Categories of Information Collected
The type of information we collect depends on how you use the Services. Generally, we collect the following information:
Identifiers / Contact Information: Name, user name, gamertag, postal and email address, phone number, unique IDs, mobile device ID, platform ID, gaming service ID, advertising ID (IDFA, Android ID) and IP address
Protected Characteristics: Age and gender
Commercial Information: Purchase and usage history and preferences, including gameplay information
Billing Information: Payment information (credit / debit card information) and shipping address
Internet / Electronic Activity: Web / app browsing and gameplay information related to the Services; information about your online interaction(s) with the Services or our advertising; and details about the games and platforms you use and other information related to installed applications
Device and Usage Data: Device type, software and hardware details, language settings, browser type and version, operating system, and information about how users use and interact with the Services (e.g., content viewed, pages visited, clicks, scrolls)
Profile Inferences: Inferences made from your information and web activity to help create a personalized profile so we can identify goods and services that may be of interest
Audio / Visual Information: Account photos, images, and avatars, audio information via chat features and functionality, and gameplay recordings and video footage (such as when you participate in playtesting)
Sensitive Information: Precise location information (if you allow the Services to collect your location), account credentials (user name and password), and contents of communications via chat features and functionality.
How We Use Information and Our Legal Grounds
We use the information we collect within Glay as follows, pursuant to various legal bases:
Business Purposes: Provide the Services and support; fulfill orders and requests; improve the Services and our business; develop new products and services; enhance your experience on the Services; protect the security for our users, employees, facilities, and Services; and develop internal marketing and demographic studies
Commercial Purposes: Market and advertise our and our business partners' products and services; send you promotional materials; and administer promotional activities or events
We also use your information as permitted by law.
We use information we collect for our business purposes, including to:
Provide the Services
Fulfill product orders and other requests, respond to your questions, and communicate with you
Enhance and personalize your experience on the Services, including to recognize you, maintain your preferences and settings, connect you with other users and link to your third-party platform, gaming, and social networking accounts
Provide technical and other support
Review the use and operations of the Services, develop new products or services, and conduct analyses to enhance or improve our software, content, marketing, support, and Services
Conduct internal marketing and demographic studies
Address issues with the Services or other business needs
To protect the security or integrity of the Services, users and our business such as by protecting against and preventing violation of our terms and policies, including combating fraud, piracy, cheating, tampering, unauthorized transactions, claims, and other liabilities, and managing risk exposure
Interact on your behalf with the third-party platform, gaming, and social networking accounts you connect with our Services
Participate in other processing that we inform you about when you provide your information or when you consent to such processing
As permitted by law
We use information we collect for commercial purposes, including to:
Provide you and other users with customized content, targeted offers, and advertising on the Services, via email and text message, or on other sites, mobile applications, or social media on behalf of Glay or our business partners
Contact you with information and promotional materials
Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners
Analyze our users, in combination with other data, to assess our user base and target marketing at other similar groups
---Legal Reasons to Process Personal Data
If you are based in a location that requires us to establish legal grounds, we process your information on the following grounds:
Establish and perform our contract with you (such as the terms applicable to our Services, or to take steps at your request, such as to complete transactions with you and to allow you to play our games online)
Compliance with a legal obligation
For our or our partners' legitimate interests, such as to improve our products and services; perform analytics to better understand our users; conduct direct marketing (when we do not need your consent); otherwise supporting our business, operations, and services; and enforce and prevent violations of our terms or policies
Protect your vital interests or those of another person (for example, another player)
With your consent, such as when you sign up for direct marketing or you connect your Glay account with a third-party service
Sources of Information We Collect
How we obtain information depends on how you use the Services. For example, we collect information:
you provide directly to us, such as when you set up an account, sign-up for marketing, or contact us
about the games you play (automatically)
from third-party platforms, such as when you play our games or access our Services with third-party accounts
automatically, including through cookies and similar tracking technologies
from third parties, such as advertising networks, business partners, third party information providers, and other players
---Information You Provide
You provide us with information when you use the Services, such as when you:
create an account or use the Services
subscribe to marketing and communications
comment on our message boards, forums, chat rooms, feeds, sites, or other Services
purchase or redeem one of our products or services, including physical items, virtual items, virtual currency, or add-ons
download, install, or access demos, programs, or other software
contact us for support or other purposes
use our email or share features
participate in events, contests, promotions, surveys, or playtesting
participate in an activity where you provide your information
Depending on the Service or your activity, we collect information such as your name, email address, phone number, photo, mailing address / zip code, payment or purchase information, age, gender, password, platform ID, software products played, survey data, geolocation, and the systems or platforms you play on. We combine this information across devices that you use.
---Gameplay Information
When you use the Services, we automatically receive information about your gameplay. Gameplay information includes your platform ID or gaming service ID, game achievements, game scores and performance, IP address, MAC address or other device IDs, other platform / device information, and other information and statistics regarding your use of the Services. We collect gameplay information even if you do not register for the Services. We may combine gameplay information with other information we have about you. We also may use internal and third-party anti-cheat technologies to detect and prevent cheating within our Services.
