Last updated May 2020

INTRODUCTION

Your privacy is important to us, and we take our responsibility of caring for it seriously. We respect your privacy rights and are committed to protecting the personal information that is collected about you. This Privacy Policy describes what information Play Hub collects and how we use, disclose, transfer, and store it. If you do not want Play Hub collect, store, use or share your information in the ways described in this Privacy Policy, you may not be able to play our games or use our services.


We, including our service collects, stores, and uses your information as a data controller in connection with, and in order to provide and develop, Play Hub games, mobile applications, services and websites (together referred to as the “Services”) in accordance with this privacy policy (“Privacy Policy”).


All of our Services, whether used on mobile devices, PCs or other platforms, are governed by this Privacy Policy. By using the Services, you hereby consent to this Privacy Policy.


We reserve the right to change this Privacy Policy at any time. In the event that we make material changes to this Privacy Policy, they will be re-posted in the "Privacy" section of our websites and apps with the date the modifications were made indicated at the top of the page. Therefore, please review this Privacy Policy from time to time so that you are aware when any changes are made to it. Your continued use of the Services after such change(s) constitutes your acceptance of any such change(s), and if you do not accept any changes, you may choose not to use the Services or opt out by sending us appropriate notice. If you would like further information about any recent changes made, please send your request to mailto:playhubca@silverlines.info and include “Information about Changes” in the subject line


COLLECTION OF YOUR INFORMATION

Play Hub collects some information from you when you: (a) play our games or use game-related services, (b) make a purchase within our Services, (c) watch advertisements within our Services, (d) contact Play Hub customer service and take part in technical-support sessions, (e) enter a contest or participate in a challenge held by Play Hub, (f) share or contribute to our social-media channels and other community websites. The information we may collect includes: -

  • Information you provide us
    1. Contact information (such as your name and email address
    2. Your age
    3. Information that you provide when seeking help from our customer service (such as chat logs and customer-support)
    4. Other information you provide us
  • Information we collect automatically directly from you when you use our Services
    1. Information about your game progress and activity
    2. Information about your interactions with other players
    3. IP address and device identifiers (such as your device ID, advertising ID
    4. Information about your device (such as device name and operating system, browser information, including browser type and the language you prefer
    5. Information we collect using cookies (Note: You can refer to our Cookies Policy)
    6. General geolocation information
    7. Precise geolocation information (GPS)
    8. Play Hub player ID
  • Information we obtain from our partners
    1. Information that we receive if you decide to connect to a third-party social network (such as Facebook)
    2. Information from telco operators and/or billing partners (if you subscribe to some games
    3. Information for advertising and analytics purposes, so we can provide you with better Services

USE OF YOUR INFORMATION

We primarily use the information to provide you with a better gaming experience, but we also use your information, both individually and combined, as follows: -

  • To operate our business and to enhance your gaming experience, including to: -
    1. provide you with the Services that are suitable to your age and compliance with the applicable laws of your country of residence
    2. provide gaming experiences that you may like and functionalities you have subscribed to
    3. track your use of the Services to help us learn more about your gaming activities and understand your preferences and tendencies, so that we can personalize your experience, provide you with in-game offers and notifications that are tailored to you, and otherwise enhance your gaming experience
    4. offer you the opportunity to take part in playtesting (game tests)
    5. protect against cheating, crime or fraud, or for other security reasons
    6. identify and fix bugs and service errors
    7. use it for administration, analytics, research, and optimization
    8. compile statistics
    9. comply with all regulatory and legal requirements, and answer any requests from Data Protection Authorities or any law-enforcement agency
  • To provide you with support, communicate with you and respond to any requests or questions you have submitted through our customer support.
  • To personalize our communication with you, including to: -
    1. handle your subscription to, and opting-out of, our newsletters
    2. contact you to promote our Services
    3. send you, with your prior consent, promotions or marketing materials (we will provide you with the opportunity to opt out of receiving such materials in the future)
    4. provide you with advertising that better suits your interests and profile and is age-/gender-appropriate and targeted to your general location
    5. serve and measure the effectiveness of advertising
    6. personalize your content and offers
    7. send you push notifications (if you choose to allow that function)—only for users 18 years old or older

For some purposes described above, Play Hub may use and perform analytics. Analytics information supports business analysis and operations, allows product development, improves products and Services, personalizes content, provides advertising, and makes recommendations.


Our legal basis for collecting and processing your personal information is described above.

We will normally collect personal information from you only: -

  1. when we need the personal information to fulfill a contract with you and provide you with the Services, such as customer services, bug and service-error detection, and fraud prevention

  2. when we have your consent to do so

  3. when the processing is in our legitimate interests (when we serve and measure the effectiveness of advertising or marketing campaigns, analyze your gaming activities, protect and improve our products and services) and not overridden by your rights, or

  4. when we have a legal obligation to collect personal information from you.


