Pley Privacy Policy

1. General

1.1 Purpose of this Privacy Policy

This Privacy Policy explains how Pley AB, reg. no. 559074-0659 (Pley, we, us) processes your personal data as a data controller when you use the Service (as defined in the Terms of Service). The processing of personal data is carried out in accordance with applicable legislation, including the General Data Protection Regulation (GDPR).

1.2 Relation to the Terms

This Privacy Policy forms part of, and is incorporated into, the Terms of Service. Capitalized terms have the meanings given in the Terms unless stated otherwise.

1.3 Contact information

If you have questions about how we process your personal data, you may contact us at:
support@pley.com

2. Personal data we process

2.1 Categories of personal data

We may process the following categories of personal data when you use the Platform or the Service:

• Account information: email address, username (if applicable), account identifiers shared by Developers or third-party channels
• Technical and device information: IP address, browser and device type, operating system, language settings, and crash logs
• Usage information: interactions with the Playable, gameplay events, session data, timestamps, feature usage and analytics data
• Transaction information: in-Game purchases, transaction metadata (purchase amount, items bought, timestamp, Game identifier)
• Support information: contents of emails and support messages submitted to Pley
• Cookie data: information collected via cookies or similar technologies as described in our Cookie Policy

2.2 Sources of personal data

Personal data is collected:

• directly from you (e.g., account creation, support requests)
• automatically through your use of the Platform or the Playable (e.g., technical and usage data)
• from Developers or third-party distribution channels that provide identifiers for account linking or access

2.3 Purpose of processing

We process personal data in order to:

• provide and operate the Service and the Platform
• authenticate and manage User Accounts, including linked accounts created automatically
• enable gameplay and game-related features
• process Transactions and comply with related legal obligations
• communicate with you regarding your User Account or the Service
• provide support and handle user requests
• improve and develop the Service, including analytics and error monitoring
• ensure the security and proper functioning of the Service
• comply with applicable laws and regulations

3. Legal basis

3.1 Lawful grounds for processing

We process personal data based on:

• performance of a contract: to provide the Service and operate the Platform as described in the Terms
• legitimate interest: to maintain, secure, analyze, improve and develop the Service
• compliance with legal obligations: including tax, accounting and consumer protection
• consent: only where required (for example, certain cookie categories under applicable law)

3.2 Security measures

Personal data is processed confidentially and protected with appropriate technical and organizational security measures to prevent unauthorized access, disclosure, alteration or destruction.

3.3 Sharing of personal data

We may share personal data with:

• Developers, where necessary to operate the Game or to apply the Developer’s restrictions or account-related decisions
• third-party distribution channels, where required for linked accounts or technical integration
• payment service providers or tax intermediaries acting as merchant of record for Transactions
• hosting, analytics, security and support service providers acting as processors on our behalf
• public authorities, when required by law or legal request

Personal data is only shared for the purposes for which it was collected or for compatible purposes under applicable law.

4. International transfers

4.1 Transfers outside the EU/EEA

Personal data may be transferred to countries outside the EU/EEA. When doing so, we ensure appropriate safeguards are in place, such as the European Commission’s Standard Contractual Clauses or other mechanisms permitted under the GDPR.

5. Storage and deletion

5.1 Retention periods

Personal data is stored only for as long as necessary to fulfil the purposes of the processing or as required by applicable law. After this period, personal data is deleted or irreversibly anonymised.

5.2 Support and communications

Support messages and associated data may be retained for a limited period in order to resolve your request and maintain the quality of the Service.

5.3 Withdrawal of consent

Where processing is based on your consent, you may withdraw your consent at any time by contacting support@pley.com. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

6. Your rights

6.1 Overview

As a data subject, you have certain rights regarding your personal data. These rights are not absolute and may be subject to limitations under applicable law.

6.2 Your rights include:

1. Right of access – to request information about our processing and obtain a copy of your personal data
2. Right to rectification – to correct inaccurate or incomplete personal data
3. Right to erasure – to request deletion of your personal data in certain circumstances
4. Right to object – to object to processing based on legitimate interest
5. Right to restriction of processing – to request that we restrict processing of your personal data
6. Right to data portability – to request transfer of your personal data to another controller, where applicable
7. Right to withdraw consent – where processing is based on consent

6.3 How to exercise your rights

You may exercise your rights by contacting support@pley.com from the email address associated with your User Account. Requests will be handled as soon as possible and no later than one (1) month from receipt, unless an extension is permitted.

6.4 Complaints

If you believe our processing violates data protection law, you have the right to lodge a complaint with the Swedish Authority for Privacy Protection (IMY).

7. Children

7.1 Age limits

The Service is intended for users aged eighteen (18) or older. Children aged thirteen (13) or older may access the Service as Guest Users only. To create a User Account, you must be at least eighteen (18) years old.

We do not knowingly collect personal data from unsupervised children under the age of thirteen (13). If we become aware that such data has been collected, we will delete it.

8. Third-party sites and services

8.1 External websites

The Service may contain links to third-party websites that are not operated by Pley. We are not responsible for such sites and recommend that you review their privacy policies.

8.2 Developers and channels

Developers and third-party distribution channels act as independent data controllers for their own processing of personal data. Their privacy practices are governed by their own privacy policies, which you should review separately.

9. Cookies

9.1 Use of cookies

Cookies and similar technologies are used to provide, maintain and improve the Service and to distinguish between users. Details are provided in our Cookie Policy.

9.2 Cookie Policy

Our Cookie Policy, available at https://www.pley.com/cookie-policy, describes the categories of cookies used and the third-party vendors involved. The Cookie Policy may be maintained via a consent management platform.

10. Amendments

10.1 Changes to this Privacy Policy

Pley may amend this Privacy Policy at any time. The latest version is always available at:
https://www.pley.com/privacy-policy. Your continued use of the Service after an amended version has been made available constitutes your acceptance of the amended Privacy Policy.

10.2 Your responsibility to review

It is your responsibility to review this Privacy Policy periodically. If you do not agree with an amended version, you must stop using the Service.

10.3 Consent-based processing

Where required by applicable law, Pley may seek renewed consent if changes to this Privacy Policy affect processing that is based on your consent.

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