PRIVACY POLICY

Last modified: 5 November, 2025

RECITALS

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use Company Products, Games and tells You about Your privacy rights and how the law protects You.
We use Your Personal Data to provide and improve the Company’s Games and other Company Products as defined below.
By using the Games, You agree to the collection and use of information in accordance with this Privacy Policy.
The provisions of the Policy apply to all Company Products as defined below.

  1. INTERPRETATION AND DEFINITIONS

    The words of which the initial letter is capitalized have meanings defined in the Terms of Use, unless an alternative meaning is ascribed to them under the following provisions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

    1. Advertising Partners shall have the meaning ascribed to it in section 6.1.1. of the present Policy.
    2. User (you, Your, Yours, etc.) shall mean the individual, company, partnership and/or any other entity, organization and/or group accessing or using the Games and/or any other Company Products, as applicable.
    3. Personal Data shall mean any information that directly or indirectly identifies the User.
    4. Personal Data Processing shall mean any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data and/or personal data sets, including, without limitation, collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, erasure, destruction of personal data.
    5. Terms of Use shall mean the Terms of Use that form the agreement between You and the Company regarding the use of the Games and other Company Products, which is available at: https://playvision.games/terms_of_use.html.

  2. PRINCIPLES OF DATA PROCESSING

    In the processing of Your Personal Data, We adhere to the following principles:

    1. Lawfulness. We process Personal Data only legally (with Your consent, by virtue of the law, based on legitimate interest, on other legitimate grounds) and for specific purposes, as well as for the proper performance of Our contractual obligations with the Users.
    2. Transparency. We strive to be as clear and as open as possible about how We collect, use and share Personal Data. If You have any questions about any provisions of the Policy, We are open to communication.
    3. Fairness. We do not allow the processing of Personal Data in an unreasonable, harmful, discriminatory, derogatory, unexpected or misleading way.
    4. Specified, explicit and legitimate purposes. The exhaustive list of purposes of processing Your Personal Data is stipulated in the present Policy. We do not process Personal Data for purposes not specified in this Policy.
    5. Data minimization. We process Personal Data only to the extent necessary to achieve the processing objectives specified in the present Policy and We do not process Your Personal Data for any other reasons.
    6. Accuracy. We keep Your Personal Data up-to-date to the extent possible.
    7. Storage limitation. We do not store Personal Data for longer than is necessary for processing purposes.
    8. Integrity and confidentiality. We strive to ensure the security of Your Personal Data by protecting it from unauthorized or illegal access, processing, as well as from accidental loss, destruction or damage, using appropriate technical and organizational measures.

  3. COLLECTING AND PROCESSING OF YOUR PERSONAL DATA

    We process three main types of Personal Data:

    🚩3.1. Information and data that the User provides to us voluntarily:
    This information is necessary for us to properly fulfill Our contractual obligations to Users under the Terms of Use. Without this information, You may not be able to access and use the Game, and/or any other Company Products and/or parts thereof .
    • User name, nickname;
    • ID of the corresponding platform and / or social network;
    • photo and/or other images which the User opts to use as an avatar;
    • data regarding the Users’ statistics within the Games (membership and place in leagues and/or tournaments within each Game, IDs, number of total games played and win percentage (rates), ratings of each Users in each Game);
    • data about exchange of information between the Users within the Games as may be permitted by the Games’ functionality from time to time (e.g. contents of chats between players, gifts, standard phrases, invitations, friends’ lists and/or stickers);
    • subscriptions and other purchases made within the Games as may be permitted by the Games’ functionality from time to time (e.g. purchases of chips, tickets, VIP subscriptions, etc.); data on the amount of chips and/or tickets held by the User at any given time within the Games;
    • Users’ setting and preferences within the Games (e.g. volume level, language preferences, sorting of cards, bones, tap, notification and vibration settings, etc.)
    This information is necessary to send requests to the Company's technical support and provide assistance in resolving them. For the purpose of resolving requests, the Company may request additional information about the User through its technical support staff.
    • User name and/or nickname of the User in question;
    • phone number of the User in question;
    • email of the User in question;
    • account ID, ID of the corresponding platform;
    • the subject matter of the issue and/or request addressed to the Company’s technical support and data pertaining to such issue and/or request.
    🚩 3.2. Data that the User provides automatically:
    We process the information that You provide automatically due to the settings of Your mobile devices and software. Most devices allow You to manage, monitor, and disable Data provision.
    • data about Your age;
    • data about Your account and the progress of using the Games (such information includes the type of browser You use, the platform through which You accessed the Games, Your operating system, access time, Your IP address and the page You visited before accessing Our Services, device ID, advertising user ID, mobile network information and time zone, IMEI code)
    • data about Your device, such as the device name and operating system, language, MAC address, and other unique device identifiers, device token;
    • data about Your exact or approximate location, including the IP address or GPS sensor data on Your mobile device;
    • if applicable: Game usage data, such as gameplay data and User interaction with other Users within the Game.
    In most cases, We also create special IDs for You when You use the Games.
    🚩 3.3. Data that We receive from third parties:
    We may also receive information from third parties. For example, if You log in to Our Games using a third-party site, partner platform, or third-party platform (such as social media platform). We also process information transmitted from app stores, for example, when You download or update one of Our Games from Google Play or from Apple App Store.
    • data from the platforms on which the Game is launched (user name, profile information, social media IDs, advertising IDs, including a photo, subject to the in accordance with the received permission of the procedure determined by such a third-party site or platform);
    • data that We receive when You link third-party services with Our Games. The set of transmitted information is determined by these services or Your privacy settings;
    • information about payments (date, amount, type of payment, payment status), information about purchased in-Game item and/or functionality (name, quantity), information about the activation status of purchased functionality)
    1. The Company may use Personal Data for the following purposes:
    Type of Personal Data (as per section 3 of the present Policy) Purpose(s) (as per section 5 of the present Policy) Legal Basis
    Information and data that the User provides to us voluntarily (section 3.1.) Provision and maintenance of the Games (section 5.1.1.)

