Privacy Policy
This
Privacy Policy describes Plinko Master’s practices
for collecting, using, disclosing, maintaining and protecting your personal
information on the media platforms we operate, including the Plinko Master app on the iOS or Android platforms (the
“App”), our Website, or any other platform on which you see this Privacy Policy
(collectively, the “Services”). We will refer to our users as “you” in this
Privacy Policy. This Privacy Policy is incorporated into, and part of,
the Terms of Use (the “Terms of Use”), which governs your use of our Services.
Please
read this notice carefully to understand our policies and practices for
processing and storing your personal information. By accessing and
utilizing our Services, you accept and consent to the practices described in
this Privacy Policy. This Privacy Policy may change from time to time
(see Changes to our Privacy Policy). Your continued access and/or use of
our Services after any such revisions indicates that you accept and consent to
them. Please check periodically for updates.
1. Who We Are
We are Plinko Master Studio Limited (“Plinko
Master,” “we,” “our,” “us”).
Third-Party Links
The platforms on which our Services run may include links to third-party
services, plug-ins and applications. Clicking on those links or enabling those
connections may allow third parties to collect or share data about you. We do
not control these third-party services and are not responsible for their
privacy statements. When you leave our website, we encourage you to read the
Privacy Policy of every other website or app you visit.
2. The Data We Collect About You
We
collect several different types of personal information from you depending on
how you interact with our Services. Personal information means any information
about an individual from which that person can be identified. It does not
include information where the identity has been removed or is not able to be
associated with an individual.
Most of
the information we collect is given to us by you through filling out forms,
registering for an account, or otherwise providing information when
asked. Occasionally, we collect information from your device which helps
us better provide our services to you. Because we may change our website
and the services we offer from time to time, the means and methods to provide
us with personal information may also change. Depending on how you
interact with us and use our services, the personal information we collect may
vary.
We may
process the following types of personal data about you, which we have grouped
together as follows:
Identifiers |
This may include your name (first
and last), a username (or similar identifier), data of birth, gender, and
profile photo if you upload it. |
Contact Information |
This may include your email
address, mailing address, telephone number. |
Virtual Gifts Transaction
Information |
This may include information you
provide for the purposes of sending virtual gifts to you, such as the email
address associated with your account. It also includes the records, amounts
and other information associated with virtual gifts transactions. |
Technical Information |
This may include your IP address
(which may identify your general geographic location), device identifier
data, the type of device you use, your operating system and version, the
URL’s of our web pages that you visit, the URL’s of referring and exiting
pages, the pages you view, the time spent on a page, the number of clicks
made, the platform type, and generalized, non-specific location data. |
Usage Information |
This may include information about
the game features you use, your game preferences, the types of games you
play, how long you use our Services, and how you use our Services. |
Account Information |
This may include your username and
password, your preferences, feedback and survey responses. |
Marketing and Communications
Information |
This may include your
communications preferences in receiving marketing from us and/or third
parties. |
Geolocation Data |
We collect your geolocation data
whenever you choose to access the rewards or wallet features and play our
games. We use this data to determine our legal obligations in that
jurisdiction. |
3. How We Collect Your Personal Information
We
collect information about you in many different ways. Most of the time we
collect through your direct interactions with our Services, but we may also
automatically collect personal information from your devices, and occasionally
from third parties or publicly available sources.
We
collect information about you in the following ways:
Direct Interactions. When you
interact with our Services, you may provide us your personal information by
filling in forms, communicating with us by email, telephone, text/SMS, post, or
otherwise. This may include personal information you provide when you:
·
Subscribe for
our Services/Register for an Account;
·
Request that the
App be texted to you;
·
Request
marketing be sent to you;
·
Enter a game,
competition, promotion, or survey,
·
Provide us
feedback, requests support, or otherwise communicate with Us.
Automated Collection. As
you interact with our Services, we may automatically collect Technical
Information and Usage Information. We collect these categories of Personal
Information by using cookies, SDK’s, web beacons, and other similar technologies.
Third Parties or Public Sources. We may share and receive personal information about you from
various third parties as follows:
·
Technical
Information and Usage Information from the following parties:
o
Advertising
Networks
·
Contact
Information, Transaction Information, and Technical Information from providers
of technical, communications, and service providers;
·
Social
Networking Posting Tools and Share features. When you visit a page that
includes one of these sharing tools, the third-party company that operates the
tool may be collecting information about your browser, device, and other online
activity through its own technology not controlled by us. Please read their
privacy policies.
·
Identifiers and
Technical Information from Social Networks when you grant us permission to
access data on one or more of those services.
·
Publicly visible
data, such as your social media and other information submitted to social media
or other publicly available media.
