PLAYNOMIC PRICACY POLICY

This Privacy Policy sets forth how personal information is collected and used, that is provided on Internet Web site located at www.playnomic.com (the “Site”) and our mobile application (collectively, “Playnomic Technology”). Unless otherwise indicated, this Privacy Policy only applies to personal information collected through Playnomic Technology by Hudson Street Labs Limited or any of its  respective affiliates (together, for purposes hereof, “Playnomic”). By using the Playnomic Technology, you agree to be bound by this Privacy Policy and our Terms of Use, as they may be amended from time to time in the future (see "Change to this Privacy Policy" below).

Playnomic is committed to maintaining the confidentiality, integrity and security of any personal information about our users. This Privacy Policy explains how we protect personal information provided through the Playnomic Technology and how we use that information in connection with our service offered through the Playnomic Technology (the "Service"). "Personal information" for purposes of this Privacy Policy means information that identifies you, such as your name, address, phone number, fax number or email address.

Playnomic privacy and security standards to guard against identity theft and provide security for your personal information. We regularly re-evaluate our privacy and security policies and adapt them as necessary to deal with new challenges.

Personal Information Collected

We collect the following personal information from you:

• contact information such as name, email address, mailing address, phone number;
• stored contacts from your mobile phone from including information such as name and phone number;
• financial information such as bank account numbers and transaction;
• unique identifiers such as username, account number, password; and
• demographic information such as age, education, gender, interests, and zip code.
  
• biometric data– As part of the verification process, we may collect biometric information from government IDs and images to verify your identity

When you visit the Site or download and use our Services, we may automatically collect certain information sent to us by your computer, mobile device, or any other device. This information may include the type of device you use, operating system, the device identifier (or "UDID"), your IP address, location, mobile network information, and standard web log information, such as your browser type traffic to and from our site, the pages you accessed on our website, and other available information. We may also collect information about your use and interaction with the Site, our mobile application, or our Services. For example, we may evaluate your computer, mobile phone, or other access device to identify any malicious software or activity that may affect the availability of the Services. When you use the Services, we may also store information based on your usage history. This includes, but is not limited to, details of your purchases, content you viewed, event information, click stream information, and cookies that may uniquely identify your browser or your account.

Information Sharing

Playnomic uses and discloses your personal information only as follows:

• to analyze site usage and improve the Service;
• to deliver to you any administrative notices, money alerts, and communications relevant to your use of the Service;
• to enable product features such as the leaderboard and invite a friend;
• to fulfill your requests for certain products and services;
• for market research, project planning, troubleshooting problems, and detecting and protecting against error, fraud, or other criminal activity;
• to third-party contractors that provide services to Playnomic and are bound by these same privacy restrictions;
• to enforce Playnomic'c Terms of Use; and as otherwise set forth in this Privacy Policy.

In addition, we may, from time to time, offer promotions with various businesses, websites, mobile applications or third parties, which may include opportunities for you to earn deposits within your Playnomic account. Each such promotion will be subject to and governed by our Terms of Use, this Privacy Policy, and any applicable rules or terms and conditions we may post online, post in our mobile application, include within e-mail or other communications, or otherwise make available to you. To the extent you elect to participate in any such promotion or otherwise make any purchase subject to a promotion, we may share personal information such as name, e-mail address, purchase dates, and other related information with the applicable third party for the limited purpose of allowing the parties the make the promotion available and track participation within such promotion.

We may use information you provide to connect you with people you may already know. For example, through our mobile application we may identify contacts within your address book as potential new users of Playnomic. We may match the contact information you provide to the information provided by other users to improve the Service, including making it easier to find contacts you may refer to Playnomic that are not already customers.

We may also disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

If you are a EU resident, we will not share personal information we collect about you except to the extent permitted under EU law.

If Hudson Street Labs Limited is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Third Party Services

Playnomic uses Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using the Service, you grant Playnomic and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy.

User Access and Choice

If the personal information on file for you changes, or if you no longer desire our service, you may correct or update by emailing us at support@playnomic.com.

We will retain and use your information as necessary to comply with our legal and/or regulatory obligations, resolve disputes, and enforce our agreements.

If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us at the information below.

Cookies / Tracking Technologies

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on the Site. We do not link the information we store in cookies to any personally identifiable information you submit while on the Site.

We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory.

If you reject cookies, you may still use the Site, but your ability to use some areas of the Site, such as contests or surveys, may be limited.

