Privacy Policy
Last updated: January 08, 2024
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
Please read the terms of this PENNYSIX User Privacy Notice (this “Policy”) carefully. The Policy describes to users (“User,” or “Users,” or “you”) how PENNYSIX LIMITED (“PENNYSIX”, “we,” “us” or “our”) collects, uses, discloses or otherwise processes your personal data collected in connection with websites, mobile applications, progressive web applications, content, features, digital events or products we create or operate (the “Services”). This Policy is incorporated into and forms a part of PENNYSIX’s Global Terms of Use (the “Terms”). As used below, capitalized terms not defined in this Policy have the meaning given to them in the Terms. “Personal data” and “personal information” generally mean any information that directly or indirectly identifies you, which might vary slightly depending on applicable laws. Examples of personal data include your name, phone number, email address, and other information about you such as data about your device or how you use the Services. This Policy does not govern your use of a third-party developer’s game that you discover and access through the Services. The processing of your data by the game developer (“Game Partners”) is governed by the game developer’s privacy policy which you should review prior to using their game and when exercising any rights subject to Game Partners privacy policy.
Please note, if you are younger than 13, you are prohibited from using PENNYSIX's applications.
Be sure to return to this page periodically to review the most current version of the Policy. We may change or otherwise modify the Policy, such as in order to reflect changes in the Services. If we modify it, we will update the "Last Updated" date and will alert users that a change has occurred within the affected Services. Please do not use the Services if you do not accept the current Policy including any addendums that apply to you in Annex A: Region-Specific Notices.
1. INFORMATION WE COLLECT ABOUT YOU
PENNYSIX is the controller, within the meaning of applicable laws, with regard to the collection, processing and use of personal data in the context of the Services and as described in this Policy. This means PENNYSIX is responsible for deciding the purpose and the means of how your personal information will be used and processed. We collect information that you direct us to collect, such as your email,phone or other accountId when you when you claim your reward; indirectly, such as your IP address when you download our app; and from other sources, such as public record sources; or information from our partners or clients, depending on our relationship with them for the purposes listed in this Policy and in accordance with applicable laws. We have specified the personal data we collect in Annex B, Table for Legal Processing Activities, in this Policy.
PENNYSIX may link or combine the personal data we collect through several methods, so that we may provide you with a personalized experience. We generally use personal data to:
• provide, deliver, monitor and improve our Services, which requires us to award Points
• personalize the Services for you with tailored suggestions of games, features and events through the Services
• market PENNYSIX’s Services on third-party platforms, including mobile applications and websites
• offer participation in activities such as contests, sweepstakes and other digital events and determine winners
• meet operational and business transaction requirements such as billing, attribution of game installs, accounting, calculating Points earned in the Rewards Program and delivering prizes for contests, sweepstakes and other promotions
• verify your digital identity to prevent fraud and secure our platform and Services
• develop new products and update features in our Services
• create operational reports and develop insights about our business with aggregate data or in a format that is anonymized and cannot be used to re-identify Users
• communicate with you according to your preferences
• troubleshoot software bugs and operational problems
• provide technical and customer support and respond to requests, complaints and feedback.
The legal basis for PENNYSIX processing your personal data as described in this Policy will typically include one or more of the following:
• performance of our agreement with Users
• meeting our legal and compliance obligations
• our legitimate interest in, for example, monitoring, promoting and improving services we provide, providing customer support, securing the Services, assuring use of our Services in accordance with our Terms, analyzing personal data and developing new products and services
• consent, when required by applicable laws, as further explained in the regional notices in Annex A.
For more information on the legal basis for specific processing activities, see Annex B.
3. HOW WE SHARE PERSONAL INFORMATION ABOUT YOU
We share data with the following third parties that support us in delivering and analyzing the Services.
Corporate Affiliates and Transaction Parties. We may share your personal data with our subsidiaries or affiliates under common corporate control and with counterparties as part of corporate transactions such as merger, sale of company assets, financing or acquisitions.
Law Enforcement, Regulators and Other Parties for Legal and Security Reasons. We may disclose personal data when necessary to protect the legal rights of PENNYSIX, Users or third parties, in order to avoid fraud, manage our risks or comply with applicable laws, legal orders or processes. This includes exchanging information with other companies for these purposes. In these cases, we disclose personal data to comply with legal obligations or to protect the legitimate interests of PENNYSIX or affected third parties.
Service Providers. We have agreements with various service providers to facilitate delivery of our Services, which include those we engage to give customer support, operate the technical infrastructure needed to provide the Services, assist in providing you rewards and protecting and securing our systems and Services and to help market PENNYSIX Services.
Service providers that we use are required by contract to have the same level of privacy protection as we have and will follow the standards of this Policy. Other providers enable us to tailor the Services we provide to you and may also combine the personal data we share with them with other data they collect about you, e.g. your use of their services.
• Advertising Platforms and Networks. We partner with certain providers to either display advertising on their sites, conduct analytics in relation to advertisements or to manage our advertising on other sites. Personal information we disclose to these vendors include device IDs and IP addresses to keep or exclude as part of advertising campaigns for PENNYSIX in order to limit the number of times Users view a specific campaign and to assure we enforce user preferences about receiving messages.
