Privacy Policy

2.1 Introduction

This Privacy Policy explains how PlayToEarn PTE. LTD. ("we", "us", "our") collects, uses, discloses, and protects personal data when you visit or use https://playtoearn.com (the "Site"). We are committed to protecting your privacy and processing your personal data in accordance with the EU General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act (CCPA/CPRA), and the Singapore Personal Data Protection Act (PDPA), as applicable.

By using the Site, you acknowledge that you have read and understood this Privacy Policy.

2.2 Data Controller

The data controller responsible for your personal data is:

2.3 Personal Data We Collect

We collect the following categories of personal data:

(a) Information you provide directly

• Account information: username, e-mail address, password (stored hashed), date of birth, country of residence, language preference.
• Payout information: e-mail address linked to your payout method, cryptocurrency wallet address, or other identifiers required to deliver rewards.
• Identity verification (KYC): government-issued ID, selfie, proof of address – requested only when required for fraud prevention or compliance.
• Communication: any messages, support tickets, or feedback you send to us.

(b) Information collected automatically

• Device and connection data: IP address, browser type and version, operating system, device identifiers, screen resolution, language settings, time zone.
• Usage data: pages viewed, offers clicked or completed, referral source, timestamps, clickstream data, performance metrics.
• Cookies and similar technologies: see our Cookie Policy.

(c) Information received from third parties

• Offerwall and advertiser providers (e.g., Revenue Universe, Torox, AyetStudios) confirm offer completions and may share related transaction data.
• Payment and reward processors confirm successful payouts.
• Fraud prevention partners may provide risk scores and signals associated with your IP, device, or behavior.
• Analytics providers (e.g., Google Analytics, Cloudflare) provide aggregated and individual usage information.

2.4 Purposes and Legal Bases

We process your personal data for the following purposes and on the following legal bases under the GDPR (where applicable):

1. Providing the Service – creating and managing your account, crediting Coins, processing payouts. Legal basis: performance of a contract (Art. 6(1)(b) GDPR).
2. Fraud prevention and security – detecting multi-accounting, bot activity, abuse, and unauthorized access. Legal basis: legitimate interest (Art. 6(1)(f) GDPR) and legal obligation (Art. 6(1)(c) GDPR).
3. KYC and compliance – verifying your identity, complying with anti-money-laundering and sanctions laws. Legal basis: legal obligation (Art. 6(1)(c) GDPR).
4. Communications – responding to support requests, sending transactional e-mails. Legal basis: performance of a contract and legitimate interest.
5. Marketing – sending newsletters, promotional offers, and product updates. Legal basis: consent (Art. 6(1)(a) GDPR), which you may withdraw at any time.
6. Analytics and product improvement – understanding how the Service is used and improving its functionality. Legal basis: consent for non-essential cookies, legitimate interest for aggregated analytics.
7. Legal claims and dispute resolution – establishing, exercising, or defending legal claims. Legal basis: legitimate interest and legal obligation.

2.5 Recipients of Your Personal Data

We share personal data only as necessary with the following categories of recipients, all of whom are bound by appropriate confidentiality and data protection obligations:

1. Offerwall and advertiser providers, including Revenue Universe, Torox, and AyetStudios, in order to track offer completion and credit Coins.
2. Hosting and infrastructure providers, including Cloudflare, which provides content delivery, DDoS protection, and security services.
3. Analytics providers, including Google Analytics, which help us understand aggregated usage patterns.
4. Payment and reward processors that deliver cash, cryptocurrency, or gift card rewards.
5. Identity verification and fraud prevention providers.
6. Professional advisors (lawyers, auditors, accountants) where necessary for legal or regulatory purposes.
7. Public authorities, regulators, or courts where required by law or to protect our legal rights.

We do not sell your personal data. For California residents, we do not "sell" or "share" personal information as those terms are defined under the CCPA/CPRA, except as may be implied through our use of cookies and analytics tools, for which you can opt out at any time.

2.6 International Data Transfers

As an organization based in Singapore, we may transfer personal data outside of the European Economic Area, the United Kingdom, or your country of residence. Where we do so, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses, adequacy decisions, or other lawful transfer mechanisms.

2.7 Data Retention

We retain personal data only as long as necessary to fulfil the purposes for which it was collected, including any legal, accounting, or reporting requirements. As a general rule:

• Account data: for as long as your account is active, and up to 24 months after closure for fraud-prevention purposes.
• Payout records: up to 7 years to comply with financial and tax record-keeping obligations.
• KYC documents: as required by applicable anti-money-laundering law.
• Server logs: typically up to 12 months.
• Marketing data: until you withdraw consent.

2.8 Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

1. Right of access – obtain confirmation of whether we process your personal data and a copy of it;
2. Right of rectification – correct inaccurate or incomplete data;
3. Right of erasure ("right to be forgotten") – have your personal data deleted under certain conditions;
4. Right to restriction of processing;
5. Right to data portability;
6. Right to object to processing based on legitimate interest or for direct marketing;
7. Right to withdraw consent at any time, where processing is based on consent;
8. Right to lodge a complaint with a supervisory authority in your country of residence;
9. For California residents: rights to know, delete, correct, and opt out of "sale" or "sharing" of personal information, as well as the right to non-discrimination for exercising these rights.

To exercise any of these rights, please contact us at [email protected]. We will respond within the timeframes required by applicable law.

2.9 Security

We implement appropriate technical and organizational measures designed to protect personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption in transit (TLS), hashed password storage, access controls, network monitoring, and regular review of our security practices. However, no method of transmission over the Internet is completely secure, and we cannot guarantee absolute security.

2.10 Children

The Service is not directed to individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that a minor has provided us with personal data, we will delete it without undue delay.

2.11 Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or in applicable law. The "Last updated" date at the top of this document indicates when it was last revised. Material changes will be announced through the Site or by e-mail.

2.12 Contact

For any questions, requests, or concerns regarding this Privacy Policy or the processing of your personal data, please contact: [email protected].