Privacy Policy

1. Introduction

This Privacy Policy ("Policy") outlines how Pagsmile Limited - Unipessoal Lda (referred to as "Pagsmile Limited," "we," "us," or "our") collects, utilizes, protects, and manages your Personal Data and Non-Personal Data when you engage with our online games, websites, and related services (collectively, the "Services"). Pagsmile Limited, as the data controller, is committed to safeguarding your privacy and ensuring compliance with applicable data protection laws and regulations. By accessing or using our Services, you acknowledge and consent to the practices described in this Policy.

2. Information We Collect

We collect information to operate our Services effectively and to enhance your gaming experience. This information falls into two primary categories: Personal Data and Non-Personal Data.

• Personal Data: This refers to information that can be used to identify you directly or indirectly. The Personal Data we may collect includes:
  • Account Information: Nickname, email address, and any information imported from linked social media accounts (e.g., Facebook, VK, Discord).
  • Contact Information: First and last name, billing address, phone number, and email address (if provided directly).
  • Transaction Information: Details of transactions made within the Services, including purchase history and payment information (processed by secure third-party e-commerce payment providers). Although we do not store your credit card details, we collect transaction identifiers (e.g., unique identifiers, account creation date) to prevent fraudulent activities.
  • Device and Usage Information: IP address, device model, manufacturer, RAM, ROM, CPU information, SoC device model, OS version and type, Device ID, Advertising ID, registration time, login time, game session data, and network-related information.
  • In-Game Communications: Data from in-game chat (text and audio) and interaction data with other users, player IDs.
  • Support Interactions: Customer support ticket IDs and any communications with our support team, including optional photos, and information you provide in a contact with support.
  • Location Information: Region location used to verify your region, set up your gameplay on a regional server, provide geographic ranking, and improve gameplay.
  • Registration source: Information related to the way you found our services for advertising and marketing analytics.
• Non-Personal Data: This encompasses information that does not directly identify you. This may include your in-game score, playtime, in-game activities, internet protocol addresses, browser type, browser language, referring and exit URLs, and number of clicks. This data is used for analytical and service improvement purposes.

3. How We Use Your Information

We utilize the collected information for various legitimate purposes, including:

• Service Provision: To create and manage your game account, facilitate in-game features, connect you to the appropriate game server, and provide you with the Services under our Terms of Use.
• Personalization: To customize your gameplay experience based on your preferences and settings, such as gender-specific content (if provided) and regional server allocation.
• Communication: To communicate with you about product updates, new releases, special offers, and to provide customer support.
• Analytics and Improvement: To improve our Services, identify bugs, assess game functionality for optimization, prevent fraudulent activities and violations of our terms and conditions, and enhance the overall gaming experience. This includes analyzing player behavior, monitoring ad campaign effectiveness, and managing registrations and accounts.
• Security and Verification: To maintain the security and integrity of our Services, protect against fraud, and verify user accounts.
• Legal Compliance: To comply with applicable legal obligations, including child protection and age restriction laws.
• Advertising: To analyze and monitor the success of our advertising and marketing campaigns.

4. Legal Basis for Processing

Our processing of your Personal Data is based on several legal grounds, including:

• Contractual Necessity: To fulfill our obligations to you under the Terms of Use.
• Legitimate Interests: To pursue our legitimate interests in improving and securing our Services, analyzing user behavior, and promoting our offerings, provided these interests are not overridden by your rights and interests.
• Legal Obligations: To comply with our legal obligations.

5. Data Sharing and Disclosure

We may share your Personal Data with third parties in the following situations:

• Third-Party Service Providers: We may engage trusted third-party service providers to assist us in operating and improving our Services. These providers include technical support, software, SaaS, legal counsels, auditors, advertising, and marketing agencies. They are contractually obligated to keep your Personal Data confidential and comply with applicable data protection laws.
• Payment Processors: Secure third-party e-commerce payment providers handle your payment information. While we do not store credit card details, we receive specific data (excluding credit card numbers) to facilitate administration.
• Legal and Regulatory Compliance: We may disclose your information as permitted by law to comply with legal processes, governmental requests, and to protect our rights, prevent fraud, and ensure the safety and security of individuals and our services.
• Affiliates and Partners: In some instances we may share your personal data with our affiliates and partners and we will ensure data transfer is in accordance with safeguards under the law.

Additionally, when providing in-game communication data, such as that from chat logs (both text and audio), we may be able to provide information not only from a specific chat channel but from all available channels, upon a valid request and subject to any applicable legal limitations.

6. Data Storage and Transfer

Our game is available worldwide and therefore we may collect data from various countries. We are committed to minimize the data transfer from one region to another, and ensure your data is secured in accordance with the industry standards. In the interests of ensuring the seamless provision of our Services, your personal data may be processed, stored and transferred to servers located in various regions, including outside of your own country.

7. Your Rights

You have certain rights concerning your Personal Data, including:

• Access: You can request access to the Personal Data we hold about you.
• Correction: You can request corrections to any inaccuracies in your Personal Data.
• Deletion: You can request the deletion of your Personal Data, subject to applicable legal requirements.
• Withdraw Consent: You can withdraw your consent to process your Personal Data at any time.
• Restriction of Processing: You can request a restriction on how we process your Personal Data.
• Data Portability: You can request a copy of your Personal Data in a portable format.
• Objection: You can object to certain processing activities, including for direct marketing.
• Complaint: You can lodge a complaint with the appropriate supervisory authority.

8. Data Security

We implement appropriate technical and organizational measures to safeguard your Personal Data from unauthorized access, use, or disclosure. These measures align with industry standards and include access controls, encryption, and secure storage. Although we strive to protect your data, no method of data transmission or storage is entirely secure. As such we cannot guarantee the absolute security of your information. By using our services you acknowledge and assume this risk.

9. Cookies and Tracking Technologies

We may use cookies and similar tracking technologies to enhance your experience. Cookies help us identify you as a unique user and remember your preferences. Third parties, including advertisers may also place cookies on your browser to serve ads to the site. You can control your cookies preferences via your browser settings.

10. External Links

Our Services may contain links to external websites. We are not responsible for their privacy practices. We advise you to review the privacy policies of those websites before interacting with them.

11. Changes to this Policy

We may modify this Policy periodically to reflect changes in our data handling practices, technological advancements, or legal requirements. Any changes will be effective upon posting the revised version. We encourage you to review this Policy regularly.

12. Contact Us

If you have any questions about this Policy or our privacy practices, please contact us at:
[email protected]