• Marketing Vendors. Our marketing vendors offer general campaign support, administer testing, deliver events to engage with Users and surveys, contests and sweepstakes, subject to applicable law. If you choose to participate in one of these offers, your personal data may be disclosed to these marketing vendors for record keeping purposes, as required by law (e.g to names of sweepstakes winners).
• Analytics. We work with several providers that help us analyze and understand the personal data about you and develop trends, patterns and insights to optimize sales, improve our Services and create new products. These analytics providers also support billing and attribution by providing and analyzing Gameplay Data.
• Game Partners. We may share personal information with our Game Partners, including in some cases, their mobile measurement partners, to provide you, among other things, with personalized content, for marketing purposes, to grow our business and for attribution of game installs and for reporting purposes. If you choose to access a game recommended through our Services, you will share your personal data with the Game Partner that develops the game, subject to the Game Partners’s privacy policies.
PENNYSIX may also disclose aggregated information about Users along with information that does not and cannot identify any individual or device, except where limited by applicable laws. For example, we may use anonymized user ratings, review of apps and aggregated information for statistical and machine learning purposes, to provide insights into developing or enhancing Services, for marketing and advertising and for other legally permissible purposes such as testing our IT systems and features. For more information regarding the sharing of data with third parties please review the applicable sections below and notices within Annex A or contact us as instructed below.
4. HOW WE STORE , TRANSFER AND SECURE PERSONAL INFORMATION ABOUT YOU
We are based in Hong Kong and we store information that we collect from your device on our Amazon Web Services servers in the Hong Kong. The information that we collect may be transferred, stored, or used in other jurisdictions, where some of our providers may be located. While we protect your information by choosing appropriate providers and having contractual safeguards in place with those vendors, the privacy laws in such jurisdictions may not be as protective as in, for example, Hong Kong or the EU.
We maintain administrative, organizational procedures, technical and physical safeguards, consistent with legal requirements where the personal data was obtained, designed to ensure the security and confidentiality against unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the personal data we collect and process.
If you are resident of a country in Europe, please see Annex A below for more information on international data transfers that are applicable to you.
You can always update preferences and exercise rights you may have under applicable data protection laws by contacting us as directed below. However, if you do choose to change preferences, opt-out or withdraw consent where it has been given, your experience with our Services may change, be diminished or your ability to use some of the features and options in our Services may be limited (such as access to Points and the Rewards Program described in our Terms). Please keep us informed if your personal data changes or should be corrected.
For a description of the specific rights with respect to accessing and deleting personal information that are provided to residents of certain European countries, Korea and the states of California, Colorado, Connecticut and Virginia, please see Annex A for Region-Specific Notices. We will handle your request in accordance with applicable laws, such as in relation to response time, verification of identity and content. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Depending on your jurisdiction, your rights may include:
• The Right to Withdraw Consent. Where you provided us with your consent, you may withdraw your consent to the collection and processing of personal data at any time by sending a written request to [email protected]. Upon receiving notice that you have revoked your consent, we will stop processing your personal data without undue delay. Withdrawing consent may impact your use of the Services, such as access to certain events and eligibility for earning rewards.
• The Right to Erase Your Personal Data or Delete Your account. By deleting your account, any Points that you have earned and not redeemed will be deleted. Please note that we may not be able to delete all data you requested, for instance to comply with applicable tax laws.
• The Right to Object to the Processing of Personal Data. If we receive such a request, we will review your objection and delete personal data that we processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or applicable law requires us to retain the data.
6. OTHER IMPORTANT INFORMATION
In accordance with the Terms, you may not use the Service if you are under 13 years old. PENNYSIX is committed to complying with laws protecting children, within the meaning of applicable law. If you believe we might have any information from or about a child, please contact us.
PENNYSIX will only retain personal data for as long as is required by law, as long as you use the Services, or as long as is necessary to meet the purposes for which it was collected. For example, PENNYSIX account balances or rewards earned as of termination must be preserved for some period to allow for such matters as billing and tax reporting. Specifically, we destroy your personal information or store it separately if you do not interact with our services for 5 years.
Note, under the Terms, if a User does not use the Service for at least 180 days, the User’s inactive account may be terminated, Points earned may automatically expire and personal data may be deleted.
You may also ask us to delete your account. By deleting your account, however, any Points that you have earned and not redeemed will be deleted. Otherwise, if we choose to maintain or use de-identified information, we continue to do so in a de-identified manner and will not attempt to re-identify you. To delete personal data held by Game Partners, you must contact them as directed under the terms of the Game Partners privacy policy.
If you have questions that do not relate to this Policy or data privacy, please write to our customer support team and Submit a Request. To exercise applicable data protection rights or comment about this Policy and our privacy practices to the extent you may enjoy any data subject rights as per privacy laws applicable to you, you may reach out to our data protection office at:
Data Privacy Officer
PENNYSIX LIMITED
188 GRAND ST NEW YORK，NY10013
or via email at [email protected]
ANNEX A: REGION-SPECIFIC NOTICES
We may choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions or states.
EUROPE AND UNITED KINGDOM NOTICE
SPECIFIC NOTICE FOR RESIDENTS OF THE UNITED STATES
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