Privacy Policy

This Privacy Policy is designed to tell you about how Playto Holdings Inc. and its affiliates and subsidiaries (“Playto,” “us,” or “we”) may collect, use, and disclose information that we obtain through the “Services.”

The “Services” includes our video games, software programs and any other websites, mobile applications, and other services under the control of Playto.  By using the Services, you consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy.
 
 

What We Collect

 
When you interact with the Services, we may collect the following types of information:

Personal Information You Provide. 
We may collect Personal Information when you download or register for the Services, use certain areas of the Services, purchase the Services, subscribe to any communications from us, or otherwise voluntarily provide it to us. “Personal Information” means information that alone or when in combination with other information may be used to readily identify or contact you. Personal Information can include name, age, child’s email address, parent’s email address, address, credit card number, card verification value, location data or other information about you that is directly linked to Personal Information.  We do not consider Personal Information to include information that has been de-identified or aggregated so that it does not allow a third party to easily identify a specific individual.

Additional Profile Information. 
To register for or download certain Services, we may ask or require that you provide additional, optional information that helps us to personalize your experience and improve the Services.

Cookies, Automatic Data Collection, and Related Technologies. 
When you access or use the Services, we and third parties that may provide certain functionality on the Services, such as social media or advertising networks, may engage, receive, collect, and store information through automatic data collection tools including cookies, pixel tags, web beacons, embedded web links, and similar technology. These technologies may collect information including, but not limited to, information such as your Internet Protocol (IP) address, browser type, the date and time that you use the Services, referring/exit pages and URLs, number of clicks, cookies that may uniquely identify your browser, and information about your mobile device.

Cookies are small text files placed in visitors’ web browsers to store their preferences or provide certain functionality. Most browsers allow you to block and delete cookies. However, if you do the Services may not work properly.

Customer Support. 
We may collect Personal Information through your communications with our customer support team.

Payment Method Information. 
Some Services may require you to furnish certain financial information, such as credit card or other payment account information in order to complete a purchase.

Children’s Personal Information. 
We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age without prior parental consent, and we will only collect the information from a child that is reasonably needed in order to allow the child to use the Services.  If a child wishes to use the Services, a parent or legal guardian must set up an account and approve all information collection via the Parent Dashboard provided with the Services.

With parental consent, we may collect Personal Information from children under the age of 13 that includes: email address, age and gender. We may also collect Usage Information from a child under the age of 13.

Parents must approve and review the information collected from their child, and may ask to have it deleted or refuse to allow further collection of their child’s information, by contacting us at privacy@playto.org or via the Parent Dashboard.  If we learn that we have collected any Personal Information from children under 13 without parental consent, we will promptly take steps to delete such information and terminate the child’s account.
 
 

How We Use Your Information

 
Internal and Service-Related Usage. 
We use information, including Personal Information and Usage Information, for internal and service-related purposes only and may provide it to third parties to allow us to facilitate the Services. We may use and retain any data we collect to provide and improve the Services.

Service Communications. 
We may contact you using the contact information you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance.

Marketing. 
We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission. We also do not provide any Personal Information to any third-party ad networks. We may use your Personal Information and other information to communicate with you by email, text message, or push notification to provide you with information we think may be of interest to you.  You may opt out of marketing emails at any time by using the opt-out link in an email.  We will send you text messages only with your consent, which we will ask you for at the time you provide us with your mobile telephone number.

Aggregate Data. 
We may de-identify and aggregate data collected through the Services and use it for any purpose. It is important to remember that such information does not identify you individually.
 
 

How We Share Information

 
Vendors and Service Providers. 
We may share any information, including Personal Information, that we receive with vendors and service providers retained in connection with the provision of the Services.

Social Networking and Other Website Services. 
The Services may allow you to share information, including Personal Information, with third-party services and social networking websites, such as Facebook and Twitter. We do not share your Personal Information with them unless you direct the Services to share it. Their use of the information will be governed by their privacy policies, and you may be able to modify your privacy settings on their websites.

As Required By Law and Similar Disclosures. 
We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; or protect yours’, ours’ or others’ rights, property, or safety.

Merger, Sale, or Other Asset Transfers. 
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information.

With Your Consent. 
We may also disclose your Personal Information with your permission.
 
 

Third Party Websites and Applications

 
The Services may contain links to certain third party websites. We do not own, control, or operate such linked sites, and we are not responsible for the privacy policies or practices of such linked sites. Privacy policies and practices for such linked sites may differ from this Privacy Policy and our practices. We encourage you to read the privacy policies of such linked sites before disclosing your personal information on such sites, as those privacy policies will apply to information collected through those third party websites.
 
 

Security of Your Information

 
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services or by sending an email to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at privacy@playto.org.
 
 

Data Transfer

 
All Personal Information may be stored on servers in Hong Kong, the United States and any other territories that we may see fit from time to time to provide the Services and may be subject to American law. By choosing to use the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy may be governed by the law of the state of California and the adjudication of any disputes arising in connection with Playto or the Services will be in accordance with the Terms of Use.

Users from outside of the United States, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information you consent to any transfer and processing in accordance with this Policy.

Update Your Information or Pose a Question or Suggestion:

If you would like to update or modify any Personal Information you have provided us, you can do so by emailing us at privacy@playto.org.
  If you have any questions or concerns about this Privacy Policy or the use of your information, please contact us at privacy@playto.org.

Changes to Our Privacy Policy and Practices:

Posting of Revised Privacy Policy. 
We may update this privacy policy to reflect changes to our information practices. If we make any change in how we use Personal Information, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

New Uses of Personal Information. 
From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

Playto Holdings Inc. 2402 Dominion Centre, 43-59 Queen’s Road East, Wanchai, HONG KONG

Last updated: 20 September 2015