4. How We Use Your Personal information
We will
only use your personal information when allowed by law. Generally, we will use
your personal information: (a) where we need to perform the contract we are
about to enter into or have entered into with you; (b) where it is necessary
for our legitimate interests and your interests and fundamental rights do not
override those interests; and (c) where we need to comply with a legal or
regulatory obligation.
Purposes for which we will use your personal information
Below is
a chart of some of the common ways in which we process your personal
information. We have identified what our legitimate interests are where
appropriate. Note that we may process your personal information for more than
one lawful ground depending on the specific purpose for which we are using your
data. Please contact us if you need details about the specific legal ground we
are relying on to process your personal information where more than one ground
has been set out in the table below.
Purpose/Activity |
Type of data (varies depending on circumstances) |
Lawful basis for processing
including basis of legitimate interest |
To register you as a user of our
Services. |
Contact Information Account Information |
Performance of a contract with you. |
Notifying you about changes to our
terms or Privacy Policy. |
Contact Information |
Necessary to comply with a legal
obligation |
To enable you to participate in a
game, contest, competition, survey, or similar event. |
Identifiers Contact Information Technical Information Usage Information |
Performance of a contract with you. Legitimate Interests (to learn how
our users use our Services, to improve our Services, to grow our business). |
To administer and protect our
business and this website (including troubleshooting, data analysis, testing,
system maintenance, support, reporting and hosting of data). |
Identifiers Contact Information Technical Information Usage Information |
Necessary for our legitimate
interests (for running our business, provision of administration and IT
services, network security, to prevent fraud and in the context of a business
reorganization or group restructuring exercise) |
To provide you with information and
marketing communications about our products and services. |
Identifiers Contact Information Marketing and Communications
Information |
Consent Legitimate Interests (in marketing
goods or services in which you may have a personal interest based on our
ongoing business relationship). |
To provide you with third party
offers that may be relevant to you. |
Identifiers Contact Information Marketing and Communications
Information |
Consent |
To respond to customer service
requests including order status and chat communications. |
Identifiers Contact Information Technical Information |
Legitimate Interest (for running
our business, provision of administration and IT services, network security,
to prevent fraud and in the context of a business reorganization or group
restructuring exercise) Consent |
5. Marketing and Advertising Practices
We may
reach out to you in different ways, for example, to tell you about new
features, games, or sweepstakes on the App we think you’d be interested in, or
to show you how to use a particular feature we think you may enjoy. However,
you can also let us know that you’d rather not hear from us with this type
of communication.
Promotional Offers From Plinko
Master. We may use any of the
categories of personal information we collect to make decisions about what we
think you may desire or need as our consumer. We will only make these marketing
decisions if you agree to receive email marketing from us. In all cases, we
allow you to opt-out of receiving marketing communications from us.
Interest Based Advertising. Plinko Master uses advertising to help fund our services
and we utilize and numerous advertising technology platforms to help deliver
relevant advertising to you. Plinko Master and the
technology service provider may collect, receive, or use your personal data in
connection with our use of the platform in order to provide interest-based
advertising to you. In such cases the advertiser is acting as a controller of
the data for its own purposes.
Most of
the third-party advertising and data companies we work with,
including subscribe to the DAA Principles and/or are members of the
Network Advertising Initiative (“NAI”). To learn more about the information
collection practices of NAI members and your related opt-out choices, please
visit the NAI’s website here. For more on EU online choices, please visit the EU
online choices website here. You can opt out of interest-based advertising from
Google by visiting the About Google Ads page
or opt out of the DoubleClick cookie by installing the DoubleClick opt out extension. For information about how Google uses data from DoubleClick for
Publishers, click here.
Please
refer to the privacy policies of our advertising partners for more information
on how to exercise your rights and control your advertising choices. Our
advertisers include the following:
·
MoPub: https://www.mopub.com/legal/privacy/
·
AppLovin: https://www.applovin.com/privacy/
·
Facebook: https://www.facebook.com/about/basics/advertising
·
Unity: https://unity3d.com/legal/cookie-policy#cookies
·
Vungle: http://vungle.com/privacy
·
Fyber: https://www.fyber.com/privacy-policy/
Mobile App Advertising and Tracking. Plinko Master, our authorized service
providers and/or other third-party partners (listed above)
involved in the delivery of advertising you receive through our App may
collect information about your mobile device, including your mobile device’s
advertising identifiers and the names and IDs of apps you have installed, as
well as information about how you use our mobile applications and other
unaffiliated applications. We and our partners use this information to enable
interest-based advertising you receive through our Services and within
third-party apps and other marketing channels. Depending on your device and
operating system, you may be able to reset your mobile device’s advertising
identifier to limit this data collection or prevent the collection of usage
data across unaffiliated applications for interest-based advertising purposes
by accessing the privacy settings on your mobile device. Each operating system,
iOS for Apple devices, Android for Android devices and Windows for Microsoft
devices, provides its own instructions. Visit the privacy settings for your
mobile device for more information.
