PLAYSIMPLE GAMES PRIVATE LIMITED

PRIVACY POLICY

Last Updated: July, 2020

 

1.         INTRODUCTION

 

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 information, including Personal Information (“Personal Information” or “PI”).  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.

 

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. 

IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL TO support@playsimple.in. 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 IN WRITING SENT IN AN EMAIL TO support@playsimple.in. 

WE SHALL HAVE THE OPTION NOT TO PROVIDE OR CONTINUE OUR SERVICES WHEN WE RECEIVE IN WRITING YOUR WITHDRAWAL OF YOUR CONSENT. IT MAY ALSO LEAD TO IMMEDIATE TERMINATION OF OUR SERVICES. IN CASE YOU DO NOT PROVIDE US WITH A WRITTEN NOTICE OF YOUR WITHDRAWAL OF YOUR CONSENT IN THE MANNER PROVIDED IN THIS PARAGRAPH, THE SAME SHALL NOT BE CONSIDERED AS WITHDRAWAL OF YOUR CONSENT UNDER THIS PRIVACY POLICY. 

 

2.         WHAT INFORMATION DO WE COLLECT?

We collect the following information:

A.        Information You Give Us Directly

Personal information shall mean and include information collected by us that may help identify you and information needed by us to provide you with our Services. Personal information is only gathered as voluntarily provided by you and based on your consent. Some information may be gathered by other sources linked to the Services (such as Facebook).

In some instances, Playsimple may gain access to some Personal Information through third-parties or affiliates.

Some of the information that may be collected can include, but is not limited to:

_               Contact information such as name/username, email address, Facebook ID;

_               Device information such as Device ID (Android) or Advertising ID (iOS devices);

_               additional information required to verify your identity, such as age;

_               supplemental information from third parties; and

_              Any other information you may provide to us on a need basis in order for us to provide you with our Services.

B.         Other Information We Collect When You Use Our Products

We collect other information automatically when you use our Platforms for providing enhanced user experience, including:

_               IP address;

_               Mobile and other hardware or device identifiers;

_               Referring and exit pages, including landing pages and pages viewed;

_               Profile photograph;

_               Platform type; and

_              Device event information, including crash reports, request and referral URL's and system activity details (e.g. whether you encountered an error playing our games or lost Internet access).

We may also collect and store information locally on your device, using mechanisms like cookies, browser web storage (including HTML 5) and application data caches.

C.         Information Provided to Us by Third Parties

Apps. If you play or purchase our games on your mobile device and/or any other device such as a tablet etc., we receive information about you from the app stores and other mobile platform providers. This information includes your username and/or device ID and the fact that you made a purchase, for instance, but does not include any sensitive or financial information. Some of our Apps may send information to us that you authorize them to provide. Our Apps also may request additional Personal Information from you, such as push notification tokens or contact list, and we will collect this information only if you give us your explicit consent.

 

Other Third Parties. We may receive information from third parties, like Facebook or Game Center, when you use these service providers in connection with our Services. We may also receive information about you when other players choose to share their contact lists with us. We may also receive information from third parties legally to supplement the information we receive from you. We use information from these companies primarily to help us deliver relevant advertising to you. We also may use information from third parties, for instance, to help us understand your approximate geolocation via your IP address, or to customize certain Services to your location, and for fraud and/or abuse prevention purposes.
 

3.         HOW DO WE COLLECT YOUR INFORMATION

We collect some information from you when you provide it to us directly, such as via an online form or when you talk with our customer experience team. We and third parties also use certain technologies described below to collect information to deliver excellent experiences.

A.         Cookies and Similar Technologies

Cookies are small text files stored on your Internet browser. We use cookies and similar technologies to help us understand things like what web pages, features or advertisements you view and what games you play. This information helps us measure the effectiveness of our advertising, make sure you do not see the same ad repeatedly and otherwise help enhance your user experience. You can disable cookies, limit the types of cookies you allow, or set your browser to alert you when cookies are being sent. We use other technologies for similar purposes as a cookie. We use pixels or clear GIFs to collect information about your use of our Platform and your response to our marketing emails. We use Internet log files (which contain technical data such as your IP address) to monitor traffic on our Platform, troubleshoot technical problems, detect and prevent fraud and enforce our User Agreement. Other examples include HTML 5 cookies, Silverlight Application Storage, device fingerprints and "flash cookies”.

We currently do not respond to Do Not Track (DNT) signals. We may adopt a DNT standard if one is established. In the meantime, you may opt out of certain types of tracking, including certain analytics and tailored advertising by changing your cookie settings.

We also use Analytics, Advertising, Anti-Cheat and Anti-Fraud technologies in our Platforms that utilize the same cookies and similar mechanisms. These technologies are described below.

