PRIVACY POLICY

Last modified date: 26 July 2024

Our Mission

In this section, you may initially learn more about who we are and how to get in touch with us.At Pinoy Pool, we offer a variety of free online games and may collect your personal information during gameplay. If you have any inquiries about how we handle data, your rights, or if you wish to raise any concerns or complaints, feel free to reach out to us via email at help@pp-casual.com, or write to us using the address provided in our Privacy Policy.

Information We Gather

We gather personal information directly from you, such as when you engage in gameplay or sign up for an account. Additionally, we generate data about your interactions with our games, including gameplay and logging activities. If you choose to log into a game using your social media credentials, we will obtain details about you, including your name, profile image, and email address. Moreover, we receive information from external sources like social media networks.

Utilizing Your Personal Data

Your information serves to furnish you with our games, offer assistance, evaluate your usage, and enhance our services. Furthermore, we employ your data to address any inquiries you may have. Periodically, we may send you promotional emails, push notifications, or display targeted advertisements within our games. You have the option to discontinue receiving these communications at any time by opting out or adjusting your browser or device settings.

Sharing Your Personal Information

To fulfill the objectives outlined in this Privacy Policy, we collaborate with third-party entities, such as providers of support services like game servers, customer support systems, and game analytics. We also engage with specific advertising partners to display advertisements to you. Moreover, we share your information internally within our organization and as mandated by legal requirements.

Location of Personal Information Processing

We process your information in where our games operated, managed either by us or our service providers. These locations encompass Philippines, USA, Singpore and other major operation destinations.

Your Entitlements

You have the entitlement to access, obtain a copy of, or erase your information, as well as to restrict the handling of your information. Additionally, you possess the right to oppose our utilization of your information for specific purposes, including personalized marketing and advertising.

Modifications to the Privacy Policy

All revisions or amendments to this Policy will be posted on this platform. In the event of substantial changes, we will inform you via the website or within the game interface.

Briefing

This Policy outlines your options and our procedures concerning your Information (as defined below). In this document, references to "Pinoy Pool," "we," or "us" pertain to the Pinoy Pool Service Provider. We determine the reasons for using your Information and how it is utilized, thereby serving as the data controller in certain jurisdictions. For the purposes of this Policy, "Information" refers to any details relating to an identified or identifiable individual. This encompasses data pertaining to your engagement with: (a) our mobile games ("Mobile Games"), and; (b) the games available for download on the official Pinoy Pool website linked to this Policy ("Website"). By participating in the Mobile Games and Website Games (collectively, the "Games"), you acknowledge and accept our rules and policies governing the handling of your Information. You understand that we collect, process, utilize, and retain your Information as outlined in this Policy. If you do not consent to this Policy, refrain from playing any of the Games. Should you alter your decision in the future, discontinue gameplay and exercise your rights concerning your Information as delineated in this Policy.

1. COLLECTION OF PERSONAL DATA

1.1We will process and utilize the following Information pertaining to you:

(1)Information provided by you:

Registration details: If you have a registered Pinoy Pool account, you supplied us with your email address, password, date of birth, avatar, and username upon opening the account.

Information gathered via customer support channels: When you engage with our customer support through live chat, we may request

(a) your full name, username, and email address, and

(b) any additional details you provide to facilitate assistance, such as Game ID, team name, device make and model, advertising ID, transaction records, or device language.

(2)Information provided during gameplay: When participating in our games, you may be asked to select a username.

(3)In-Game Communication: Certain games allow player interactions through chat, audio, or video calls. We process relevant information from such interactions, including timestamps and chat content. For some functionalities, third parties may provide these services, limiting our access to communication content.

(4)Survey-generated data: We may request your participation in surveys regarding your user experience. The specifics of collected information vary by survey, typically covering topics such as interests, habits, opinions on products and services, and preferences for future offerings. This includes ratings, opinions, preferences, questions, images, and responses associated with surveys.

(5)Information specifically for Pinoy Pool:

Email address.