In
addition, you may see our services advertised in other services. After clicking
on one of these advertisements and installing our app, you will become a user
of our Service. In order to verify the installs, a device identifier may
be shared with the advertiser.
Social Media Advertising. Plinko Master also runs other kinds of online ad campaigns
on social networking websites and other non-Plinko
Master websites and apps. Some of these ads may be based on information we have
about users. If Plinko Master provides information to
a website or app for these advertising purposes, the information may only be
used to display the Plinko Master ad. Please see the
privacy policy of the website or app where a Plinko
Master ad is shown for more information about its privacy practices and privacy
choices it may offer.
6. Disclosures Of Your Personal information
From
time to time, we may need to share your personal information with others,
including in the following circumstances.
Disclosures to the Public. Some
of your personal information will be shared with the general public, including your
first name and last name initial, city, state, and country. When information is
made publicly available it may be accessed by anyone with access to the
platform to which the information is posted. It may also be indexed by
third-party search engines, and be imported, exported, distributed, aggregated,
and redistributed by others without our knowledge.
Third Party Service Providers. We may share your personal information with third party service
providers who perform various functions to enable us to provide our services
and help us operate our business, such as website design, sending email
communications, fraud detection and prevention, customer care or performing
analytics. Our contracts with these third parties require them to maintain the
confidentiality of the personal information we provide to them, only act on our
behalf and under our instructions, and not use personal information for
purposes other than the product or service they’re providing to us or on our
behalf.
With our Affiliates and Partners. When participating in events or activities that we offer along
with our partners and/or affiliates, you may be asked to share personal
information with those affiliates and/or partners. For example, a game,
contest, competition, contest, sweepstake or other offering may be co-sponsored
by another company or companies. In such a situation, the information we obtain
from you in connection with such contest, sweepstake or offering may be shared
with our co-sponsor, unless you instruct us not to (which may result in you not
being able to participate). In some of those cases, we may act as
co-controllers of your personal information, depending on the circumstances.
With Unaffiliated Controllers. In some cases we may transfer personal
information to unaffiliated third-party data controllers. These third parties
do not act as agents or service providers and are not performing functions on
our behalf. We may transfer your personal information to third-party data
controllers for the following purposes: 1) to provide you with third-party
offers; 2) to provide us information about the quality of our services
offerings. We will only provide your personal information to third-party data
controllers where you have not opted-out of such disclosures, or in the case of
sensitive personal information, where you have opted-in if the disclosure
requires consent. We enter into written contracts with any unaffiliated
third-party data controllers requiring them to provide the same level of
protection for your personal information that is required of us. We also limit
their use of your personal information so that it is consistent with any
consent you have provided and with the notices you have received.
Protection of Plinko Master and Others. We may share personal information when we believe
it is appropriate to enforce or apply our Terms of Service and other
agreements; or protect the rights, property, or safety of Plinko
Master, our products and services, our users, or others. This includes
exchanging information with other companies and organizations for fraud
protection and risk reduction. This does not include selling, renting,
sharing, or otherwise disclosing personal information of our customers for
commercial purposes in violation of the commitments set forth in this Privacy
Policy.
Response to Subpoenas and Other Legal Requests. We may share your information with courts, law
enforcement agencies, or other government bodies when we have a good faith
belief we’re required or permitted to do so by law, including to meet national
security or law enforcement requirements, to protect our company, or to respond
to a court order, subpoena, search warrant, or other
law enforcement request.
Sale of Our Business. If
we sell, merge, or transfer any part of our business, we may be required to
share your information. If so, you will be asked if you’d like to stop
receiving promotional information following any change of control.
With your Consent. Other than as set out above, we will provide you with notice
and the opportunity to choose when your personal information may be shared with
other third parties.
7. Data Security
We have
put in place appropriate security measures to prevent your personal information
from being accidentally lost, used or accessed in an unauthorized way, altered or
disclosed. In addition, we limit access to your personal information to those
employees, agents, contractors and other third parties who have a business need
to know. They will only process your personal information on our instructions
and they are subject to a duty of confidentiality. We have put in place
procedures to deal with any suspected personal information breach and will
notify you and any applicable regulator of a breach where we are legally
required to do so.
8. Data Retention
We will
only retain your personal information for as long as necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying any
legal, accounting, or reporting requirements. To determine the appropriate
retention period for personal information, we consider the amount, nature, and
sensitivity of the personal information, the potential risk of harm from
unauthorized use or disclosure of your personal information, the purposes for
which we process your personal information and whether we can achieve those
purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data (see “EU
Data Subjects Legal Rights”). In some circumstances we
may anonymize your personal information (so that it can no longer be associated
with you) for research or statistical purposes in which case we may use this
information indefinitely without further notice to you.