RETENTION OF YOUR INFORMATION

Play Hub retains, uses and stores your information as long as you are playing our games or using our Services, and also for the period necessary to fulfill all the purposes described in this Privacy Policy, in compliance with the applicable laws of your country of residence. We want to inform you that a longer retention period could be required to resolve disputes, or answer regulatory or police requests. In such cases, the collected information will be used and stored until the request is closed.


DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you in certain situations. Your information may be disclosed as follows: -

  1. By Law or to Protect Rights

    If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

  2. Third-Party Service Providers

    We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

  3. Marketing Communications

    With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

  4. Interactions with Other Users

    If you interact with other users of the Services [and our mobile application], those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts, following blogs.

  5. Third-Party Advertisers

    We may use third-party advertising companies to serve ads when you use the Services. These companies may use information about your use on the Services and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.

  6. Affiliates

    We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

  7. Business Partners

    We may share your information with our business partners to offer you certain products, services or promotions.

  8. Other Third Parties

    We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.

  9. Sale or Liquidation

    If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter into liquidation, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.


INTERNATIONAL OPERATIONS AND TRANSFERS OF YOUR INFORMATION

As part of our international operations, we may transfer personal information to our affiliates (which means subsidiaries, parent companies, joint ventures, and other corporate entities under common ownership of Play Hub) from time to time for our legitimate business purposes.


Play Hub is headquartered in Malaysia, and we have operations, entities and Services provided in Indonesia, Thailand, Philippines, United States and throughout the world. We have taken measures to ensure that your personal information is treated securely and lawfully, and that it receives an adequate level of protection in the jurisdictions in which we process it. If you are located in the European Economic Area (“EEA”) or Switzerland, we provide adequate protection for the transfer of personal information to countries outside of the EEA or Switzerland based on the standard contractual clauses authorized by the European Commission or other appropriate safeguards defined in Article 46, General Data Protection Regulation (GDPR) (EU) 2016/679.


TRACKING TECHNOLOGIES

We may use cookies, web beacons, and other tracking technologies on the Services to help customize the Services and improve your experience. When you use the Services, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Services. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.


THIRD-PARTY WEBSITES

The Services may link to external sites that are beyond our control. This Privacy Policy only covers the way we treat personal information and non-personal information we collect on the Services. By accessing any external sites, you agree to the privacy policies of those sites. Please understand that external sites may have different policies with respect to the collection, use and disclosure of your personal information. We have no control over, and are not responsible for, the privacy practices of such third parties. Therefore, you are encouraged to review the privacy policies of all third parties' services. Without limiting anything in the following section, we are not liable in any way for the actions, inactions or policies of any external services.


SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.


POLICY FOR CHILDREN

We encourage parents to instruct their children about privacy and the way they use their information on the Internet. Children should never disclose their name, address or phone number, or any personal information, without their parents’ prior permission.


We consider a user to be a child if they are under the age of 18, unless more stringent regulation applies in their country of residence. If we consider that any of our Services are directed at users under the minimum legal age, we can block such users from using the Services or from providing information and/or limit the collection of information from such users as more particularly described below. No personal information should be submitted to Play Hub by users under the minimum legal age.


LEGAL DISCLAIMER

Our Services operate “AS IS”, and we do not represent or warrant that our Services will be available at all times, or that your use of the Services will be uninterrupted or error-free. We are not responsible for your ability to access the Services or for matters beyond our control. This Privacy Policy is governed by the laws of Play Hub. Any dispute arising from the use of the Services shall be submitted to the competent courts of Play Hub.


OPTIONS REGARDING YOUR INFORMATION

We ask that you keep the information that you provide to us updated. You can correct any information you have provided to us by contacting us. You represent and warrant that all information you provide to us is true and correct, and relates to you and not to any other person. You can exercise your rights at any time and ask Play Hub for access to, or rectification or erasure of, your information.


Please note that other third parties (our data partners) may be controllers of your information. You can obtain more details and opt out of the sharing of your personal information to third parties for any purpose by contacting us. If you have previously consented to any direct marketing communication from us or subscribed to our newsletters, you can unsubscribe by clicking on a link available in each communication and newsletter we send you. If you want to decline to permit cookies or other tracking technologies, please read our Cookies Policy on our websites.


Please note that game functionality, Services and features can be affected by your actions. Some of your information and its processing is mandatory for Play Hub to provide the Services. Your actions can oblige Play Hub to stop providing the Services. When the conditions below apply, your game will be reset:-

  1. If you ask for the modification of this mandatory information, we may not be able to continue to link the game or game Services to you

  2. If you request limitations to processing that are mandatory for Play Hub, or you object to such processing (in which case, we may not be able to provide you with the game or game Services).

  3. If you withdraw your consent or ask for the deletion of your information, we will not use or process your information anymore but we will store it to answer regulatory or police requests. We also reserve the right to retain an archive of such information for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such information.


If you are a parent of a child who is under 18 years of age (or under another age specified by applicable regulations) and believe your child has provided us with information, please contact us and we will delete the information from our system.


CONTACT US

If you have questions or comments about this Privacy Policy, please contact us at: -

  1. by sending an email to mailto:playhubca@silverlines.info