---Platform, Gaming, and Social Networking Information
We collect information when you access our Services with third-party platform accounts, such as a gaming platform account, gaming network service account, or social networking service account. When you access our Services in this way, the third-party platforms provide us with information about you. For example, depending on your use of, or activity on the third-party platform, we receive your user name, your friends list, or account information necessary to provide the Services or a purchased in-game item. The third-party platform may allow you to control what information is provided to us. We are not responsible for the terms, policies, disclosures or actions of any third-party platforms.
---Cookies and Similar Technologies
We may use cookies, web beacons, pixel tags, Flash cookies, Internet log files, software developments kits and similar tracking technologies to improve and maintain the functionality of our Services; enhance security and fraud prevention; and provide you with targeted advertising. Our system may not respond to Do Not Track requests or headers from some or all browsers. The Manage Your Account, Communications, and Data section provides additional information about our use of cookies and similar technologies and your ability to manage cookies. You may also use the cookie preference tool, where available, or visit the Cookie Policy posted on the Service for more information.
---Information from Third Parties
We receive information from third parties to update the information that we collect about you. We may receive information from public databases, platform manufacturers, analytics providers, game developers, and other business partners and Glay Group involved in providing the Services to you, that includes demographic information and information about your interests. We may collect publicly available information, including from social media, to protect our users, employees, facilities, and Services, and to aid investigations. We also receive information from other individuals who use our Services. This may include information about you if you are mentioned in comments on the Services or an individual sends us a direct message.
When We Share Information
As detailed below, we share your information with:
vendors that perform support and other services for us
Glay group members
advertising service providers and partners
other third parties (e.g., for collaborative offerings, legal and safety purposes, in connection with the sale or transfer of a business or asset, and other purposes with your permission)
other users, such as when you participate in open communities or events, or information published on leaderboards
In the last 12 months, Glay has sold and/or shared unique identifiers, IP address, as well as Internet/Electronic Activity and Profile Inferences with third-party advertising providers to enable us to provide personalized advertising to you and others like you. We do not sell or share personal information about persons that we know are under the age of 16 without their (or depending on age, their parent's) consent.
Public Postings
If you share personal information, post an image or video, or provide other content in public forums such as on a message board, chat room, comment field, or profile page, other people can view, collect, and use that information. If your user name or ID contains your name, your name will be publicly available on leaderboards and elsewhere as described in this Privacy Policy. Users of such public forums may be able to identify you, use the information to send you messages, or copy any of the images, video, or content you have shared. There is no expectation of privacy or confidentiality on any of these public forums. Please do not share your personal information in public forums or in your user name or ID. You are responsible for any information or content you publicly post using our Services.
Data Rights
Depending on your location, you may have certain rights over your personal information, including the right to:
Request access to or a copy of your personal information
Request deletion of your personal information
Request correction or modification of your personal information
Be informed about the personal information we collect and/or process about you, the sources of personal information, and the third parties with whom information was shared or sold and for what purposes
Withdraw consent, if processing is based on consent
Opt-out of the sale or sharing of your personal information (including targeted advertising)
Opt-in/out of financial incentives
Limit the use and disclosure of your sensitive personal information
You can make a data rights request in relation to your personal information here. We will respond to data requests within a month. We may take steps to verify your identity before we can respond to your request. To the extent these rights apply to you, they may be limited in some situations -- for example when we are under a legal requirement or have a compelling interest for processing your personal information, or when the personal information is protected by trade secret. If you have unresolved concerns, where applicable, you may also have the right to complain to a privacy authority. A list of privacy authorities is available here. Alternatively, if you wish to make a data request or appeal a data request decision, please contact Glay using the details provided in the Contact Us section.
To opt out, please click on the Do Not Sell or Share My Personal Information on our site footer (and available here) and follow the instructions on that page. To opt out of online personalized advertising more broadly, please see the opt-out options identified in the Manage Your Account, Communications, and Data section. We will not discriminate against you for exercising any of these rights.
You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you've authorized them to act on your behalf, or must demonstrate they have power of attorney pursuant to applicable probate law. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent's identity.
Manage Your Account, Communications, and Data
We provide several options for you to manage your Service account, communications you receive from us, and how we use your information. These include through the settings in your Service account; email unsubscribe and deletion tools; and opting out of interest-based ads.
More information about how to manage your label-specific account and communications is available here.
---Service Accounts
You can manage how we use your personal information and the communications that you receive from us through the account, communications, and privacy settings in your Services account.
---Email Unsubscribe
You can unsubscribe from marketing emails from Glay or a specific label or division by using the unsubscribe link provided in the email.
---Interest-Based Ads
On your mobile device, you may adjust your privacy and advertising settings to control whether you want to receive advertising based on your interests. To opt out from the use of your online activities for interest-based activities by participating providers, please visit the Network Advertising Initiative at http://www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance at http://www.aboutads.info/. For visitors from the UK, EU, EEA or Switzerland, visit Your Online Choices at http://www.youronlinechoices.eu/.
