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Privacy Policy (EU)

PLAY2PAY, INC. PRIVACY POLICY

Introduction

Play2Pay, Inc. (“We”) are firmly committed to protecting and respecting your privacy, including any information you share with us or other users.  This Privacy Policy describes our information gathering, use and sharing practices for this website (www.play2pay.com (“Our Site” or “The Site”)) as well as mobile device applications (“Apps”) that operate using Play2Pay services and related services of our business affiliates (collectively “Website & App”). This privacy policy (together with our End User License Agreement (https://play2pay.com/eu-eula/) and any documents referred to in it) and our cookie policy (also contained herein) sets forth the basis on which any personal data we collect from you, or that you provide to us, will be processed and shared by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Unless otherwise stated, we will always ask for your consent to collect and process your personal data, including all personal data referenced in this Privacy Policy by asking you to accept specific terms and conditions, except where collecting and processing, including sharing information with third parties, your personal data is necessary for the provision of services. You can withdraw this consent at any time by contacting us at Play2Pay Inc., 2980 NE 207th St., STE 300 Aventura, FL 33180. This Privacy Policy was last updated in November 2018.

Who Is Collecting Your Data?

Unless otherwise stated, for the purposes of the Data Protection Act 1998 (the “Act”) and the EU General Data Protection Regulation 2016 (‘the Regulation’), all data collection is conducted by us, the data controller, namely: Play2Pay Inc., 2980 NE 207th St., STE 300 Aventura, FL 33180. Our data protection officer is Alex Hurd. If you have any questions about our policy and privacy practices, you can contact us at Play2Pay Inc., 2980 NE 207th St., STE 300 Aventura, FL 33180.

What Information Is Covered By This Privacy Policy?

This Privacy Policy privacy covers all ‘personal data’ as such term is defined in Section 1(1) of the Act and Article 4(1) of the Regulation (“PII”) that you may provide and we may collect when you use our Website & App. As per the Regulation, personal data is data that can be used to identify individual data subjects directly or indirectly. This policy also covers our treatment of any PII that our business affiliates share with us or we share with them.

What Information Do We Collect?

  1.  Information Related To Our Services

Subscribing to and using our services

When you subscribe to our services and register with Our Site and/or download or install our App, you are asked to provide the following personal information including your name, email address, phone numbers, occupation, hobbies, interests, your likes and dislikes and personal profile data. We also collect your Advertising ID. We use this data to allow advertisers to provide relevant adverts on the lockscreen of your mobile phone. In addition, we collect coarse location data from our users and use this to allow advertisers to provide relevant adverts at a city level on the lockscreen of your mobile phone. We ask for your consent to collect this data when you first register for the App through the Google Play store. In the future, you may also be asked to provide credit card or other financial information for the conduct of transactions with us and payments for services. We will notify you of any changes made and ask for your explicit consent to collect and process this data. Personalizing your content Our Site and App also automatically receive and record information on our server logs from your browser, including your IP address, browser type and cookie information, as well as certain actions you may take in connection with any delivered advertisement content about certain goods and services. We use this information to personalize the content you see, to fulfill your service requests, to inform you of updates about your activities and changes to our services, to alert you to news and activities, provide more personal content for you, including goods and services that may be of interest to you, and to offer any suggestions about other products and services we believe may also be of interest to you, based on your specified preferences and your choices.

Other

We may also collect information about your activities on our Website & App, communications and interactions with us, responses to the goods and services that are provided through our Website & App, specific actions or likes and dislikes that you may indicate while using our Website & App, as well as the feedback information that you may volunteer to leave.
  1.  Aggregate Information
We may collect certain information about all users, such as the number of visits to our Website & App, what services of features users access the most, what type of communications and contacts are most popular among users, what type of content or advertisements are enjoyed, liked or most frequented by our users. We only use such data anonymously and in the aggregate. This information helps us create a better overall user experience for all users of our Website and App. We may share this information with our business affiliates, but only in the aggregate, so that they may also understand how our visitors use our Website & App., and how they respond to certain delivered ad content.

What Do We Keep And Under What Circumstances?

  1. Our Usage and Processing
We do not sell or provide PII from our users to third parties without their consent. We may use personal information that you provide to us as part of our services to you and to improve your experience and enjoyment of the Website & App, and personalized goods and services ads that are provided using our Website and App.  For example, we may use your preferences, likes and dislikes to target better content, including goods and services, to you, through our Website and App. We may also use SSL (“Secure Socket Layer”) or some other type of encryption to safeguard your credit card data when used in E-commerce transactions, and we may utilize encryption techniques to safeguard your username and password used in connection with the Website & App.

We may record and share aggregate information with our business affiliates.

