playsimple.in/ (the “Website”) or through our mobile applications (“App” when it is a single gaming application and “Apps” for multiple gaming applications) (collectively, the “Services”). The capitalized terms have the same meaning as ascribed in our Terms of Service, as applicable, unless otherwise noted here.

The meaning of certain terms we use in this Privacy Policy is defined by the General Data Protection Regulation (“GDPR”), unless otherwise stated. When we refer to the GDPR we are referring to the General Data Protection Regulation of the UK as well, unless we otherwise specify that we are referring to only one of these laws. All definitions set out in Art. 4 GDPR apply to this Privacy Policy.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR PERSONAL DATA AND HOW WE WILL TREAT IT. PLEASE DO NOT USE OUR SERVICES IF YOU DISAGREE WITH THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO NOT PROVIDE OUR SERVICES TO YOU IF YOU DECLARE THAT YOU DO NOT AGREE WITH THE PROCESSING OF YOUR PERSONAL DATA AS SET OUT IN THIS PRIVACY POLICY.

IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL AT support@playsimple.in. IF APPLICABLE, YOU SHALL AT ANY TIME WHILE AVAILING THE SERVICES OR OTHERWISE, HAVE AN OPTION TO WITHDRAW YOUR CONSENT PROVIDED TO US TO COLLECT, STORE, AND/OR PROCESS YOUR PERSONAL INFORMATION. SUCH WITHDRAWAL OF YOUR CONSENT SHALL BE SENT TO US THROUGH OUR APP OR VIA EMAIL TO .

This Privacy Policy may be updated from time to time, hence it is advisable to review it frequently. We will notify you of material changes to this Privacy Policy via a notice on our home page (http://playsimple.in/). Your continued use of our Platform or Services means that you accept the changes. If you disagree with the processing of data described in this Privacy Policy, you may not be able to continue to use the Platforms or Services provided.

WHO WE ARE

We are the controller of your personal data when processing it:

Playsimple Games Private Limited
No 147, 2nd floor, Anjaneya Techno Park
Kodihalli, HAL Old Airport Road
Bangalore , Karnataka - 560 008

We work together with our affiliate company (“Affiliate”):

PlaySimple Games Pte. Ltd.,
30, Cecil Street, #19-08, Prudential Towers,
Singapore, 049712

Together we are the PlaySimple Group, a group of undertakings (“PlaySimple Group”).

If you want to contact us regarding any request regarding data protection, we encourage you to use the “Contact us” option available in the game(s). Also, you can at any time reach out to our Data Protection Officer by sending an email to dataprivacy@playsimple.in

We and our Affiliate have a representative in the European Union for data protection matters:

Modern Times Group MTG AB,
556309-9158, Skeppsbron 18,
Box 2094, 111 30 Stockholm,
Sweden

Since we and our Affiliate are a subsidiary companies of Modern Times Group MTG AB (“MTG”), we and our Affiliate form a group of undertakings together with it and its other subsidiaries.

TERRITORIAL RESTRICTION

If you are a resident of the United States (“US”), the laws of the State of Delaware, United States shall apply. If you are a resident of any other country, please ensure compliance with all local laws prior to using our Website, App, or Platform. You must comply with our Terms of Use and Terms of Service, as applicable.

Some terms we use in this Privacy Policy are defined by the General Data Protection Regulation (“GDPR”), a data protection law of the European Union. When we refer to the GDPR we are referring to the UK General Data Protection Regulation of the UK as well since both laws are very similar, unless we otherwise specify that we are referring to only one of them. Art. 4 GDPR gives detailed definitions of terms which we also apply in this Privacy Policy.

WHAT DATA DO WE COLLECT?

The type of data we collect depends on the Services you use, and the applicable laws.

Data provided by you

Player name (real or alias)
Contact information (name, email address)
Profile information (such as profile photo)
Your in-game messages to the Services (support tickets raised by you and chat logs)
Other information you choose to share (e.g., data to identify your lost account)

Data collected automatically

Your game account details and game progress
Your Mobile device identifiers and IP address
Your device data like the device name, operating system, and language
Data we collect with cookies and similar technologies (see more below)
Approximate location (as suggested by your IP address)
Your gameplay data and/or interactions with other players inside the Service
Application performance and de-bugging information

Data collected from our partners

We also use third-party partners, such as social networking sites, advertising networks, and data analytics providers.

