- INTRODUCTION.
About this Privacy Policy.
Playgap Ltd. (“Playgap”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal data. By “personal data,” we mean information that identifies you as an individual or that relates to an identifiable individual.
The purpose of this privacy policy is to explain, among other things, the following:
- The personal data Playgap collects about you when we are acting as a data controller and how we collect it.
- How we use that personal data.
- How your personal data is shared with third parties when we are acting as a data controller.
- Certain individual rights you may have concerning your personal data.
It is important that you read this privacy policy, together with the documents that are linked to from this privacy policy, and any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Additional provisions of this privacy policy applicable to individual residents of various states within the United States of America that have enacted omnibus data privacy laws are included in our U.S. State Law Privacy Notice.
For those Playgap customers that have entered into Playgap's Terms please refer to our Data Processing Agreement which outlines Playgap's role when acting as a data processor on behalf of our customers in certain circumstances.
About Playgap.
Playgap Ltd (company number: 14949926) is a company incorporated in England with its registered address at 20 Wenlock Road, London, England, N1 7GU. Playgap provides solutions for mobile application publishers to monetize advertising opportunities and services for advertisers to acquire inventory within its network (the “Services”).
If you have any questions about this privacy policy or our privacy practices, or wish to exercise any legal rights you may have with respect to your personal data, please email us at contact@playgap.io.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
- PLAYGAP'S DATA COLLECTION.
If you are a user of the Website or the Services, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, and title.
- Contact Data includes billing address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- Technical Data includes certain identifiers such as Advertising ID (which is IDFA or GAID), IP address, and a self-created ID unique to a specific app, and IDs unique only to apps of the same developer (IDFV). We also collect general technical information about the devices you use, such as the device's time zone setting and location, the amount of free memory on the device, the name and version of the app to which the advertisement is served, battery status, operating system and platform name and version, the language of the operating system, the name of the mobile carrier, your login data, browser type and version, browser plug-in types and versions, internet connection type (e.g. WiFi), and other technology on the devices you use to access this website and/or our services.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We use different methods to collect personal data, including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: create an account via our website; purchase our services; subscribe to our publications; request marketing to be sent to you; and/or give us feedback or contact us. We also receive personal data about you where you provide us with your consent to process such personal data, for example, through Device IDs used on our website.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Advertisers and Publishers that are using our services.
- HOW WE USE YOUR PERSONAL DATA.
We will only use your personal data when the law allows us to. In cases when Playgap is a data controller, it's most commonly in the following circumstances:
- Where we need it to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where you have given your consent.
- Where we need to comply with a legal obligation.
We may send you marketing messages about our products or services. You can ask us or third parties to stop sending you marketing messages at any time by emailing us at contact@playgap.io
- PURPOSES FOR WHICH WE MAY USE PERSONAL DATA WHEN ACTING AS A CONTROLLER.
We have set out below, in a table format, a description of all the ways we may use your personal data when we are a controller, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data 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 grounds we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|
| Registering for an account via the Website including access to the Playgap Dashboard. | - Identity
- Contact
- Technical
- Profile
| - Your consent.
- Performance of a contract with you.
|
| Registering for an account via the Website | - Identity
- Contact
- Technical
- Profile
| - Your consent.
- Performance of a contract with you.
|
| Uploading content to your account for use of the Website in the performance of the Services. | - Identity
- Contact
- Financial
- Transaction
- Technical
| - Your consent.
- Performance of a contract with you.
- Necessary for our legitimate interest.
|
| To administer and protect our business and this website and our services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | - Identity
- Contact
- Technical
| - 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 reorganisation or group restructuring exercise)
- Necessary to comply with a legal obligation
|
| To deliver relevant website, services content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | - Identity
- Contact
- Profile
- Usage
- Marketing and Communications
- Technical
| - Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
|
| Storing and using data to improve our data models and algorithms. | - Financial
- Transaction
- Technical
| - Necessary for our legitimate interests (to train and improve the accuracy of our data models and analytics and to improve our Services).
|
| To make suggestions and recommendations to you about goods or services that may be of interest to you | - Identity
- Contact
- Technical
- Usage
- Profile
- Marketing and Communications
| - Necessary for our legitimate interests (to develop our products/services and grow our business)
|
| To monitor trends so we can improve Services. | - Identity
- Contact
- Technical
- Profile
- Usage
| - Necessary for our legitimate interests (to develop our Services, define types of customers for our products and Services, to develop our business and to inform our marketing strategy).
|
| To monitor information about the devices used by end users of the Services and end user's use of the Services. | - Technical
- Usage
- Profile
| - Your consent.
|
| To monitor information about the campaign, for example, an indication if an advertisement was viewed, or clicked on, or if there was an install of an advertised app. We also monitor information about actions performed within an advertiser's app following such an install such as in-app purchases and level in the game. | - Technical
- Usage
- Profile
| - Your consent.
|
| To log a variety of technical information about end users of the Services to improve the efficiency of our services, and to identify usage trends. This also allows us to develop new products and Services, as well as enhance and improve our current Services. | - Technical
- Usage
- Profile
| - Your consent.
|
| To personalise our interactions with end users and to provide end users with information or offers, that may be tailored to the individual end user's interests or behaviour. This may be based on your past usage and/or preferences, and will allow us to deliver content to you as an end user that we believe will be relevant and interesting to you. | - Technical
- Usage
- Profile
- Marketing and Communications Data
| - Your consent.
|
Change of Purpose.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- DISCLOSURES OF YOUR PERSONAL DATA.
When we are a controller of personal data, we may share your personal data with the parties set out below for the purposes set out under the column “Purpose/Activity” in the table above.
- Third parties for the purpose of providing such services.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
- INTERNATIONAL TRANSFERS.
Playgap has implemented and maintains a framework consistent with applicable law for transfers of personal data outside of the UK and EEA.
- DATA SECURITY.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- DATA RETENTION.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymise your personal data (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.
- YOUR LEGAL RIGHTS.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have a right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data 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 data 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.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- 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.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data 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 at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
How to Exercise Your Legal Rights.
- Contact us. If you wish to exercise any of the rights set out above, please contact us at contact@playgap.io.
- No fee usually required. You will not have to pay a fee to access your personal data (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 could refuse to comply with your request in these circumstances.
- What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.
- Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it could 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.
- CHANGES TO PRIVACY POLICY.
We keep our privacy policy under regular review. Any changes we make to this privacy policy in the future will be posted to the Website. Any such changes will ensure that your rights are fully safeguarded. In any event, we encourage you to check the updated privacy policy published on the Website from time to time.
- MISCELLANEOUS.
Aggregated Data. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. “Aggregated Data” could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or services feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
Third-party Links. The Website and Playgap's Services may include links to third-party websites, 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 websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Cookies. Playgap does not use any tracking cookies on its website. We only utilise necessary cookies to ensure that users remain logged in for a specified duration while navigating the website or when leaving and returning to the site. These necessary cookies are essential for providing a seamless user experience and do not track user activities beyond the scope of session management.
Glossary.
- Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
- Consent means that you have given us permission (your consent) to process your personal data for one or more specific purposes.
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Website means our website at www.playgap.io where the Services can be accessed.