B.         Analytics Technologies

We use our own game servers and internal and third-party analytic technologies to collect information about how you use our Platforms, your computer or device and the health of our Platforms.

For instance, Playsimple may collect and store data from your computer or device when you use our Platforms. This information includes technical and related information about your computer or device and operating system (such as IP Address and device ID), information about your feature usage, gameplay and usage statistics, system interactions and peripheral hardware for purposes described in Section 3, below. If you play a game offline, this data will be stored on your device and transmitted to Playsimple when your device connects to the Internet. If you participate in online Services, Playsimple also may collect, use, store, transmit and publicly display statistical data regarding game play (including scores, rankings and accomplishments), or identify content that is created and shared by you with other Users.

Third party analytics services integrated into our Platform may combine the information they collect in connection with Playsimple's Services with information they have independently collected over time and across different websites. Many of these companies collect and use information under their own privacy policies. 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 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 on our Website, Apps, and Platforms including Google’s “DoubleClick” platform integration. We use these Cookies to compile data regarding User interactions with ad impressions and other ad service functions as they relate to our Website. 

C.         Ad Serving Technologies

Our Platform employs ad serving technologies that use cookies, clear GIFs, web beacons, tracking pixels, and other similar technologies like identifiers to deliver offers to you. Some of these technologies can sync or connect behavior across different websites, mobile apps and devices. The ads can be tailored to your interests. For instance, you may be presented with an offer for a game we think you might enjoy or if you express interest in a game, you might receive an advertisement later for that game or similar products on third party sites. Other in-game advertising technologies enable advertising to be temporarily uploaded to your game, web browser, or mobile device and later replaced while you are online.

These technologies collect and use information so we can serve appropriate advertising to you and help track results and measure effectiveness. In addition to identifiers, this information includes:

_               advertisements served and the location of such advertisement;

_               length of time an advertisement was visible;

_               domain type, IP address, size of the advertisement; and

_               advertisement response.

Third party advertising companies may combine the information collected in the context of delivering an advertisement to you via our Services with other information they have independently collected over time and across different websites. Many of these companies collect and use information under their own privacy policies.

Note that opting out does not mean you won't see advertisements; it just means that the advertising you see may be less relevant to your interests.

D.         Anti-Cheat and Fraud Prevention Technologies

Playsimple strives to provide a safe and fair gaming environment for all the Users. When you log in to our Platform, we or third parties may use cookies and similar technologies, or collect data about your machine or device, to create a machine "fingerprint" or "hash" of your machine components, for fraud prevention, security and authentication purposes. We also may use other anti-cheat technology on our Platforms.

 

4.        HOW WE USE YOUR INFORMATION

We use your Personal Information and non-personal information, both individually and combined together, in the following ways:

A.        To operate our business and to enhance and personalize your gaming experience including to:             

_               Operate, improve, and develop our Apps, Platforms, and Services;

_               Populate online leaderboards and enable online matchmaking;

_               Help you find your friends or tell your friends about Playsimple Apps, Platform or Services;

_               Facilitate sharing on social networks;

_               Serve and measure the effectiveness of advertising;

_               Measure the health of our Services;

_               Set up and maintain accounts you register for;

_               Provide gaming experiences that you may like;

_               Set up loyalty programs;

_               Facilitate your gameplay on multiple devices when available;

_               Identify, fix, and troubleshoot bugs and service errors;

_               Provide software updates;

_               Activate or authenticate your games and save game progress and statistics;

_               Adhere to your preferences and to deliver dynamic content; and

_               Help keep our Services safe and fair, resolve disputes, investigate and help curb fraud and illegal behavior, comply with the law, and to enforce our agreements and policies.

B.        To provide you support, including to:

_               Help identify and troubleshoot problems with your account or games;

_               To survey your opinions through surveys or questionnaires;

_               Communicate with you and respond to your specific requests or questions; and

_               Manage and send you confirmations and important information about your account, Platform, purchases, subscriptions, and warranties.

C.        To personalize our communications with you, including to:

_               Present offers and/or information relating to games you might like;

_               Make recommendations to you; and

_               Personalize advertising for you and deliver targeted marketing, updates on our Services and promotional offers.

 

5.         INFORMATION WE SHARE WITH THIRD PARTIES

We do not share Personal Information that directly identifies you (such as your name, e-mail or postal address) with independent third parties without your consent, unless it is either required by law or we determine that disclosure is reasonably necessary to enforce our rights, property or operations or to protect our Users or third parties or for providing our Services to you and to fulfill our obligations under this Privacy Policy or any related agreement. We may share anonymous or aggregated information, or other data that does not directly identify you, with third parties, for instance your persona on leaderboards or to show trends about use of our Platform.

