PLAYSTUDIOS ASIA LIMITED (“PLAYSTUDIOS”,” “we,” “us” or “our”) values your privacy. We offer a variety of games through various means, including our mobile application, our Facebook application and through other selected platforms which may include SMS, LINE, Kakao, WeChat, Weibo, Google+ and Tango (collectively, our “Applications”). On our website http://www.playstudios.asia and http://play.lucky.life (the “Site”), we provide information about our products and services, including those games, how you may redeem certain points that you earn through the Applications and marketing campaigns relating to our games we may have from time to time. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our Site and our Applications, and the services offered on each (collectively, “Services”).
By using any of our Services or visiting our Site or Applications, you agree that your personal information will be collected, used, stored and disclosed as described in this Policy. Your use of our Site, Applications or Services is subject to this Policy and our Terms of Service. The PLAYSTUDIOS Terms of Services are incorporated by reference into this Policy:
Please do not continue to use our Services or visit our Site or Applications if you disagree with any of the practices described in this Policy or do not consent to our collection, use, storage or disclosure of your personal information as described in this Policy.
All capitalized terms used in this Policy and not defined within the Policy are defined in the Terms of Service.
In the event of any conflict or inconsistency between the English version and other language versions of this Policy, the English version shall prevail.
What Information Do We Collect About You and Why?
We may collect information about you, in electronic form, directly from you and from third parties, as well as automatically through your use of our Site, Applications or Services.
The personal information that we may ask you to provide is entirely optional. You may enjoy the game services on an anonymous basis. However, in to access certain services, such as saving your point balances between devices or sessions, or redeeming rewards, you will need to authenticate your account via selected Authentication methods, which may provide certain personal information to us. If you choose not to provide any personal information to us through the Authenticating your account, we may not be able to provide the full complement of our Services to you. Certain promotions may also require you to directly submit certain personal information to us; providing this information, as is your participation in such promotions, is entirely at your option.
Information We Collect Directly From You and As You Play Our Games
Certain areas and features of the Applications require registration, such as to accumulate, purchase and redeem Loyalty Points, Virtual Items and Rewards, and to post any User Content. To register, you must create an account with PLAYSTUDIOS by accessing our Applications through your Facebook account or other authentication method offered through the Service (“Authentication”), which may include SMS, LINE, Kakao, WeChat, Weibo, Google+ and Tango. You may earn Loyalty Points as you visit our Applications, and we will keep track of your Loyalty Points. Specific rules may also apply to the earning and redemption of Loyalty Points. Where you are entitled to do so, if you choose to purchase a Reward with your Loyalty Points, we will collect your name and email address in order to process your Reward.
Participation in our marketing campaigns relating to our games may also require registration. We may collect information about you including but not limited to your name, email address, country and the operating system you use.
Information We Collect About You From Facebook or Other Authentication Platforms
When you log into our mobile application through your Facebook or Authentication account, you will be asked to enter your log-in details and password. Facebook and the respective Authentication platform controls the information collected from you during the log-in process; PLAYSTUDIOS does not control the information that Facebook and other Authentication platforms collect from you. When you use any of our Applications (whether our mobile application, our Facebook application or if you access our games through other Authentication platforms), we will collect or access yourinformation as follows, but only with your permission: (i) access and collect your basic information (this may include your name, profile picture, gender, networks, user IDs, list of friends, date of birth, email address, and any other information you have set to public on your Facebook or Authentication account); (ii) send you promotional emails, but only with your permission; (iii) post to your Facebook Wall or other social network you have connected with; (iv) access posts in your news feed within Facebook or other Authentication account; and (v) access your data on Facebook or other Authentication account at any time even if you are not using Facebook or the respective Authentication account. Please note, if you allow PLAYSTUDIOS to have access to this information, then PLAYSTUDIOS will have access to this information even if you have chosen not to make that information public.
For information about how Facebook or other Authentication platforms may disclose your information, including any information you make public, please consult the Privacy Policy of Facebook or respective Authentication platform. We have no control over how Facebook or the respective Authentication platform uses or discloses the personal information you provide to it. We store the information that we receive from Facebook and other Authentication platforms along with other information that we collect from you or receive about you.
Information We Collect Automatically
For users of our mobile application, we collect the following information about your use of our Services: language information, your geo-location (with your permission), unique device identifier (as permitted), and device name and model.
This information we collect about you may constitute personal information. We may use this information in the aggregate or we may combine it with personal information about you.
Site Analytics
We use automated devices and applications, such as Google Analytics or Facebook Insights, to evaluate usage of our Site and, to the extent permitted, our Applications. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services and user experiences.
How We Use Your Information
We use the information that we gather about you in electronic form for the following purposes:
To provide our Services to you, to communicate with you about your use of our Services, to respond to your inquiries, to fulfill your orders, and for other customer service purposes.