Data Retention
We'll keep your information for as long as necessary to provide you with the Services, fulfil our legal obligations, and/or exercise, defend or establish our rights.
We retain your information while your account is active, as needed to provide you Services, or to administer our Services. If you wish to delete your account or request that we no longer use your personal information to provide Services to you, contact us as identified in the Manage Your Account, Communications, and Data section. If your account is inactive, we will maintain your account for the length of time for which we reasonably expect you to reengage with our Services. After such period, we will delete personal information, including your email address and log-in credentials, and you may no longer be able to access your account. We may still retain some of your personal information in our files for a reasonable period of time to resolve disputes, enforce our terms and policies, administer our Services, comply with technical and legal requirements, and/or other constraints related to the security, integrity, and operation of our Services, after which we will take steps to delete or archive your personal information.
Children's Privacy
Generally, we direct our Services to a general audience and we do not knowingly collect personal information from children under 13 years old (or older, if applicable law provides for different protections). We may direct certain Services to an audience of all ages---including children. For these Services, we may restrict the collection of personal information on the Services from anyone, apply an age gate allowing children to use the Services while restricting the collection of personal information on the Services from children, or get a parent's permission to collect personal information from children. If we become aware that a child has provided personal information without a parent's permission, we will promptly delete this information. We encourage parents to instruct their children to never give out their real names, addresses, or phone numbers, without permission, when using the Internet.
Data Security
We follow generally accepted industry standards and maintain appropriate safeguards to help protect the security, integrity, and privacy of the information we collect about you. These security measures are designed to protect against the accidental or unlawful destruction, loss, misuse, alteration, and unauthorized disclosure of, or access to, the information under our control. However, no system can be 100% secure and we cannot guarantee our security measures.
International Transfers
We and our vendors and partners may process, transfer, and store information about you in connection with the Services in the United States and other countries that may not have privacy laws equivalent to the country where you reside. We take steps to apply appropriate safeguards when we transfer that information.
When your information is in another country, it may be accessed by the courts, law enforcement, and national security authorities pursuant to the laws of that country. If you reside in the UK, EU, EEA or Switzerland, we rely on Standard Contractual Clauses and/or other approved legal mechanisms to transfer personal information from the UK, EU, EEA or Switzerland to countries located outside of these locations (as applicable). To request a copy of such Standard Contractual Clauses, if applicable, please make a data request as provided under the Data Rights or Contact Us section.
Other Glay Terms, Third-Party Terms, and Links to Other Sites
Use of our services and products may be subject to other terms and disclosures provided by us, platform manufacturers, and other partners, including: (i) the terms that accompanied your purchase; (ii) terms applicable to online Services; (iii) other terms and disclosures made available to you by us or third parties. We are not responsible for practices on third-party sites that may be linked to the Services.
---In-Game Transactions and Reseller / Store
The third-party platform you use to access the Services, or the online reseller, governs in-game transactions. We may process Glay online store transactions directly or through our official online resellers. These transactions are subject to both Glay's and the third-party platform or online store's privacy policy and terms (as applicable). Please review the third-party's terms and privacy policy for more details on their policies.
---Third-Party Services
If you connect to us through third-party services such as platform, mobile device, gaming, and social networking accounts, that third-party's terms and privacy policy govern your use of that service. We are not responsible for third-party services.
---Third-Party Sites
Our Services may direct you to third-party sites. If we link to another site, it is not an endorsement, authorization, or representation of our affiliation with that third party. Please review the privacy policy of the other site before you submit any of your personal information to that site.
Contact Us
If you have questions about this Privacy Policy, please use https://www.palgame.vip/contactus/ to contact our Data Protection Officer. You may also contact us or our Data Protection Officer by mail at the addresses below. Please identify your location in your message. You may also have the right to complain to a privacy authority. You may also contact us by email at [email protected].
Country | Address |
Non-European Countries | Glay Game, Inc. 110 W 44th Street, New York, NY 10036 USA, Attn: Privacy Policy Administrator |
UK, EU, EEA, or Switzerland (“European Countries”) | Glay Game Limited Glay House 30 Cleveland Street, London W1T 4JD, UK Attn: Privacy Policy Administrator |
For purposes of privacy laws, the data controller of your personal information is Glay Game Limited. Depending on the Services, our labels and divisions may be considered data controllers, either together with Glay Interactive or by themselves. Data controller and representative information and contact details are listed here. References in this Privacy Policy to Glay should be interpreted as references to the applicable Glay entity identified as the controller of personal information for the particular Services you are using.
Changes to Privacy Policy
We reserve the right to make changes to this Privacy Policy. Please check back from time to time to review these changes. If we change this Privacy Policy in a material way, we will provide appropriate notice to you and, as appropriate, provide additional choices regarding such change. As permitted by applicable law, your continued use of the Services means that you accept these changes.