1.2Automatically collected or generated information when playing games:

(1)Identifiers: IP address, advertising ID, Adjust ID, HTTP header, device ID, third-party app IDs (apptoken), unique Pinoy Pool ID, and location data at country and city levels, as well as device details like model, brand, language, and operating system.

(2)Cookies: We utilize cookies and similar technologies (e.g., web beacons, log files, scripts, and eTags) to enhance your gaming experience. Cookies are small files placed on your device to enable specific features and functionalities. You have the choice to accept or disable these cookies. While you can opt-out of installing cookies, certain game functionalities may be impaired as a result.

(3)Information on game usage: Game ID, timestamps for installation and uninstallation, event dates and times, gameplay duration, scores achieved, interactions with our teams, engagement with advertising and promotions, transaction records, and evidence related to the use of cheating software or modified game versions.

1.3Information Obtained from third parties:

(1)Registration through third-party platforms: If you register using a third-party account (e.g., Facebook, Google, or Apple), we receive your name, profile picture, third-party ID, optional email address, and optionally, your friends list.

(2)Payment processing providers: When you conduct transactions within our games, we receive specific details from our payment service providers. This includes transaction ID, country, payment method used, items purchased, currency, transaction value, and timestamp of the payment.

(3)Analytics data: In certain games, we incorporate analytics software from third-party providers. This enables us to receive reports that aid in optimizing game features and events personalized to each user. These reports include your user ID and information regarding your in-game activities.

(4)Advertising partners: We receive information from third-party advertising providers, which includes user IDs and data regarding your interactions with advertisements displayed in our mobile games.

(5)Mobile measurement partners: Information is received from third parties to facilitate the monitoring of our marketing campaign performance and to detect any fraudulent activities associated with these campaigns. This information may encompass advertising IDs, IP addresses, location data, and transaction details.

(6)Communication services: In games featuring functionalities like chat, audio, or video calls provided by third parties, we obtain information about you from these services. This includes third-party IDs, usernames, and, in some instances, the content of communications.

2.CHILDREN

Our games are intended for players who are 18 years old or older. If you are younger than 18 (a "Child"), we suggest that you ask your parents or legal guardian ("Parents") for permission before playing our games. It would be helpful to review this Policy together with your Parents so they can assist with any parts that may be confusing. If you are a Parent and have concerns about your Child’s use of our games or if you have any questions, please reach out to us using the contact information provided in section 7 below.

3. How We Utilize Your Personal Information

3.1We use your information for the following purposes:

(1)Provision of Games: We use your information to fulfill our contractual obligations by allowing you to create accounts, play games (including as a guest), save your progress, play games with friends, and communicate via in-game chat, audio, or video calls where applicable. This includes enabling purchases via Google Play, IOS App Store, and maintaining purchase records. Information processed includes registration details, data provided during gameplay, identifiers, content generated during gameplay, and details about your game usage.

(2)Enhancing and Monitoring Game Usage: Improving our games for our customers is a legitimate interest. This involves automatically collecting or generating information about your activities in the games, as well as data related to your device such as battery status, Wi-Fi signal strength, device make and model, operating system, and available storage space.

(3)Providing Support and Addressing Requests: When you seek support, we use your information to create support accounts, respond to and resolve queries and complaints, and facilitate support activities (e.g., assisting with password retrieval). This aligns with our contractual obligations. Information processed includes registration details, identifiers, device information like Wi-Fi strength and available storage, and any additional information gathered through customer support channels.

(4)Conducting Analytics: Analyzing game usage, advertising campaigns, and user interaction is in our legitimate interests. This involves processing automatically collected or generated information about your game activities or interactions with our advertising efforts to (a) create anonymized and aggregated data, (b) identify user segments with specific characteristics or interests, and (c) perform predictive analytics regarding your interests.

(5)Sending In-Game Updates and Offers: We display promotional offers and information about virtual items available for purchase in-game, personalized based on gameplay patterns, location, device data, and in-game interactions. This is done in our legitimate interest.