    Accounts Management (section 5.1.2.)

    Analytics (section 5.1.3.)

    Contacting Users (section 5.1.4.)

    Support (section 5.1.5.)

    Refund Purposes (section 5.1.7.)    		 Your consent, which you express by continuing to play the Game(s) or to use any other Company’s Products, as Well as the performance of Our contractual obligations under the Terms of Use, including, without limitation, provision of the in-Game items and additional functionality You have purchased and/or may purchase in the future
    Data that the User provides automatically (section 3.2.) Provision and maintenance of the Games (section 5.1.1.)

    Accounts Management (section 5.1.2.)

    Analytics (section 5.1.3.)

    Advertising (section 5.1.6.)    		 Your consent, which you express by continuing to play the Game(s) or to use any other Company’s Products, as well as Our legitimate interest in direct marketing.
    Data that we receive from third parties (section 3.3.) Provision and maintenance of the Games (section 5.1.1.)

    Accounts Management (section 5.1.2.)

    Analytics (section 5.1.2.)

    Advertising (section 5.1.6.)

    Refund Purposes (section 5.1.7.)    		 Your consent, which you express by continuing to play the Game(s) or to use any other Company’s Products, as well as Our legitimate interest in analyzing your activity to make sure that the Games are functioning properly, as well as to fix problems and improve your future experience.

  5. PURPOSES OF PERSONAL DATA PROCESSING

    1. The Company may process Your Personal Data for the following purposes:
      1. Provision and maintenance of the Games: Your Data may be used in order to provide and maintain Our Games and other Company Products, including monitoring the usage of Our Games;
      2. Accounts Management: to manage Your registration as a user of the Games. The Personal Data You provide can give You access to different functionalities of the Games and/or other Company Products that are available to You as a registered User;
      3. Analytics: We and Our partners (“Analytics Services”) collect and process some of your Personal Data for analytics purposes for Our Games. For example, We use this information to:
        1. assess of the difficulty level of the Games;
        2. correct any bugs and/or errors which may occur in the Games;
        3. assessing the demographics of Our Users;
        4. determining the need to support a new type of device for the Games.
      4. Contacting Users: To contact You by email or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding software updates, communications related to the functionalities of the Games and/or other Company Products, sending and/or filing of receipts, bills and other communication regarding Your in-Game purchases, refunds, security updates, etc.;
      5. Support: To attend to and manage Your requests to Us, including, without limitation, the requests sent to Our support team and the feedback left in the form of comments on the platforms through which the Games are distributed;
      6. Advertising: We may use Your Personal Data in order to develop and display content and advertising (and work with third-party vendors who do so) tailored to Your interests and/or location and to measure its effectiveness;
      7. Refund purposes: since We do not process Your Personal Data when you make in-Game purchases within Our Games directly, in order to better process You refund requests We have to obtain Your consent for processing your refund requests, as well as for transfer thereof to Our payment agents. Please be aware that you are allowed to freely withdraw your consent for this purpose at any time, but We note that in case of your consent withdrawal, We may be unable to process your refund requests properly.
    2. For other purposes: We may use Your Personal Data for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of Our promotional campaigns and to evaluate and improve Our Service, products, services, marketing and enhancing Your experience with the Games.