We may also disclose your PII or aggregated information about our users pursuant to a law, regulation, or written request to a governmental agency, or pursuant to a subpoena or court order demanding and requiring such disclosure as required under Article 6(c) of the Regulations.  Furthermore, we may use any PII or aggregate information about users in any action or lawsuit involving our Website & App services. We will make full effort to keep any legal disclosures protected from the broad public dissemination and subject to confidentiality obligations protecting private and personal information.
  1. Limited Use Of Information After The Termination Of Services
We may keep certain PII you have given us for at least as long as you remain an active user of our Website & App services, either directly or through the communications services provider in order to deliver our services to you. We may also keep your PII for a certain limited time after the termination of your services where such processing is necessary for the purpose of our legitimate interests under Article 6(f) of the Regulation. Such information will be primarily for accounting, resolution of any pending disputes between you and any other users of our services, for tax-related purposes and to resolve any technical issues. We do not allow your personal information, profile data or other PII to be visible to other users of our Website & App once you have terminated your services with us. Sharing Information With Our Business Affiliates And Consultants

We may share your PII with any member of our group, including any subsidiaries or our holding company, as defined in section 1159 of the UK Companies Act 2006.

We may share your information with selected third parties including:

  • Business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them for purposes of providing our services to you. For example, companies or individuals may provide or assist with supporting and providing services for your wireless device, hosting our Website and App, backup, servers, providing marketing services, processing credit card payments and other business and financial transactions and related services.
  • Analytics and search engine providers that assist us in the improvement and optimization of our site.

We may disclose your PII to third parties:

  • in the event that we sell or buy any business or assets, in which case we may disclose your PII to the prospective seller or buyer of such business or assets;
  • if we, or substantially all of our assets, are acquired by a third party, in which case PII held by us about our customers will be one of the transferred assets;/
  • if we are under a duty to disclose or share your PII in order to comply with any legal obligations including any legal obligations under the Act, or in order to enforce or apply our End User License Agreement and other agreements; or to protect our or your legitimate interests, rights, property, or safety including the interests, rights and safety of our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction; or
  • if you redeem your Adfone Points for a reward, to the gift card vendor and/or provider of the reward, including Lycamobile UK Limited, depending on what reward is chosen.
The privacy policies of our affiliates and third parties with whom we share your data are available on their websites.

Our Process with Lycamobile UK Limited

In order to provide adverts on your mobile phone in exchange for extra bundles, we provide Lycamobile UK Limited (‘Lyca’) with the following personal details allowing them to see which of our customers wish to redeem points for extra bundles. These details include the MSISDN (mobile phone number), details of the bundle to be redeemed, the status of the bundle redemption and the remaining number of points available.  Insofar as Lyca provide any extra services or perform any additional data processing, this is covered by their Privacy Policy which can be found at https://www.lycamobile.co.uk/en/privacy.

Our Process with Mopub Inc

In order to provide coverscreen adverts on your mobile phone in exchange for extra bundles, we provide Mopub Inc (‘Mopub’) with the following personal details allowing them to promote the service to advertisers. These details include the Advertising ID, your interests, age, gender and coarse location. Mopub acts as a Data Controller as detailed in their Privacy Policy which can be found at https://www.mopub.com/legal/privacy/.

Our Process with Fyber N.V

In order to provide offer wall opportunities on your mobile phone in exchange for extra bundles, we provide Fyber N.V  (‘Fyber’) with the following personal details allowing them to promote the service to advertisers. These details include the Advertising ID,  your IP Address and your coarse location.. Insofar as Fyber provide any extra services or perform any additional data processing, this is covered by their Privacy Policy which can be found at https://www.fyber.com/legal/privacy-policy/

Our Process with IronSource Mobile Ltd

In order to provide rewarded video opportunities on your mobile phone in exchange for extra bundles, we provide Ironsource Mobile Ltd  (‘Ironsource’) with the following personal details allowing them to promote the service to advertisers. These details include the Advertising ID,  your IP Address and your coarse location. Insofar as Ironsource provide any extra services or perform any additional data processing, this is covered by their Privacy Policy which can be found at https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/

Our Process with Pollfish

In order to provide survey opportunities on your mobile phone in exchange for extra bundles, we work with Pollfish (‘Pollfish’). When a user connects to this app, a specific set of user’s device data (including Advertising ID which will may be processed by Pollfish only in strict compliance with google play policies- and/or other device data) and response meta-data (including information about the apps which the user has installed in his mobile phone) is automatically sent to Pollfish servers, in order for Pollfish to discern whether the user is eligible for a survey. For a full list of data received by Pollfish through this app, please read carefully Pollfish respondent terms located at https://www.pollfish.com/terms/respondent. These data will be associated with your answers to the questionnaires whenever Pollfish sends such questionnaires to eligible users. Pollfish may share your response metadata back to Play2Pay (linked to your Advertising ID) to generate more relevant survey availability. By downloading the application you accept this privacy policy document and you hereby give your consent for the processing by Pollfish of the aforementioned data. Furthermore, you are informed that you may disable Pollfish operation at any time by using the Pollfish “opt out section” available on Pollfish website.