9. International Data Transfers
Plinko Master
has its headquarters in Hongkong. Information we collect
from you will be processed in Hongkong. Where we
transfer EU data subject’s personal information to third parties outside of the
European Economic Area (EEA), we rely on appropriate suitable safeguards or
specific derogations recognized under data protections law, including the GDPR.
The European Commission has adopted standard data protection clauses, which
provide safeguards for Personal information transferred outside of the
EEA. We may use Standard Contractual Clauses when transferring Personal information
from a country in the EEA to a country outside the EEA.
10. EU Data Subjects Privacy Rights
EU data
subjects have certain rights with respect to your personal information that we
collect and process. We respond to all requests we receive from individuals in
the EEA wishing to exercise their data protection rights in accordance with
applicable data protection laws.
·
Access,
Correction or Deletion. You may
request access to, correction of, or deletion of your personal information. You
can often go directly into the Service under Account Settings to take these
actions. Please note that even if you request for your personal information to
be deleted, certain aspects may be retained for us to: meet our legal or
regulatory compliance (e.g. maintaining records of transactions you have made
with us); exercise, establish or defend legal claims; and to protect against
fraudulent or abusive activity on our Service. Data retained for these purposes
will be handled as described in Section 9 “Data Retention”, above.
·
Objection. You may object to processing of your personal
information where we are relying on a legitimate interest (or those of a third
party) and there is something about your particular situation which makes you
want to object to processing on this ground as you feel it impacts on your
fundamental rights and freedoms. You also have the right to object where we are
processing your personal information for direct marketing purposes. In some
cases, we may demonstrate that we have compelling legitimate grounds to process
your information which override your rights and freedoms.
·
Restriction. You have the right to ask us to suspend the
processing of your personal information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b)
where our use of the data is unlawful but you do not want us to erase it; (c)
where you need us to hold the data even if we no longer require it as you need
it to establish, exercise or defend legal claims; or (d)
you have objected to our use of your data but we need to verify whether we have
overriding legitimate grounds to use it.
·
Portability. You have the right to request the transfer of your
personal information to you or to a third party. We will provide to you, or a
third party you have chosen, your personal information in a structured,
commonly used, machine-readable format. Note that this right only applies to
automated information which you initially provided consent for us to use or
where we used the information to perform a contract with you.
·
Withdraw
Consent. If we have collected and
processed your personal information with your consent, you can withdraw your
consent at any time. Withdrawing your consent will not affect the lawfulness of
any processing we conducted prior to your withdrawal, nor will it affect
processing of your personal information conducted in reliance on lawful
processing grounds other than consent.
·
File a
complaint. You have the right to file a
complaint with a supervisory authority about our collection and processing of
your personal information.
To file
a request or take action on one of your rights, please contact us at the
contact details provided. You will not have to pay a fee to access your
personal information (or to exercise any of the other rights). However, we may
charge a reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we may refuse to comply with your request in these
circumstances.
We may need to request specific information from you to help us confirm your
identity and ensure your right to access your personal information (or to
exercise any of your other rights). This is a security measure to ensure that
personal information is not disclosed to any person who has no right to receive
it. We may also contact you to ask you for further information in relation to
your request to speed up our response. We try to respond to all legitimate
requests within one month. Occasionally it may take us longer than a month if
your request is particularly complex or you have made a number of requests. In
this case, we will notify you and keep you updated.
11. Children’s Privacy
We are
committed to complying with the laws protecting the privacy of children,
including the United States’ Children’s Online Privacy Protection Act (COPPA).
Our Services are not directed to children under the age of 16. We do not
knowingly collect personal information from children under the age of 16. If we
receive personal information that we discover was provided by a child under the
age of 16, we will promptly destroy such information. If you would like to
learn more about COPPA, visit the Federal Trade Commission home page at http://www.ftc.gov.
12. Changes to our Privacy Policy
By using
this website, you agree to the terms and conditions contained in this Privacy
Policy and Conditions of Use and/or any other agreement that we might have with
you. If you do not agree to any of these terms and conditions, you should not
use this website. You agree that any dispute over privacy or the terms
contained in this Privacy Policy will be governed by the laws of the State of
California. You also agree to arbitrate such disputes in California, and to
abide by any limitation on damages contained in any agreement we may have with
you.
This
Policy is expected to change from time to time. We reserve the right to amend
this Privacy Policy at any time and provide notice to you by posting of the
amended Privacy Policy on the website. We may also email you to give you notice
of material changes to this Privacy Policy. The provisions contained herein
supersede all previous notices or statements regarding our privacy practices
and the terms and conditions that govern the use of this Services.
13. How to Contact Us
If you have any questions or wish to
register a complaint in relation to this Privacy Policy or the manner in which
your personal information is used by us, please contact us:
support@plinko.vip