For identity verification, rewards announcement, logistics arrangement and to administer our marketing campaigns.
To tailor the content and information that we may send or display to you, to offer location customization, and to otherwise personalize your experiences while using the Site, Applications, or our Services.
Where permitted by law, and in accordance with the applicable terms and conditions of Facebook and other Authentication platforms, for marketing and promotional purposes. For example, we may use your information, including but not limited to your name, email address and telephone number, to send you information in relation to our products, services and events, including but not limited to games, news and newsletters, special offers, promotions, marketing campaigns, new Rewards Partners and rewards provided by our Rewards Partners including but not limited to food and beverages, hotel packages, travel packages, access to clubs and lounges, shows, amusement parks, entertainment, special offers at retail outlets and casinos. In some countries, we are only legally permitted to use your personal information for direct marketing purposes where you have consented to the use of your personal information for such purposes, and in these countries we will only do so with your consent. Even if you consent, you will have the option to opt out of receiving direct marketing materials from us at a later date. We may also use the information that we learn about you to determine where to assist us in advertising our Services on third party websites.
To better understand how users access and use our Services, both on an aggregated and individualized basis, in order to improve our Services, analyze player traffic and activity, respond to user desires and preferences, and for other research and analytical purposes.
We also may post to your Facebook Wall or other social network you have connected with, access posts in your news feeds with Facebook or other Authentication account, and access your data on Facebook or other Authentication account at any time even when you are not logged into Facebook or the respective Authentication account, but only with your permission. We will use and access this information for the purposes described in this section and as discussed below, but only with your permission.
To manage, develop and improve our business operations, to manage payments, billing, accounting and debt-recovery matters.
To investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in dispute resolution in which PLAYSTUDIOS is involved.
As required or permitted by law, or in order to comply with a judicial proceeding, court order, other legal process, such as in response to a court order or a subpoena or to comply with a request from a governmental or regulatory authority.
For any purposes in connection with any claims made by or against or otherwise involving you in respect of any Services provided by us.
To enforce our legal rights and obligations.
For any other purpose for which we have obtained your express permission.
Your personal information may be retained and may continue to be used until: (i) the relevant purposes for the use of your information described in this Policy are no longer applicable; and (ii) we are no longer required by applicable law, regulations, contractual obligations or legitimate business purposes to retain your personal information and the retention of your personal information is not required for the establishment, exercise or defense of any legal claim.
How We Share Your Information
We may share the information that we receive from you, including personally identifiable information, as follows:
Users of Facebook and Authentication platforms. Your Facebook and Authentication accounts’ username and profile picture will be visible to all other PLAYSTUDIOS users, regardless of whether they are your Facebook friends or friends on Authentication accounts. In addition, when you join PLAYSTUDIOS, if you grant request to post on your Facebook Wall or other social network you have connected with under settings, a notification will be visible on your Facebook pageor respective Authentication platform telling your friends that you have started using PLAYSTUDIOS. The PLAYSTUDIOS application will also be visible on your Facebook page under “applications” or equivalent section in the respective Authentication platform.
PLAYSTUDIOS Users. Your username and any information that you post to PLAYSTUDIOS, including, without limitation, reviews, comments, scores, participation in the game, and text will be available to, and searchable by, all other PLAYSTUDIOS users.
Our Group. The information we collect about you may be shared with and accessed by staff who work for PLAYSTUDIOS and its affiliates, located in the United States and Hong Kong. For a full list of our affiliates, please click here http://www.playstudios.com/contact/ .
Our Partners. We may share certain information regarding your Rewards with our partners. The partners will use this information solely for the purpose of determining your eligibility for the Reward. Any information that you submit to a third party will be governed by that third party’s website privacy policy and not this Policy. We do not share your personal information with our partners or other third parties for their direct marketing purposes. Our partners may be located in countries other than your home country, including the United States, Hong Kong, Taiwan, China, Australia, New Zealand, Malaysia, Singapore, and Thailand. For the contact details of our Rewards Partners, please see below:
MGM Macau - https://www.mgmmacau.com/contactus
MGM Resorts International - https://www.mgmresorts.com/contact/
Resorts World Manila - http://www.rwmanila.com/contact-us
Silks Place - http://www.silksplace-tainan.com.tw/en/contactus.php
51Book – telephone +86 551 65238888
Westminster Travel – http://www.westminstertravel.com/hk/Content/ContactUs.aspx
Wolfgang Puck - http://wolfgangpuck.com/contact-us
Service Providers and Advisors. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf. We may also disclose your information to our insurers and advisors, including but not limited to consultants, auditors, accountants and lawyers. Our service providers and advisors may be located in countries other than your home country, including the United States and Hong Kong.
Business Transfers: If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
In Response to Legal Process or Legal Requirement. We also may disclose the information we collect from you to any relevant governmental or regulatory authorities, courts, law enforcement agencies and any person in connection with any claims made by or against or otherwise involving you in respect of any Services provided by us.