We employ third parties located in and outside of your country of residence (including outside of the European Economic Area (EEA)) to collect or process Personal Information on our behalf for various reasons, such as  facilitating credit card processing, or sending emails. When our third-party agents or service providers collect or receive your Personal Information, we require that they use this information only on our behalf for purposes consistent with this Privacy Policy and shall be bound by confidentiality provisions to protect the confidentiality of your Personal Information and shall not share your Personal Information without our prior written consent. We do not knowingly disclose Personal Information about children under 18 years of age to independent third parties even with consent.

However, in the event of a reorganization, divestiture, merger, sale or bankruptcy, we may transfer all information we collect to the relevant third party and will obtain your consent to do so if required by law.

We do not control information sent from your browser to third parties, such as advertising networks and analytics companies that receive information in the normal course of your Internet activity. When third party technologies or social tools are integrated on to our Platform, those third parties may collect information when you use our Platform. An example is the Facebook "Like" button.

 

6.         HOW WE HOLD YOUR INFORMATION

Personal Information we collect may be stored and processed for the purposes set out in this Privacy Policy in the United States or any other country in which Playsimple, its subsidiaries, or third party agents operate. By using our Platforms, you consent that your Personal Information may be transferred to recipients in the United States and other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship.

 

7.         ACCESSING, CORRECTING AND DELETING YOUR INFORMATION

Upon request, we will provide you with the information about whether we hold any of your Personal Information. If your Personal Information changes, or if you no longer desire our Services, you may correct, update, delete inaccuracies, or delete your Personal Information by contacting us at support@playsimple.in. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why. We will respond to your access request within a reasonable timeframe but within forty-five (45) days from the date of receiving your request.

 

8.         HOW WE COLLECT YOUR PERSONAL INFORMATION

Our Website, Platform and the App use an SSL certificate as an added security measure. We require username and passwords for our employees who can access the Personal Information of Users that we store and/or process on our Platforms and servers. In addition, we actively prevent third parties from getting access to the Personal Information of Users that we store and/or process on our Platforms and servers. We will implement reasonable security measures every time you (a) place an order, or (b) enter, submit, or access your information, (c) register, or (d) access our Platforms, on our Website and the Apps.  

A.        DATA SECURITY MEASURES.

 

  1. Security Measures.  We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure server behind firewalls.   The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a Password for access to certain parts of our Platform, Website, and/or the App, you are responsible for keeping this Password confidential. We ask you not to share your Password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Platforms, Website, or the Apps. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Platforms, Website, or the Apps.
  2. We and you agree to comply with all applicable Indian security laws.
  3. We and you agree to comply with all applicable Indian consumer protection laws.
  4. Data Breach.  In the event of a personal data breach, we will notify the User within forty-eight (48) hours via (i) email and/or (ii) our notification system on our Website and/or the App.

 

9.         DATA RETENTION

We retain your information for as long as your Account is active or as needed to provide you our Services.  We will also retain and use your information as necessary to comply with any legal obligations, to resolve disputes, and to enforce our agreements with the Users.

 

10.       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 contacting 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.

 

11.       YOUR CHOICES AND CONTROL

We give you meaningful choices when it comes to important uses and collection of information. For example, you can update your account information and preferences, choose to opt in or out of Playsimple’s marketing emails and choose whether to share your information with select Playsimple partners. If you would like to opt out at any time after granting approval, contact the support team from Playsimple at support@playsimple.in.

You may deactivate your Playsimple Account or delete the Personal Information associated with your Account by contacting support@playsimple.in. If you do so, you will no longer have access to the Playsimple Services associated with your Account. Note that Playsimple may retain information needed to resolve disputes, enforce our User agreements, protect our legal rights, and comply with technical and legal requirements and constraints related to the security, integrity and operation of our Platform. Otherwise, we will retain your Personal Information for as long as reasonably necessary to provide you Services, create and improve our Platform, comply with the law, and to run our business.

 

12.       THIRD PARTY SERVCES AND THIRD PARTY SERVICE PROVIDERS

Our Website and Platforms may contain advertising or third-party services (such as the Facebook Like button or links to third-party websites). If you click on those links, including an advertisement, you will leave the Playsimple Website and go to the website you selected. If you visit a third-party website or use a third-party service, you should consult that website's privacy policy.

We will not allow third-party service providers to access your Personal Information except for our sub-contractors and sub-processors, who need such access to enable us to provide our Services to you and to fulfil our obligations under our contract with you and who will be bound by confidentiality provisions to protect the confidentiality of your Personal Information and to not share such Personal Information without our prior written consent. Currently our sub-processor consists of Amazon Web Services who host our Platforms. If we add additional sub-processors, we will revise this Privacy Policy and notify you as set forth under Section 12 below.