Data made available by you via your privacy settings in third-party services like Facebook, Google, Apple
Demographic data (such as to determine the coarse location of your IP address)
Data to fight fraud related to refund or advertising
Data from platforms that the games run on (such as purchase data to verify payments)
Additional information (such as data for advertising and analytics purposes) to help display more relevant ads for you and improve the services we provide

WHY DO WE COLLECT YOUR DATA

You personal data can be processed for the following purposes:

Offer our Services

Create accounts and make it possible for you to use our Service
Verify and confirm payments
Process the requests made by you

Offering you our Services can be based on a contract between you and us or our Affiliate. Also, we and our Affiliate have a legitimate interest in processing your personal data to offer you our Services. Due to this, the legal basis for processing your data is Art. 6 para. 1 let. b) and/or f) GDPR. Without this data we could not sufficiently enter into a contract and communicate with you to offer you our Services.

Offering Additional Services

Maintain and update player profiles
Enable social features in our Services
Enable personalization and customization in our Services
Provide player support
Provide offers within our Services
Communicate with you regarding service updates, security alerts, and support messages
Enable communication within the player community

Offering Additional Services is a legitimate interest of ours and our Affiliate, so we can offer interesting features and a good user experience. Due to this, the legal basis for processing your data is Art. 6 para. 1 let. f) GDPR.

Show personalized advertisements

Make advertisements more relevant to you
Serve, measure and improve the effectiveness of advertising

Processing your personal data to show personalized advertisements as well as to measure and improve their effectiveness is based on your consent. Due to this, the legal basis for processing your data is Art. 6 para. 1 let. a) GDPR. For information on how to opt-out from personalized advertisements, see section 'Your Rights and Options' below.

Provide a safe and fair experience and take legal matters into account

We strive to maintain the highest standard of safety and fairness in all our features. In order to do this and fight fraud, we use the data to

Analyze and monitor the social features
Take action against any fraudulent activity
Verify your identity, if needed, to comply with data subject requests of yours
Maintain proof that we comply with applicable laws (e.g., the GDPR)
Sufficiently defend ourselves against any legal claims

Ensuring that our Services are safe, and fair is a legitimate interest of ours and our Affiliate, so we can offer interesting features and a good user experience. This applies to complying with applicable laws and being able to sufficiently defend ourselves and our Affiliate against legal claims, since this can have legal binding effects on us as a company. Due to this, the legal basis for processing your data is Art. 6 para. 1 let. f) GDPR. The processing of your personal data for the purpose of verification, compliance or legal defense is additionally based on Art. 6 para. 1 let. c) GDPR, since we can be obliged by law to process the data.

For details on our policies and terms of service, please visit here.

WHO CAN SEE YOUR DATA?

Apart from PlaySimple, some of your data may be available to others in following situations:

OTHER PLAYERS

Through our Social features, other players may be able to view your profile, in-game achievements and any other detail that you have made public. If you share personal information, post an image or video, or provide other content in public forums such as on a message board, leaderboards, chat room, comment field, or profile page, other people can view, collect, and use that information. If your user name or ID contains your real name, then you acknowledge that your name will be made publicly available on leaderboards and elsewhere as described in this Privacy Policy. Users of such public forums may be able to identify you, use the information to send you messages, or copy any of the images, video or content you have shared. You are strongly encouraged not to share your personal information in public forums or in your username or ID. You are responsible for any information or content you publicly post using our Services.

SERVICE PROVIDERS & AFFILIATES

We work together with vendors that can process your data we share with them to provide certain services. These services may include hosting, player support, advertising, analytics and fraud prevention.

Our partners provide certain features to our Service, such as social media interaction tools, application programming interfaces (APIs) or software development kits (SDKs) and in-game advertising. These partners operate under their own privacy policies hence we encourage you to check their privacy policies and data processing practices.

The data collected by these partners may include your IP address, mobile identifiers, page(s) visited, location, time of day. This data may be combined with the data that we have collected from you. Together, this data may be used for targeted advertisements when you visit third-party services within their networks. If you do not want to share your personal data with third-party advertising partners, please follow the instructions given under the “Your Rights and Options” below.

OTHER COMPANIES AND AUTHORITIES

In case of any fraud or illegal activity, your data may be shared with other organizations and/or public authorities in response to lawful requests.

Data disclosure will be conducted as per the law and protection of the rights and safety of our players shall be ensured.

INTERNATIONAL DATA TRANSFERS

If you are an EU resident, we rely on certain safeguards when sharing your personal data with a recipient established outside of the EEA/EU.

Some vendors with which we share your personal data are established outside of the European Union. Principally, there are two possible safeguards we can rely on when we share your personal data with these recipients:

If a recipient is located in a country for which the European Commission has found it provides an adequate level of data protection, we rely on such adequacy decision by the EU Commission.
If a recipient is not located in a country with an adequate level of data protection according to the European Commission, we either have concluded a contract with this recipient in which we agree on rules to make sure the recipient takes adequate care of your personal data (EU Standard Contractual Clauses developed by the European Commission) or we rely on binding corporate rules of a group of undertakings or enterprises that have been approved by a supervisory authority.