  6. SHARING OF PERSONAL DATA WITH THIRD PARTIES

    1. We may share Your Personal Data with the following third parties, in which cases such third parties may collect, store, utilize and otherwise process Your Personal Data in accordance with their respective privacy policies:
      1. Advertising Partners. To keep Our Games free, We display advertisements in it with the help of third-party advertising partners ("Advertising Partners"). We integrate their technologies into Our Games, thanks to which Advertising partners independently determine which ads to show to You. In order to serve You ads that may be of interest to You, Advertising Partners collect and use Your Personal Data. If location services are enabled in Your device settings, Advertising Partners may additionally collect data about Your geolocation. In some cases, Advertising Partners collect information about you on Our behalf and act as a processor of Your Personal Data, and in some cases, Advertising Partners independently decide to collect Your personal data through the mechanisms built into Our applications. In the latter case, Advertising Partners act as a controller in accordance with the EU General Data Protection Regulations (GDPR). We recommend that you familiarize yourself with the list of Our Advertising Partners and their privacy policies in section 9 of the present Policy.
      2. Payment Service Providers. We may share Your Personal Data with Payment Service Providers in order to process your purchases and refunds. We recommend that you familiarize yourself with the list of Our Payment Service Providers and their privacy policies in section 10 of the present Policy.
      3. Our Affiliates. We may share Your Personal Data with Our affiliates, in which case We will require those affiliates to honor this Privacy Policy. Affiliates include Our subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
      4. Governmental Bodies. We may be required to disclose some or all of Your Personal Data by the applicable laws and regulations (e.g. if such disclosure is ordered by a court, requested by an authorised administrative body authorised to request such Personal Data by the applicable law, etc.).
    2. We may disclose Your Personal Data to other third parties not listed above if you provide us with Your consent for such a disclosure.

  7. DATA RETENTION

    1. How long We retain Your Personal Data depends on why We collected it and how We use it.
    2. We generally retain Your Personal Data as long as Your account is active and for no longer than is necessary for the purpose for which such Personal Data is processed. Please note, however, that We may retain and use Your Personal Data as necessary to comply with Our legal obligations, to resolve disputes, and to enforce Our agreements and rights, or if it is not technically and reasonably feasible to remove such Personal Data from Our databases.
    3. Consistent with these requirements, We will endeavor to delete Your Personal Data promptly upon Your written request.

  8. TRANSFER OF YOUR PERSONAL DATA

    1. Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.
    2. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
    3. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

  9. ANALYTICS AND ADVERTISING\

    Google Analytics Google Analytics is a Web analytics service offered by Google that tracks and reports Website traffic. Google uses the data collected to track and monitor the use of Our Service.

    This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

    You may opt-out of certain Google Analytics features through Your mobile device settings, such as Your device advertising settings.For more information on the privacy practices of Google, please visit the Google Privacy & Terms Web page: https://policies.google.com/privacy
    IronSource We use the IronSource platform to display advertisements and analyze the effectiveness of advertising campaigns in our application. In this regard, certain user data may be transferred to IronSource (ironSource Ltd., Israel) for processing in accordance with their Privacy Policy.

    The data that may be shared includes: device identifiers (such as Advertising ID or IDFA); IP address, country, and device language; information about the device type, operating system, and app version; data on app usage and interactions with advertisements (such as ad views, clicks, and rewards).

    This data is used for the following purposes: displaying and optimizing ads, including personalized advertising (where the user has provided consent); analyzing advertising performance and improving the user experience; preventing fraudulent activity and ensuring compliance with applicable regulations. For more information on what type of information IronSource collects, please visit their Privacy Policy page: http://dev.tapjoy.com/en/legal/Privacy-Policy.
    LitoffMobile We use the LitoffMobile platform to display advertisements and analyze the performance of advertising campaigns in our application. Accordingly, certain user data may be transferred to LitoffMobile for processing in accordance with their privacy policy.