(6)Providing Advertising: Presenting advertisements and recommendations within our games or elsewhere, including ads for our own games or other services of potential interest to you. These ads may be personalized for you. Where consent is necessary, we obtain it; otherwise, for contextual advertising or when consent is not required, we proceed based on our legitimate interests. You can withdraw consent for targeted advertising via game settings or follow instructions in our Cookie Policy for browser and device settings adjustments.

(7)Preventing Fraud and Managing Legal Obligations: Protecting users from online abuse and other inappropriate or illegal activities, monitoring game usage to detect fraud or activities compromising game integrity, addressing fraud and concerning behaviors, defending against legal claims or disputes, and enforcing our terms and policies. Information processed includes details you provide, automatically collected data, and information received from third parties.

(8)Conducting Surveys: Occasionally, we may invite you to participate in surveys to better understand our user base and improve our games. This is in our legitimate interest. Participation involves processing registration details and other information gathered through survey responses.

4. How We Share Your Personal Information

4.1We disclose your information to various third parties, including:

(1)Other Players and Users: Your profile information, in-game activities, and any shared chat data are visible to other players and users.

(2)Vendors and Service Providers: We engage various service providers to facilitate game provision, such as cloud service providers like Amazon Web Services for data storage, and customer support solutions such as Livechat based in the U.S. for managing customer inquiries.

(3)Analytics Providers: We collaborate with analytics, segmentation, and mobile measurement service providers like Adjust GmbH in Germany to gain insights into our user base.

(4)Social Media Integration: We integrate certain Facebook and Google software to enhance social features in the game, accessing features like friend lists and profile pictures.

(5)User Acquisition Partners: We work with partners for user acquisition, utilizing identifiers like Advertising IDs or Facebook IDs to participate in programs like Custom Audience and Lookalike Audience to display targeted ads on partner websites.

(6)Advertising Partners: As an ad-supported service, we share certain information with advertisers to deliver targeted ads within our games and measure ad effectiveness. This includes sharing advertising identifiers and user characteristics.

(7)Payment Processors: For mobile games, we use payment processors such as Google (for Android) and Apple App Store payments (for iOS), which handle the processing of your information according to their respective privacy policies.

(8)Group Companies: We share information with entities within our corporate group.

(9)Legal and Judicial Bodies: We disclose information if legally required, to comply with legal obligations, enforce our terms, investigate potential violations, detect fraud, address security issues, or protect rights and safety as required or permitted by law.

(10)Corporate Transactions: In the event of a merger, acquisition, bankruptcy, reorganization, partnership, asset sale, or similar transaction, your information may be disclosed as part of the transaction.

5.THIRD PARTY INFORMATION COLLECTION

When you access any games through a third-party platform such as Facebook or Google ("Third-Party Services"), it's important to note that these services may collect additional information about you. This includes information you directly share with them or data they gather about your game usage, all governed by their own terms and privacy policies. The privacy practices outlined in this policy do not extend to Third-Party Services. Links provided within the games to Third-Party Services do not imply our endorsement or review of those services.

6.SECURITY

While we implement security measures to safeguard the privacy and integrity of your information, it's important to note that transmitting information over the internet is not entirely secure. We also employ additional precautions to protect your information and limit the data we process. For instance, during the registration process when you provide your password, we set up a database for added security.

7. LOCATION OF PERSONAL INFORMATION PROCESSING

We process your information in countries where our games or services operate, including the United States of America, Philippines, and other locations. If we need to transfer your information outside the UK or the EEA in the future, we ensure it goes to countries recognized by the EEA or the UK as having adequate protection measures. In cases where adequacy hasn't been established, we use standard contracts approved for use in the EEA or the UK to protect your information during its transfer outside these regions.

8. RETENTION PERIOD FOR YOUR INFORMATION

We retain your information for the duration of your registration or active use of our games, and for up to three years after your last interaction with the games. When we delete information, we ensure it is irrecoverable or irreproducible, and any electronic files containing information are permanently erased.