YOUR RIGHTS AND OPTIONS

Push Notifications

You may opt-out from receiving our push-notifications by changing the settings on your mobile device.

Opt-out of targeted advertising

You can opt-out of interest-based advertising by following the privacy settings of your Android, iOS or Amazon device and selecting "Limit Ad Tracking." You can also opt-out by turning off “personalized ads” on Apple iOS,or "Opt-out of Interest Based Ads" on Android, or by disabling Interest based Ads on Amazon.

You can choose to agree or disagree with us sharing your personal data for displaying targeted ads depending on which platform you play our games:

iOS: Choose from the consent pop-up at the start of the game (if you haven’t already generally disabled tracking in your system settings).
Android: Opt out of ad tracking by going to Settings > Ads > Opt out of Ads Personalization
Fire OS: Opt out of ad tracking by going to Settings > Security & Privacy > Advertising ID > Interest-Based Ads

If you would like more information about advertising practices and to know your choices about not having this information used by these companies, you can visit Apple/Google's Advertising and Privacy page or the Network Advertising Initiative. Please understand that if you disable or block certain ad features, then other aspects of our mobile games may not work correctly.

Your Rights

Under the GDPR you have certain rights concerning the processing of personal data by us. According to the GDPR you have the following rights:

Right of information: You have the right to be provided information regarding the processing of your personal data by us, in accordance with Art. 13 and 14 GDPR.
Right of access: You have the right to obtain confirmation as to whether or not we are processing your personal data and, if this should be the case, access to the personal data, in accordance with Art. 15 GDPR.
Right to rectification: You have the right to obtain rectification of inaccurate or incomplete personal data concerning you, in accordance with Art. 16 GDPR.
Right to erasure (“right to be forgotten”): Under certain circumstances you have the right to obtain the erasure of personal data concerning you, in accordance with Art. 17 GDPR.
Right to restriction: Under certain circumstances you have the right to obtain the restriction of processing, in accordance with Art. 18 GDPR.
Right to data portability: Under certain circumstances you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit this data to another controller, in accordance with Art. 20 GDPR.
Right to object: Under certain circumstances you have the right to object to the processing of personal data concerning you, in accordance with Art. 21 UK GDPR. This includes but is not limited to the right to object in cases in which we process your personal data on the legal basis of Art. 6 para. 1 let. f) GDPR.
Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of the EU of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR, as set out in Art. 77 GDPR.
Right to withdraw consent: If a processing of your personal data is based on your consent as set out in Art. 6 para. 1 let. a) GDPR or Art. 9 para. 2 let. a) GDPR, you have the right to withdraw your consent at any time, in accordance with Art. 7 para. 3 GDPR. Such withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.
Right to not be subject to a decision based solely on automated processing: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, as set out in Art. 22 para 1 GDPR.

If you wish to exercise any of the rights mentioned below :

Right of Access/right of disclosure/right to know
Right to erasure/right to deletion (the right to be forgotten)
Right to withdraw consent

Please contact our support team through the in-game Help Center. For all your data related request, please follow the steps: Contact us / Help Center > Other issue > My Data. Apart from the self-service mechanisms, the PlaySimple Group offers a channel to contact the Data Protection Team and exercise rest of the data subject rights via email (dataprivacy@playsimple.in).

If you wish to exercise any of the rights mentioned above, please contact our support team through the in-game Help Center. For all your data related request, please follow the steps: Contact us / Help Center > Other issue > My Data

We may also take additional steps to verify your identity before fulfilling your request.

COOKIES AND SIMILAR TECHNOLOGIES

Our services and those of our partners use cookies and similar technologies to enhance our Services. Please note that our partners may operate under their own privacy policies.

We collect and store your information using cookies and similar tracking technologies in order to

Detect and prevent fraud;
Enable users to sync devices seamlessly
Carry out analytics, and personalization
Limit the the number of times players are shown the same advertisement, across all known or inferred devices
Show personalized advertising on each device

Google, as a third-party vendor, uses Cookies to serve advertisements to Users on our Platforms, Website, and the Apps. Google uses first-party Cookies, such as Google Analytics Cookies, to compile data regarding User interactions with ad impressions and other ad service functions as they relate to our Platforms, Website, and the Apps. We currently use Google Analytics to collect and process certain usage data collected from our career website, Platforms and the Apps usage data. To learn more about Google Analytics and how to opt-out, please visit :

https://policies.google.com/privacy/google-partners.

We have implemented advertising features in Apps, and on our Platforms including Google’s “DoubleClick” platform integration. We use these Cookies and similar technologies to compile data regarding User interactions with ad impressions and other ad service functions.