The use of cookies by our partners, affiliates, tracking utility company, and/or service providers is not covered by our Privacy Policy. We do not have access or control over these cookies. Our partners, affiliates, tracking utility company, and/or service providers use session ID cookies to make it easier for you to navigate the Site.

We employ (and/or our third-party advertising partner employs) a software technology called clear gifs (sometimes known as web beacons or web bugs), that help us better manage content on the Site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ personally identifiable information.

Security

The security of your personal information is important to us. When you enter sensitive information, such as a credit card number or financial information, on our forms, we encrypt the transmission of that information using secure socket layer technology (SSL).

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on the Site, please contact us.

Changes to this Privacy Policy

We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we will notify you by email or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

If you have any questions about our Privacy Policy, please contact Playnomic's Customer Service at:

support@playnomic.com

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Under the General Data Protection Regulation (GDPR), we process the following categories of personal data about EU residents:

Categories of Personal Data

Identity Data: First name, last name, username or similar identifier, title, date of birth, and gender.

Contact Data: Email address, telephone numbers, billing address, delivery address.

Financial Data: Bank account details, payment card details, transaction history.

Technical Data: Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our services.

Profile Data: Your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data: Information about how you use our website, products and services.

Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties and your communication preferences.

Special Categories of Personal Data: We may process biometric data for identity verification purposes. We will only process this data with your explicit consent or where otherwise permitted by law.

Legal Basis for Processing

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Contract Performance: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legal Obligations: Where we need to comply with a legal obligation.
• Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Consent: Where you have given us explicit consent to process your personal data for specific purposes.

Specific Legal Bases by Purpose:

• To register you as a new customer: Performance of a contract with you
• To process and deliver your service: Performance of a contract with you; Necessary for our legitimate interests
• To manage our relationship with you: Performance of a contract with you; Necessary to comply with a legal obligation; Necessary for our legitimate interests
• To administer and protect our business: Necessary for our legitimate interests; Necessary to comply with a legal obligation
• To deliver relevant content and advertisements: Necessary for our legitimate interests
• To use data analytics: Necessary for our legitimate interests
• To process biometric data: Your explicit consent

Your Rights Under GDPR

As an EU resident, you have the following rights regarding your personal data:

1. Right to Access (Article 15)

You have the right to request access to your personal data and receive a copy of the personal data we hold about you.

2. Right to Rectification (Article 16)

You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.

3. Right to Erasure (Article 17)

You have the right to request that we erase your personal data, under certain conditions:

• The personal data is no longer necessary for the purposes for which it was collected
• You withdraw consent and there is no other legal ground for processing
• You object to the processing and there are no overriding legitimate grounds
• The personal data has been unlawfully processed
• The personal data must be erased for compliance with a legal obligation

4. Right to Restrict Processing (Article 18)

You have the right to request that we restrict the processing of your personal data, under certain conditions:

• You contest the accuracy of the personal data
• The processing is unlawful and you oppose erasure
• We no longer need the data but you require it for legal claims
• You have objected to processing pending verification of legitimate grounds

5. Right to Data Portability (Article 20)

You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

6. Right to Object (Article 21)

You have the right to object to our processing of your personal data under certain conditions:

• Processing based on legitimate interests or the performance of a task in the public interest
• Direct marketing (including profiling)
• Processing for purposes of scientific/historical research and statistics

7. Rights Related to Automated Decision-Making (Article 22)

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

8. Right to Withdraw Consent

Where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

Exercising Your Rights

To exercise any of your rights under GDPR, please submit a request to us by:

• Email: support@playnomic.com
• Website: playnomic.com

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Response Timeframe

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. We will not charge a fee for responding to your request unless it is excessive, repetitive, or manifestly unfounded.

International Data Transfers

We may transfer your personal data outside the European Economic Area (EEA). When we do, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards:

• Transfers to countries with adequacy decisions by the European Commission
• Use of Standard Contractual Clauses approved by the European Commission
• Transfers to organizations with approved Binding Corporate Rules

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Data Protection Officer

While we may not be legally required to appoint a Data Protection Officer, we have designated a privacy contact who can be reached at support@playnomic.com for any questions or concerns regarding our data processing activities.

Complaints

You have the right to make a complaint at any time to your local supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

EU Supervisory Authorities

Each EU member state has its own data protection supervisory authority. You can find your local authority at: https://edpb.europa.eu/about-edpb/board/members_en

Changes to This Privacy Notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

Contact Information

If you have any questions about this privacy notice or our privacy practices, please contact us at:

Website: playnomic.com
Email: support@playnomic.com
Data Protection Contact: support@playnomic.com

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