    The data that may be shared includes: device identifiers (such as Advertising ID or IDFA); IP address, country, and device language; information about the device type, operating system, and app version; data on app usage and interactions with ads (e.g., ad views, clicks, rewards).

    This data is used for the following purposes: displaying and optimizing ads, including personalized advertising (where user consent has been provided); analyzing ad performance and improving the user experience; preventing fraud and ensuring compliance with applicable legal requirements. For more information on what type of information LitoffMobile collects, please visit their Privacy Policy page: http://liftoff.ai/privacy-policy/.
    Mintegral We can use the advertising and analytics platform Mintegral, provided by Mobvista International Technology Limited. This service helps display advertisements and analyze the performance of ad campaigns.

    Data processing by Mintegral is carried out in accordance with applicable data protection laws, including GDPR. Users may opt out of personalized advertising by adjusting their privacy settings on their device or within the application.

    For more information on what type of information Mintegral collects, please visit their Privacy Policy page: https://www.mintegral.com/en/privacy
    Firebase Firebase is an analytics service provided by Google Inc. You may opt-out of certain Firebase features through Your mobile device settings, such as Your device advertising settings or by following the instructions.

    All Firebase services (aside from App Indexing and Vertex AI in Firebase) have successfully completed the ISO 27001 and SOC 1, SOC 2, and SOC 3 evaluation process, and some have also completed the ISO 27017 and ISO 27018 certification process. For more information on the privacy practices of Google, please visit the Google Privacy & Terms Web page: firebase.google.com/support/privacy
    Unity Analytics Unity Analytics is provided by Unity Technologies.

    Unity Analytics collects, stores, uses, processes, and transfers personal information to provide, operate, and improve Unity Technologies services, including personalized advertising services. For more information on what type of information Unity Technologies collects, please visit their Privacy Policy page: https://unity3d.com/legal/privacy-policy

    You can prevent Unity Analytics from using Your information by opting-out. You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.
    AppLovin AppLovin is provided by AppLovin Corporation.

    AppLovin Corporation operates a suite of tools for app developers and other businesses to automate and optimize the marketing and monetization of their platforms, products, or services by enabling the placement of different types of advertisements on digital properties including mobile apps, Websites.

    AppLovin Corporation collects, stores, uses, processes, and transfers personal information to provide, operate, and improve services, including personalized advertising services. For more information on what type of information AppLovin Corporation collects, please visit their Privacy Policy page: https://legal.applovin.com/privacy/
    AdMob by Google AdMob by Google is provided by Google Inc.

    You can opt-out from the AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/ansWer/2662922?hl=en

    For more information on how Google uses the collected information, please visit the "How Google uses data when You use Our partners' sites or app" page: https://policies.google.com/technologies/partner-sites and visit the Privacy Policy of Google: https://policies.google.com/privacy

  10. PAYMENTS

    1. When You make in-app purchases in the Games, We do not collect data about the payment transactions You make and do not have access to Your payment information. This information is collected and stored by Your platform (for example, the App Store on Apple devices, Google Play on Android devices) or by some other payment service provider that We engage to process Your payments and refunds, as Well as for verifying payments from You (“Payment Service Providers”).
    2. We will not store or collect Your payment card details. That information is provided directly to Our Payment Service Providers whose use of Your Personal Data is governed by their respective privacy policies. These Payment Service Providers adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
    3. The Payment Service Providers We engage are listed below:
      4. Apple Store In-App Payments Their Privacy Policy can be vieWed at https://www.apple.com/legal/privacy/en-ww/
      Google Play In-App Payments Their Privacy Policy can be vieWed at https://www.google.com/policies/privacy/
    4. Please note that purchases of in-Game items, subscriptions and additional functionality can be carried out not only through the functionality of the Games, but also through the stores of third-party services authorized by us. We encourage you to review the privacy policies of such third-party services.

  11. CHANGES TO THIS PRIVACY POLICY

    1. The Company reserves the right to periodically modify this Privacy Policy.
    2. We encourage You to review the Privacy Policy from time to time for the latest information on Our privacy practices. If We make any changes to the Privacy Policy, We will revise the date at the top of the Privacy Policy with an updated revision date. In case of material or significant changes, We may provide an additional notice (such as emailing You, or placing a notice on Our Website or in-game).

  12. CONTACT US

    If You have any questions about this Privacy Policy, You may contact us at: support@playvision.games

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