This Paddle Privacy Policy (“Privacy Policy”) will help you understand the information we collect from you and the different ways we may use or share it.
This Privacy Policy applies to your use of the “Services,” which means any of our websites, games, applications, or other products or services that link to this Privacy Policy.
Paddle Co., Ltd. is responsible for providing the Services to you and is the controller of information collected under this Privacy Policy.
Personal Identifiable Information or “PII” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.
We only collect and process your PII when we have an appropriate basis including but not limited to providing Services that are subject to terms you have accepted, complying with legal obligations, pursuing legitimate interests (in accordance with applicable law) and performing maintenance on the Services. We may request for your consent for certain processing of your PII.
For this method of collection, you provide your PII to us when you use the Services. Some examples of your provision of information to us are:
The PII we collect from the above processes may vary depending on the circumstances and may include but is not limited to your name, screen name, e-mail address, wallet information, phone number, billing address and date of birth. This PII is used for the specific purpose it is collected for such as using your phone number to call you back regarding a customer support issue, using your address to award you a prize or using your name in the creation of your account.
For this method of collection, we collect your PII when you use the Services via our technology, which includes but is not limited to web browsers, cookies, log files, web beacons and any other method of collection whereby data is transmitted from our games, website and applications.
The information collected with the technology described above might only be able to identify you when combined with other information collected rather than identifying you when used alone.
We may aggregate and de-identify your PII, and the information collected as described above may be used for data analytics, preventing fraud and other misuse of the Services, improving the Services and developing new features for Services. The information we may collect automatically via our technology may include but is not limited to:
Third parties may be providing services within the Services and the technology of such third parties may be collecting information regarding your use of the Services. Those third-party services are subject to the privacy policies of such third parties. We are not responsible for the privacy practices of such third parties.
We may receive information from third parties collected from your access and use of their websites and/or services. Such information has been collected and is used pursuant to the privacy policies of such third parties; however, once we receive such information, it will be subject to the terms and conditions of this Privacy Policy. We are not responsible for the privacy practices or content of such third parties.
We may also receive information from third parties collected from your purchase of our games, applications and/or features therein relating to your account information and/or registration including but not limited to your e-mail address, screen name and date of birth. We will not receive your payment information. Again, once we receive such information, it will be subject to the terms and conditions of this Privacy Policy.
We collect, process and use the information we collect from you, including PII, for the following business purposes:
We share the information collected from you, including PII, with the following types of recipients:
We are required to seek your consent to use your PII for any purpose inconsistent with the purposes identified herein.
You may withdraw your consent to any of the PII processing purposes identified herein by contacting us at the email address in the How to Contact Us section below. Note that some processing purposes are required for operation of the Services, and without them, your user experience may be affected.
By changing the privacy settings in your browser, device or third-party service (to the extent you are allowed to under the third-party service privacy policy), you may restrict our collection of data by disabling cookies, geolocation services, tracking and other collection mechanisms. Note that such disabling of mechanisms may affect certain features of your use of the Services.
You have the right to request access to, correction of and/or deletion of your PII by contacting us at the email address in the How to Contact Us section below.
We have adopted and maintain appropriate administrative, technical, and physical safeguards to protect your PII from unauthorized access, use, modification, loss and/or disclosure. To the extent applicable law requires, we will notify you of any security breach that results in any such unauthorized access, use, modification, loss and/or disclosure.
We store PII for as long as we reasonably need it to fulfill the purposes for which it was collected.
The Services are not intended for children under the age of 13. We do not knowingly collect PII from children without parental or guardian approval in accordance with the Children’s Online Privacy Protection Act (“COPPA”) and other applicable laws. In the event we learn that we have collected PII from a child in breach of applicable law, we will take measures required therein such as deletion of the PII since it does not fulfill the purpose it was collected for.
The Services are global and our company has operations around the world. By using the Services, you acknowledge and agree that your information may be transferred and processed outside your country of residence as required to provide such services. Different countries may have different data protection laws than your own country, and we take steps to ensure adequate safeguards are in place to comply with those laws.
We may update this Privacy Policy from time to time to comply with applicable law or as our information handling procedures change. The “last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last updated. Please refer to this Privacy Policy each time you use the Services to see the most recent and governing version of the Privacy Policy.
This portion of the Privacy Policy provides the information required under the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), and other California laws. This portion of the Privacy Policy applies solely to residents of the State of California.
Unless otherwise expressly stated, all terms in this portion of the Privacy Policy have the same meaning as defined in our Privacy Policy or as otherwise defined in the CCPA.
As used in this Privacy Notice, “Sensitive Personal Information” means PII that reveals: a consumer’s social security, driver’s license, state identification card, or passport number; a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; a consumer’s precise geolocation; a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; or a consumer’s genetic data. Sensitive Personal Information also means the processing of biometric information for the purpose of uniquely identifying a consumer; PII collected and analyzed concerning a consumer’s health; or PII collected and analyzed concerning a consumer’s sex life or sexual orientation.
For the purpose of clarity, note that you have the same rights for your Sensitive Personal Information as you have for your PII in addition to the specific rights described herein.