HOW DO WE PROTECT YOUR DATA

Security Safeguards

Our priority is to provide a safe and transparent gaming environment to our players and in order to do that we ensure that our security system is constantly evolving to meet the highest standard possible. We take all necessary technical and organizational technical and organizational measures to protect your data from unauthorized access or misuse.

Data retention

Your data will be stored by us till the time you have an active account. PlaySimple may re-assess unused accounts and de-identify unnecessary data. Data that is stored for longer as you have an account or that is not related to your account is stored for as long as the purpose for processing it is still given (e.g., for as long as we still have a legitimate interest as mentioned above). Apart from this, legal obligations to store your personal data for a certain time period can apply.

COPPA COMPLIANCE (FOR CHILDREN UNDER 13 USERS ONLY)

Protecting children's privacy online is extremely important to Playsimple. Playsimple’s Website, Apps and Services are intended for general audience and Playsimple does not knowingly collect any Personal Information as the term is defined under the Children’s Online Privacy Protection Act (“COPPA”). The COPPA is a federal legislation that applies to entities that collect and store Personal Information from children under the age of 13. We are committed to ensure compliance with COPPA. Our Website, Apps, and Platform are not meant for use by children under the age of 13.

When Users identify themselves as children (i.e. under the age of 13 or under the minimum age in the relevant territory), consistent with applicable law we will: (1) not provide a path for them to input Personal Information, (2) collect certain information for limited purposes only (consistent with applicable law), (3) block or restrict the child from accessing relevant services (such as chat functionality); and/or (4) obtain consent from parents for the collection, use, and sharing of their children's Personal Information.

Through our Apps your child will be able to receive local in-app notifications, which do not collect any Personal Information.

Please note that if you grant consent for your child to use Playsimple's Platform on our Website or on the Apps, this may include such general audience communication services as email, instant messaging, and online groups, and your child will be able to communicate with, and disclose Personal Information to, other Users of all ages.

If you are a parent and wish to revoke your previously provided consent, review information collected from your child or have that information deleted, please contact the Playsimple support by writing an email to support@playsimple.in. Information collected is secured in a manner consistent with this Privacy Policy. If we make material changes to how we use, collect, or share your child's Personal Information, we will notify parents by email or by providing a notification on the Platform in order to obtain verifiable parental consent for the new uses of your child's Personal Information. We encourage you to talk with your children about communicating with strangers and disclosing Personal Information online. Under no circumstances do we condition a child's participation in an activity—like contests—on the child's disclosure of more Personal Information than is reasonably necessary to participate in the activity. On certain Apps, we may not permit children to participate at all regardless of having their parental consent. If you would like to know more about our practices and specifically our practices in relation to COPPA compliance, please email us at support@playsimple.in.

COPYRIGHT POLICY

The contents of this website, our Platforms, and the Apps may not be reproduced partially or fully, without due permission from Playsimple as per the Copyright Act, 1957. If referred to as a part of another publication, the source must be appropriately acknowledged. The contents of this website cannot be used in any misleading or objectionable context.

THESE TERMS ARE IN ADDITION TO THE TERMS AND CONDITIONS IN OUR GENERIC TERMS OF USE. PLEASE READ OUR PRIVACY POLICY AND OUR TERMS OF USE. BY REGISTERING ON OUR WEBSITE, TO PLAY OUR GAMES, AND/OR BY PLAYING OUR GAMES, YOU AGREE TO THE TERMS AND CONDITIONS IN OUR PRIVACY POLICY, TERMS OF USE, AND THE APPLICABLE SPECIFIC USER TERMS OF USE. READ ALL OF THEM CAREFULLY. IF YOU DO NOT WANT TO BE BOUND BY THEIR TERMS AND CONDITIONS, DO NOT REGISTER OR PLAY OUR GAMES. YOU ARE ALSO BOUND BY THE TERMS AND CONDITIONS AND PRIVACY POLICIES OF OUR PARTNERS WHOSE GAMES ARE ALSO FOUND ON OR ASSOCIATED WITH OUR WEB SITE.

FOR CALIFORNIA RESIDENTS

Please visit playsimple.in/disclosure-california-residents for special disclosures pertaining to California residents

FOR CANADIAN USERS

Please visit playsimple.in/disclosure-canada-residents for special disclosures pertaining to Canada residents

PLEASE NOTE: IF YOU USE AND NAVIGATE THROUGH OUR PLATFORMS OR OUR WEBSITE AND/OR DOWNLOAD OR USE OUR APPS, OR ACCESS OUR PLATFORMS OR USE OUR SERVICES, YOU HAVE AGREED TO AND ACCEPTED THE TERMS AND PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF SERVICE. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY OR THE TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF SERVICE, PLEASE DO NOT NAVIGATE, ACCESS, DOWNLOAD, OR USE OUR PLATFORMS, WEBSITE, AND/OR THE APPS.