Papaya Gaming – Privacy Policy

Last modified: January 31, 2024

Introduction

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”).

Papaya is dedicated to protecting your privacy rights and making our practices regarding your Personal Data more transparent and fair. This Privacy Policy (“Policy”) is designed to help you understand how we collect, store, use and share your Personal Data.  This Policy applies whenever you visit our Website, install or interact with our Apps, or otherwise access or use any of our Services. Please note that parts of this Policy may not be applicable to you, depending on the jurisdiction in which you reside and the applicable laws.

Specifically, this Policy describes –

1.   What types of data we collect?
2.   Tracking Technologies
3.   Why we process your Personal Data?
4.   With whom we share your data?
5.   Marketing and advertising
6.   Your rights
7.   Transfer of Personal Data
8.   How we protect your data?
9.   Minors
10.   Retention
11.   Updates to this Policy
12.   Controlling version
13.   Data Protection Officer
14.   Contact us

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.

This Policy is integrated into and forms part of the Papaya Terms of Use which are currently available at: https://www.papaya.com/terms-of-use

1. What types of data we collect?

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.

1. Account Information. If you choose to register an account with our Services, we collect your full name, email address, phone number, birthdate and user nickname, as well as voluntary information, such as your profile picture. 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.

2. Payment Information. When you decide to deposit money in our Apps, you will be required to provide us 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.

3. Usage Information. When you use our Services, we collect technical information about your interaction with our Services. Such information may include gameplay recordings, 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.

‍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. Tracking Technologies

When you visit or access our Services, we use cookies, pixels, beacons, local storage and similar technologies ("Tracking Technologies"). These allow us to automatically collect information about you, your device, and your online behavior, in order to enhance your navigation in our Services, improve our Services performance, perform analytics, customize your experience, and offer you, for example, tailored content and advertisements that better correspond with your interests. You can learn more about our use of Tracking Technologies by visiting our Cookie Policy.

1. What types of Tracking Technologies do we use?

When you use or access our Services, we use the following categories of Tracking Technologies:

1. 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. 

2. 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 Papaya does not control. 

3. 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. 

4. Performance Tracking Technologies – These Tracking Technologies collect information about your online activity (for example, the duration of your visit on our Services), including behavioural data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).

2. 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 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:

1. Google Chrome
2. Microsoft Edge
3. Mozilla Firefox
4. Safari (Desktop)
5. Safari (Mobile)
6. Android Browser
   

You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third-party webpages:

1. The Interactive Advertising Bureau (US)
2. The Interactive Advertising Bureau (EU)
3. European Interactive Digital Advertising Alliance (EU)
   
   

You can withdraw your consent to personalized advertising experience on your device at any time by using your device settings as follows:

1. On iOS, depending on the applicable iOS version, you may withdraw consent across all apps by either enabling the “Limit Ad Tracking” setting or disabling the “Allow Apps to Request to Track” permission in your iOS device settings. Depending on the applicable iOS version, instead of withdrawing consent on a device-wide basis, you may also have the option of withdrawing consent on a per-app basis by disabling tracking permissions for specific apps that appear under the “Allow Apps to Request to Track” setting in your iOS device settings (precise directions may differ depending on the applicable iOS version).
   

2. On Android devices, you may withdraw your consent in the Google Ads settings within your Android settings by enabling the “Opt out of Ads Personalization” setting (precise directions and the name of the setting may differ depending on the applicable Android versions and device manufacturer).

3. Why we process your Personal Data?

This section explains for what purposes we use your Personal Data and outlines the legal bases that underlie our usage.

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.

4. With whom we share your data?

We may share, sell and disclose your Personal Data as described below:

1. Affiliated companies: We may share Personal Data internally within our affiliated companies and subsidiaries, for the purposes described in this Policy. 
2. Payment processors: We share your payment information with third party payment processors, for the purpose of facilitating your payments when using our Services. These third parties may have access to your Personal Data so that they may perform these tasks on our behalf.
3. Service providers: Our service providers work on our behalf that may need access to certain Personal Data in order to provide their services to us. These companies include those we have hired to provide customer service support, operate the technical infrastructure that we need to provide the services and cloud storage vendors.
4. Third party advertisers: We may partner with third parties to either display advertising on our Services or to manage our advertising on other websites or apps. Our third party advertisers may use Tracking Technologies to gather information about your activities on our Services and other websites and apps in order to provide you advertising based upon your browsing activities and interests. For more information, please visit our partner's privacy policies in the following links: AppLovin and Unity.
5. Third Party Integrations: The Services allow you to integrate with certain third party services, such as in order to connect your Facebook or Apple account to our Apps or to place purchases, in which case you will be bound by the terms and conditions and privacy notices of said third parties (e.g., Apple, Google or Facebook) – so please make sure that you read and accept them in advance. We do not receive or store your passwords for any of these third party services.
6. Compliance with laws and law enforcement entities: We may disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal procedures (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We may also be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
7. Auditors and advisers: We may share your data with our external auditors, advisors and professional service providers (e.g., lawyers, accountants, insurers) for ensuring our compliance with regulatory requirements and industry standards.
8. Mergers and acquisitions:  We will transfer, sell or otherwise share your data in case of entering into a business transaction such as merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets.

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:

• Consumer directly
• Advertising networks
• Social networks

5. Marketing and Advertising

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 support@papaya.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. Your rights

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.

1. Rights of access to your Personal Data:‍

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.

2. Right of data portability:

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.

3. Right of rectification:

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.

4. Right of deletion/erasure:

You have the right to request that Papaya erases or deletes Personal Data held about you at any time.

5. Right to restriction or objection to processing:

You have the right to request that Papaya restricts or ceases to conduct certain Personal Data processes at any time.

6. Right to withdraw your consent:

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.

7. Right to limit use and disclosure of your sensitive Personal Data:

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.

8. Right not to be subject to automated decision making:

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.

9. Right to opt-out of the sale or share of Personal Data:

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.

10. Right to non-discrimination:

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.

Authorized agent

1. You can use an authorized agent to make a request to exercise your right under applicable laws on your behalf if:

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.

2. The request must:

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.

3. We will only use Personal Data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

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4. Making a verifiable consumer request does not require you to create an account with us. 

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7. Transfer of Personal Data

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:

1. located in the EEA or in the UK;
2. located in non-EEA countries or UK which have been approved as providing adequate level of data protection; or 
3. who have entered into legal agreements ensuring an adequate level of data protection.

8. How we protect your data?

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.

9. Minors

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.

10. Retention

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.

11. Updates to this Policy

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.

12. Controlling Version

The Privacy Policy has been drafted in the English language, which is the original and controlling version of this Privacy Policy. All translations of this Privacy Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Privacy Policy. In the event of any discrepancy between the meanings of any translated versions of the Privacy Policy and the English language version, the meaning of the English language version shall prevail.

13. Data Protection Officer

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).

14. Contact Us

If you have any further questions, please contact us by email at: support@papaya.com.  

Papaya Gaming Ltd.

35 Hamasger St.

Tel Aviv-Yafo

Israel

6721407

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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.

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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

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