Our Process with Tap Research

In order to provide rewarded survey opportunities on your mobile phone in exchange for extra bundles, we provide Tap Research, Inc (‘Tapresearch’) with the following personal details allowing them to promote the service to advertisers. These details include the Advertising ID,  your IP Address and your coarse location and other information that you voluntarily submit to them. Insofar as Tapresearch provide any extra services or perform any additional data processing, this is covered by their Privacy Policy which can be found at https://www.tapresearch.com/legal/privacy-policy-en

Our Process with Tangocard,Inc

In order to provide redemption vouchers, we work with Tangocard Inc (‘Tangocard’). When you request a voucher, we provide Tangocard with your email address in order to send the voucher. Insofar as Tangocard provide any extra services or perform any additional data processing, this is covered by their Privacy Policy which can be found at https://www.tangocard.com/privacy-notice/

Our Process with One Signal,Inc

In order to provide account reminders, we work with One Signal Inc (‘Tangocard’). When you sign up data including your Android ID and IP address will be stored by One Signal. Insofar as One Signal provide any extra services or perform any additional data processing, this is covered by their Privacy Policy which can be found at https://onesignal.com/privacy_policy

Cookies

To enhance your experience with the Website & App, and enable better services through the Website and App, we may use a feature on your Internet browser called a “cookie.”  Cookies are small hidden files that your web browser places on your computer’s hard drive. We use cookies for remembering your preferences, profile data, communications, access dates and time, tracking visits to understand better visitor behavior, and planning for increased loads on our servers.  Because of our use of cookies, we can deliver a faster and more efficient services through our Website & App, safer and quicker transactions and a more personalized user experience. You have the option of setting your browser to reject cookies. However, doing so may hinder your ability to or use offered services, and taking full financial and other advantages offered to you by our Website & App services. If you would like to know more about cookies, you may find this resource useful: allaboutcookies.org Although, please note that we are not responsible for information available on this website.

Where we store your Personal Data

Transfer of personal data outside the EEA Information, including personal information that we collect from you, may be transferred to, stored at and processed in a country outside the EEA, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By registering to use this App, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential.  We ask that you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure.  Although we will do our best to protect your PII, we cannot guarantee the complete security of data transmitted to our site; any transmission is at your own risk.  Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Updating Account Information

You may update, modify, or add personal information through the Website & App at any time.  To do so, simply logon to Our Site or the App with your username and password, and you will be able to update or modify the information you have submitted.  Please make sure that your username and password are secure and protected, and do not share or disclose it to anyone other than yourself or your authorized persons./

Privacy Policy Changes

If we decide to change our privacy policy, we will post those changes here, as our Privacy Policy, so that you will always have full disclosure about what PII and other information we collect, how it might be used, and under what circumstances we may disclose it to anyone. We use reasonable precautions to keep personal information disclosed to us secure. However, we are not responsible for any breach of security or wrongful acts of third parties, or any disclosures you may make on your own. This privacy policy is not intended to, and does not, create any contractual or other legal rights in or on behalf of any party to this Agreement or any third party.  The terms of this Privacy Policy are subject to the terms and conditions contained in the End User License Agreement, governing the relationship with and conduct of services with our users. We reserve the right to make changes to this Privacy Policy at any time without prior notice, and such changes become effective once a revised Privacy Policy is posted on Our Site or downloaded with our App or upgrade to our App.  If you continue use of our Website & App after the revisions are made to the Privacy Policy, it shall constitute your acceptance of such changes.

Your Rights

You can find out more about your rights under GDPR from the Information Commissioner’s Office.
Access
You are legally entitled to know what personal information we hold about you and how that information is processed. Additionally, you have the right to obtain information regarding where and for what purpose your data is being processed. If you would like to know what information we hold about you, please write to us at Play2Pay,  Inc., 333 Las Olas Way, CU1, Fort Lauderdale, FL 33301. We will ask you for proof of identity and provide you with a response within 30 days.
Data Erasure
You have the right to request that we erase your personal data and stop distributing it to our partners.
Objections</5h>
You have the right to object to processing of personal data concerning you based on Articles 6(e) and (f) of the Regulations. You also have the the right to object to the processing of personal data concerning you for direct marketing purposes.
Automated Decision-Making
If we use your personal information on an automated basis to make decisions which significantly affect you, you have the right to ask that the decision be reviewed by an individual to whom you may make representations and contest the decision.  This right only applies where we use your information with your consent or as part of a contractual relationship with you.
Staying up to date
Please make sure that the data you supply us with is correct and up to date. If your details change, you can update them at any time by writing to us at Play2Pay Inc., 2980 NE 207th St., STE 300 Aventura, FL 33180.
Withdrawing Consent
You have the right to ask us to stop collecting and processing your PII.  We will ordinarily seek your consent when you initially download the app and you can withdraw this consent by contacting us at our registered office address at Play2Pay , Inc., 333 Las Olas Way, CU1, Fort Lauderdale, FL 33301 or via email address support@Play2Pay .com You may also need to contact our partners to request your rights as per their privacy policies. Our site may, from time to time, contain links to and from the websites of our partner networks and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites..

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be sent to us at our registered office address at Play2Pay, Inc., 333 Las Olas Way, CU1, Fort Lauderdale, FL 33301 or via e-mail address to support@play2pay.com addressed to Data Protection Officer with the subject heading Privacy Policy Feedback.