Below is a list of all the categories of PII that we have collected in the past 12 months.
| PII Category | PII Examples | PII Collected | Source PII is Collected From | Third Party with whom PII was Shared |
|---|---|---|---|---|
| Identifiers | Cookies, e-mail address, account name, phone-number | Yes | Your browser or device Directly from you | Our business partners and affiliates |
| PII Categories from Cal. Civ. Code § 1798.80(e) | Physical characteristics or description, employment and employment history, medical information, and health insurance information* | No | ||
| Protected Classification Information | Your date of birth and gender information | No | ||
| Commercial Information | Your use of the Services and purchases | Yes | Your browser or device | Our business partners and affiliates |
| Internet/Electronic Network Activity | Your browsing history, search history and interaction with a website | No | ||
| Geolocation Data | Information about your physical location | No | ||
| Audio/Video Data | Pictures and video of you | No | ||
| Professional or Employment-Related Information | Your job title, business team, employer and duties | No | ||
| Non-Public Education Information | As defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99) such as non-public information that can be used to distinguish or trace an individual’s identity in relation to an educational institution either directly or indirectly through linkages with other information | No | ||
| Biometric Information | Your fingerprints and face | No | ||
| Inferences from the Above PII | Inferences drawn from the above PII to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes | No | ||
| Sensitive Personal Information | PII that reveals: your social security, driver’s license, state identification card, or passport number; your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; your precise geolocation; your racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of your mail, email, and text messages unless we are the intended recipient of the communication; or your genetic data. Also, the processing of your biometric information for the purpose of uniquely identifying you; or your PII collected and analyzed concerning your health; or your PII collected and analyzed concerning your sex life or sexual orientation | No |
We may collect, use or disclose your PII for the purposes listed above in this Privacy Policy. Note that even after a contract with you is terminated by cancellation, etc., your PII may still be used within the scope of the above purposes of use. We will only retain your PII for a period no longer than for the purpose such PII was collected.
In the previous 12 months, we have disclosed all of the categories of PII we collect, explained in the table above, to third parties listed in the table above, for the business purposes described above in the Privacy Policy. We do not sell PII to third parties.
We share PII with the categories of third parties listed in the table above for the business purposes listed above.
As a California resident, you may be able to exercise the following rights in relation to your PII that we have collected (subject to certain limitations at law):
You have the right to request the following information regarding your PII we have collected and disclosed in the last 12 months, upon verification of your identity:
These requests can be made no more than twice in a 12-month period.
You have the right to request a copy of the specific PII we have collected in the last 12 months, upon verification of your identity. These requests can be made no more than twice in a 12-month period.
You have the right to request the deletion of PII we have collected from you, subject to certain exceptions such as the exercise of free speech, detection of security incidents, completion of a transaction for which your PII was collected, compliance with a legal obligation, or others listed under Section 1798.105(d) of the California Civil Code.
You have the right to direct us not to sell, as defined under California law, PII we have collected about you to third parties now or in the future. If you are under the age of 16, you have the right to opt-in, or to have a parent or guardian opt-in on your behalf, to such sales and we cannot do the same unless you opt-in in this case. You have the right to opt-out of sharing of your PII for cross-context behavioral advertising. For iOS, we will treat Global Privacy Control browser signals as opt-out of sharing request, as defined in the CCPA, and will also do the same for Android if the sending of such signals becomes a required functionality.
You have the right not to receive discriminatory treatment from us for exercising the rights in this section. However, we may charge you a different price or rate, or provide a different level or quality of goods or services to you, if the difference is reasonably related to the value provided to us by your PII.
In certain circumstances, you have the right to request correction of your PII when such information is inaccurate.
You have the right to direct us to limit our use of your Sensitive Personal Information to that use which is necessary to perform our services or provide our goods, as reasonably expected, such as completing a transaction or for safety purposes.
Please submit a request by emailing them to paddle.develop@gmail.com with the subject line “California Rights Request.”
We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the PII collected in connection with a request to exercise the knowledge, access, correction, limitation or deletion rights to that PII identified in your request, certain requests may require us to obtain additional PII from you. In certain circumstances, we may decline a request to exercise the knowledge, access, correction, limitation and/or deletion rights, particularly where we are unable to verify your identity.
We do not sell to or share, as defined in the CCPA, PII with third parties. If that should change, we will make available to you a method to opt-out of such sharing or sale.
We do not and will not sell the PII of consumers we know to be less than 16 years of age, unless we receive affirmative authorization from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.
If we provide a financial incentive for your PII, we will provide you with the details, including how the incentive is related to your PII before you participate so that you may make an informed decision about whether and how to participate. In the event you decide to take advantage of a financial incentive, you will always have the right to withdraw from participation and we will provide you with directions on how to do so.
California Civil Code Section §1798.83 permits California residents to request certain information regarding our disclosure of certain types of PII to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please send an email to paddle.develop@gmail.com with the subject line “California Rights Request.” This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email address specified in this section.
We do not respond to Do Not Track (DNT) signals. However, for iOS we treat Global Privacy Control (GPC) signals as opt-out of sale and opt-out of sharing for targeted/cross-context behavioral advertising requests, and will do the same for Android if the sending of such signals becomes a required functionality.