9. YOUR RIGHTS

If both our operation region and you are reside in the EEA, UK, Switzerland, Brazil, or are a legal resident of California in the U.S., you have specific rights regarding your information. Californian residents can refer to Addendum 1 – California Privacy Rights. For residents of the EEA, UK, Switzerland, and Brazil, details on when these rights apply are provided below. To exercise these rights, please contact us via email at help@pp-casual.com.

Access: You have the right to access your information and receive an explanation of how we use it and with whom we share it. This right is not absolute; for instance, we cannot disclose trade secrets or provide information about other individuals.

Erasure: You have the right to request the deletion of your information. We may need to retain some information where legally justified, such as for defending legal claims, respecting freedom of expression, or due to overriding legitimate interests. We will inform you when this is applicable. If your information is held by a third-party data controller, such as an advertising partner or payment processor, we will make reasonable efforts to inform them of your request. However, we recommend contacting them directly per their privacy policies to ensure your data is erased.

Objection and Withdrawal of Consent: You can (i) withdraw consent previously provided, or (ii) object to our processing of your information where it is based on legitimate interests (refer to "How we use your personal information" above). You can exercise this right as follows:

To stop receiving personalized advertising: (a) adjust settings on the Website via Privacy Settings; (b) for Mobile Games, withdraw consent within in-app settings.

To stop receiving marketing emails: use the unsubscribe link at the bottom of each email.

To stop receiving push notifications: adjust settings on your device or browser.

Portability: You have the right to receive a copy of your information processed based on consent or contract in a structured, commonly used, and machine-readable format, or to request its transfer to a third party.

Correction: You have the right to rectify any inaccurate information we hold about you.

Restriction: In certain circumstances, you have the right to limit our processing of your information, except for storage purposes.

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10. CONTACT AND COMPLAINTS

We value your questions, comments, and requests regarding this Policy. Please direct them to help@pp-casual.com. If you have a complaint about how we handle your information, please contact us at help@pp-casual.com, and we will strive to address your concerns promptly. You also have the right to lodge a complaint with a data protection authority, regardless of contacting us.

11. CHANGES

Any revisions or updates to this Policy will be posted on this platform. In cases of substantial changes, we will notify you via the website and within the game interface.

12. SDK PARTNERS

We collaborate with various partners whose SDK are integrated into some or all of our games. To understand their privacy practices and how you can exercise your data subject rights, please refer to the following privacy policies. This list was last updated on July 26, 2024.

13. NO REAL MONEY

All virtual properties in this game do not contain any real value in reality, and no one is allowed to use them for any activity that generates real value.

ADDENDUM 1 - CALIFORNIA PRIVACY RIGHTS

The terms of this Addendum pertain to California residents under the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its regulations, as may be amended or replaced over time ("CCPA"). In this addendum, "Personal Information" refers to data that identifies, relates to, describes, could reasonably be associated with, or could reasonably link, directly or indirectly, to a specific consumer or household, or as otherwise defined by the CCPA. Personal Information excludes information lawfully available from government records, deidentified or aggregated data, or other information outside the CCPA's scope.

1.COLLECTION AND DISCLOSURE OF PERSONAL INFORMATION

1.1 Over the past 12 months, through your use of the Games, we may have gathered and shared various categories of Personal Information related to you:

(1)Identifiers, such as name, email address, IP address, device identifiers, advertising ID, Pinoy Pool ID, and profile photos. This data is collected directly from you or your device. If you registered through a third-party account (like Apple, Facebook, or Google), we may also have collected your third-party ID, name, and avatar from those services.

(2)Internet or other electronic network activity information, including your usage of in-game features, events, interactions with in-game advertising, and other related activities. This information is gathered from selected third-party analytics providers and advertising partners.

(3)Geolocation data, including city-level location details. This data is collected directly from you or your device, as well as from third-party services if you registered through them.