To Protect PLAYSTUDIOS and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in dispute resolution in which PLAYSTUDIOS is involved.
Others. Any other person to whom disclosure of your information is necessary in order for us to provide, manage or administer our Services to you, or for any of the purposes described in this Policy. We may also disclose the information we collect from you to any other party to whom you have consented for us to disclose your information.
Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
The parties to whom we may disclose your information may be situated within or outside your home country and your personal information may be transferred to a place outside your home country. The personal information we collect from you may also be stored in a location outside your home country. In some of these countries, there may not be in place data protection laws which are substantially similar to, or serve the same purposes as, the data protection laws of your home country. That means your personal information may not be protected to the same or similar level as in your home country. In such cases, we will nevertheless take all reasonable measures to ensure that your personal information is stored and processed securely and in accordance with this Policy, in each country in which your personal information is stored and/or processed, through contractual obligations on the recipients of your personal information.
Third-Party Links
Our Site and Applications contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead, is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
User Generated Content
We may permit users to submit their own content to our Site and Applications including, without limitation, pictures, reviews, comments and other text. We are not responsible for the privacy of any information that you choose to submit through our Site, Applications and Services, or through any public forum, such as a blog, or for the accuracy of any information contained in those postings. Any information that you disclose becomes public information. We cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.
If you submit personal information in relation to another person to our Site and Applications, you warrant to us that you have obtained the prior consent of that person to submit his/ her information to our Site and Applications and that you have obtained his/her consent to the collection, use, storage and disclosure of his/her personal information in accordance with this Policy.
Security of My Personal Information
We have implemented commercially reasonable precautions designed to protect the information we collect from loss, misuse, and unauthorized access, collection, use, disclosure, copying, alteration, destruction and similar risks. Please be aware that despite our best efforts, no data security measures can guarantee 100% security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity. To change your Facebook password or password on your Authentication account, you must go to the Facebook site or the relevant Authentication account and follow its procedures for changing your password.
Access to and Correction of My Personal Information
You have the right to request access to a copy of the information held by us about you and the right to request correction of such information. If you wish to access or correct your personal information, please contact our Data Protection Officer at [email protected] or by telephone on +852 2155 2207.
You may also modify personal information that you have submitted by logging into your account and updating your profile information. You also may deauthorize the PLAYSTUDIOS Facebook application from your Facebook page. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site or Applications for a period of time.
If you would like to access or modify your Facebook or Authentication account profile information, or adjust the types of information we receive from Facebook or your Authentication account, you must adjust your Facebook account or Authentication account settings directly through Facebook or your Authentication account, respectively. We have no control over how Facebook or your Authentication account shares your information with us or other third parties. The information you provide to Facebook and your Authentication account is subject to the Facebook Privacy Policy and the Privacy Policy of the relevant Authentication platform, respectively.
What Choices Do I Have Regarding Use of My Personal Information?
We may send periodic promotional or informational emails to you as described in this Policy. In some countries, we are only legally permitted to use your personal information for direct marketing purposes where you have consented to the use of your personal information for such purposes, and in these countries we will only do so with your consent. Even if you consent, you may opt-out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 5 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any Services you have requested or received from us.
As noted above, to adjust the types of information about you that we receive from Facebook or other Authentication accounts, you must change your Facebook or Authentication account settings directly through Facebook or your Authentication account.
You also have the right to require us to delete, or cease the collection, processing or use of, your personal information. If you wish to request any of the above, please contact our Data Protection Officer at [email protected].
Third-Party Ad Networks
We may use third parties to assist us in advertising our Site, Applications and Services, and we participate in third-party ad networks that may display advertisements on other websites based on your visits to our Site as well as other websites. This enables us and these third parties to target advertisements by displaying ads for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), LSOs and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information about your usage of our Site and our Services, as well as aggregate or non-personal information about visitors to our Site and users of our Service.
You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp (NAI) and www.aboutads.info/choices (DAA).
Opting out of one or more NAI member or DAA member networks (many of which will be the same) only means that those members no longer will deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our Site or other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI’s and DAA’s websites accessible by the above links.
Children Under 13
Our Services are not designed for persons under 18. We do not knowingly collect information from persons under 18, including children under 13 in particular. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
Contact Us
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact our Customer Support at [email protected] or by telephone on +852 2155 2207.
We will use reasonable endeavors to resolve your query or complaint promptly.
Changes to this Policy
This Policy is current as of the Effective Date set forth below. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.
Your Consent
By continuing to use any of our Services or continuing to access our Site or Applications, you are confirming that you have read and understood this Policy and expressly consent to the collection, use, storage and disclosure of your personal information by PLAYSTUDIOS, for the purposes set out in this Policy.
If you would like to withdraw any consent given to us, please contact us using the contact details in the section headed “Contact Us”.
March 14 2016