 

Name of Third-Party Service Provider

Contact Information

Amazon Web Services, Inc. 

Website: https://aws.amazon.com/premiumsupport/knowledge-center/aws-phone-support/

Address: 410 Terry Avenue North, Seattle, WA 98109-5210 USA

 

 

Additionally, if you have any questions or concerns about our third-party service provider, please email us at support@playsimple.in. 

 

13.       CHANGES TO OUR PRIVACY POLICY

We may update this Privacy Policy from time to time, so please review it frequently. We will notify you of material changes to this Privacy Policy via a notice on our home page (www.playsimple.in) fifteen (15) days before they go into effect. Your continued use of our Platform or Services means that you accept the changes. Once you accept this Privacy Policy, we will not enforce future changes we deem in good faith to be material absent your express agreement to the changed terms. If you are asked to affirmatively accept material changes to this Privacy Policy and you decline to do so, you may not be able to continue to use the Platforms or Services provided.

 

14.       OPT-OUT OF TARGETED ADVERTISING

You can opt-out of interest-based advertising on the Apps by checking the privacy settings of your Android, iOS or Amazon device and selecting "limit ad tracking" (Apple iOS) or "opt-out of interest based ads" (Android) or disabling Interest based Ads(Amazon).

 

15.       ACCESS THE PERSONAL INFORMATION WE HOLD ABOUT YOU

If you wish to obtain a list of the Personal Information we hold of you, please send in a request via email to support@playsimple.in. We will provide you a copy of your Personal Information in an electronic format.

 

16.       CALIFORNIA CONSUMER PRIVACY ACT 

 

This Section supplements the information contained in this Privacy Policy and applies solely to all visitors, Users, and others to our Website, Platforms, Apps and uses our Services, who reside in the State of California (“consumers” or “you”). We adopt this Section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Section. 

  1. Right to Request Personal Information. Upon request, we will provide you with (i) a list of all Personal Information that we have collected on you, (ii) from whom we obtained such Personal Information, (iii) the reason why we collected such Personal Information, and (iv) with whom (if any) we have shared such Personal Information. If we start selling your Personal Information or disclose your Personal Information to third parties, upon request, we will provide you with (i) a list of the Personal Information that we have collected on you, (ii) a list of the Personal Information that we sell or disclose to others on you, and (iii) to whom we have sold or disclosed your Personal Information. A consumer can make such a request only twice in a 12-month period. 

 

We require such Personal Information to be able to provide our Services to you. 

  1. Disclosure of Personal Information. We share your Personal Information with service providers, e.g., billing and collection agents, who enable us to provide our Services to you.

 

  1. Right to have Personal Information Deleted. Upon request, we will delete all of your Personal Information that we have collected on you and will direct our Service Providers to also delete all of your Personal Information. But note that if we do delete all of this Personal Information, you will no longer be able to use our Services.

 

  1. Non-Discrimination Right. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
  1. Deny you our Services.
  2. Charge you different prices or rates for goods or Services, including through granting discounts or other benefits, or imposing penalties.
  3. Provide you a different level or quality of Services.
  4. Suggest that you may receive a different price or rate for our Services or a different level or quality of Services.

 

  1. Financial Incentives.        However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

 

  1. Contact Information. You may contact us at support@playsimple.in to (i) make a Personal Information Request, (ii) lodge a complaint about our use or storage of your Personal Information, (iii) ask us to delete such Personal Information, and/or (iv) discuss our Privacy Policy and/or anything that has to do with it. We will respond within forty-five (45) days of receiving such request or query. Additionally, in order for us to respond to your request or query, we will need to collect information from the requesting party to verify their identity.

 

  1. Under 16. We will not sell your Personal Information if you are under the age of 16 unless we have the consent of your parents or your guardian nor will we sell it if you ask us not to do so.

 

  1. Opt Out Right.  Upon your request, we will stop selling your Personal Information (sometimes called your Opt Out Right). You may send the request to Opt Out to support@playsimple.in.

 

  1. Personal Information that we Store.  For your information, we store/collect the following Personal Information on you: name, email address, online contact information, phone number, persistent identifiers, photograph, username combined with a password or a security question and answer, video or audio files containing an image or voice.

 

17.       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.

 

 

18.       CONTACT US

If you have comments or questions about this Privacy Policy and our privacy practices, you may contact us at support@playsimple.in.

 

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.


 © 2014 Playsimple Games Private Limited, All rights reserved.