(4)Commercial information, such as records of products or services purchased, obtained, or considered. For example, your Apple ID number for Apple purchases and your postcode and state for Google services. This information is collected directly from you or your device, and also from our payment processors.

1.2 During the last twelve months, we have collected Personal Information from the following sources:

(1)Directly from you/your devices.

(2)Advertising networks and other partners involved in advertising.

(3)Analytics providers.

(4)Social networks, within the limits of your permissions and as applicable.

1.3 We collect Personal Information for the following purposes:

(1)Operating and administering the Games.

(2)Improving the Games.

(3)Communicating with you.

(4)Serving advertisements.

(5)Security and verification purposes, including fraud prevention and detection.

(6)Addressing technical issues and bugs.

For further details on the specific uses of each type of Personal Information, please refer to the "How We Utilize Your Personal Information" section in the main Privacy Policy.

1.4 We may disclose Personal Information to the following types of entities:

(1)Other players and users, who can view your profile information, in-game activities, and any other data you choose to share, such as chat messages.

(2)Our affiliate companies within our corporate group, who process Personal Information to operate the Games.

(3)Marketing and advertising partners, who use your information to deliver advertisements within the Games and on other platforms.

(4)Other service providers who operate on our behalf, and who are contractually restricted from retaining, using, or disclosing Personal Information for any purpose other than providing services to us.

(5)Regulatory, judicial authorities, and law enforcement agencies.

(6)Entities that acquire all or substantially all of our business.

For additional information on how we disclose Personal Information, please see the "How We Share Your Personal Information" section in the main Privacy Policy

2.Sales of Personal Information / Notice of Right to Opt-Out

Over the past year, we have utilized third-party advertising and tracking technologies within our Games to gather information about you, your devices, and your usage of our Games. This information is shared with selected third parties, such as advertising partners, who utilize it to target online advertisements towards you. You can opt-out and exercise control over these technologies at any time by adjusting settings in the Privacy Settings, and for certain Mobile Games, through in-app settings. Alternatively, you may submit an opt-out request via our web form.

2.1 Rights Under the CCPA

The CCPA grants California residents specific legal rights, subject to certain exemptions. If you are a California resident and no exemptions apply to you or your Personal Information, you have the right to:

(1)Submit a verifiable request for the following information pertaining to the preceding twelve months:

The categories of Personal Information collected, sold, or disclosed about you.

The sources from which Personal Information was collected.

The purposes for collecting or selling Personal Information about you.

The categories of third parties to whom Personal Information was disclosed, and the               categories of Personal Information disclosed (if applicable), and the purpose for disclosing               Personal Information about you.

The specific pieces of Personal Information collected about you.

(2)Submit a verifiable request for the deletion of Personal Information collected from you.

Be free from discriminatory practices for exercising your rights under the CCPA, including providing different levels or qualities of service or denying goods or services to you when you exercise these rights, subject to certain limitations.

We strive to fulfill all verifiable requests within 45 days under the CCPA. If necessary, extensions up to an additional 45 days will be accompanied by an explanation for the delay.

2.2 How to Exercise Your Rights

You can exercise your rights by emailing us at help@pp-casual.com. To opt-out or update your preferences, you may do so through the Privacy Settings on our Website and in-app for certain Mobile Games.

2.3 Verification

Requests for access to or deletion of Personal Information, whether made directly by you or through an authorized agent, are subject to our ability to reasonably verify your identity in accordance with the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your request for access or deletion, please be prepared to provide identifying information (such as your User ID, Game name, etc.) that we can verify against our records to confirm you as the rightful account holder.

2.4 Authorizing an Agent

To authorize an agent to make requests on your behalf for access, deletion, or opt-out, please email us at help@pp-casual.com.

2.5 Shine the Light

We do not rent, sell, or share Personal Information with nonaffiliated companies for their direct marketing purposes as outlined by California’s "Shine the Light" law (Civil Code § 1798.83), unless we have obtained your permission.

2.6 Do Not Track

There is no universally accepted standard for responding to Do Not Track signals, and we do not currently respond to such signals.