PLLAY Labs, Inc. ("PLLAY," "we," "us," or "our") operates the PLLAY platform (the "Service"). This Privacy Policy describes how we collect, use, share, and protect your personal information when you use our Service. By using the Service, you agree to the practices described in this policy.

PLLAY Labs, Inc.
12828 Willow Centre Drive, Ste D142
Houston, Texas 77066
privacy@pllay.io

1. Information We Collect

We collect the following categories of personal information:

Account Information: Name, email address, and password when you create an account
Profile Information: Display name, avatar, and other profile details you choose to provide
Usage Data: Information about how you interact with the Service, including prediction history, participation data, engagement metrics, and session logs
Device & Technical Information: Browser type, operating system, IP address, device identifiers, referring URLs, and access timestamps
Payment Information: When applicable, payment details are processed by our third-party payment processor (e.g., Stripe) and are not stored on our servers
Communications: Records of your communications with us, including support tickets and emails

2. Legal Bases for Processing (GDPR)

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, we process your personal data under the following legal bases:

Contract Performance: Processing necessary to provide the Service you requested (account management, transaction processing, delivering predictions and league functionality)
Legitimate Interest: Processing for our legitimate business interests, such as improving the Service, preventing fraud, enforcing our terms, and marketing (where we have balanced these interests against your rights)
Consent: Processing based on your explicit consent, such as receiving marketing communications or enabling optional cookies. You may withdraw consent at any time
Legal Obligation: Processing required to comply with applicable laws, regulations, or legal processes

3. How We Use Your Information

We use collected information to:

Provide, maintain, and improve the Service
Process transactions and manage your account
Send you updates, security alerts, and support messages
Personalize your experience and deliver relevant content
Monitor and analyze usage trends to improve the platform
Detect, investigate, and prevent fraudulent or unauthorized activity
Comply with legal obligations and enforce our Terms of Service

4. Information Sharing

We do not sell your personal information to third parties for monetary consideration. We may share information with:

Service Providers: Third parties that help us operate the Service (hosting, analytics, payment processing, customer support). These providers are contractually obligated to protect your data
Legal Requirements: When required by law, subpoena, court order, or legal process
Business Transfers: In connection with a merger, acquisition, reorganization, or sale of assets
With Your Consent: When you explicitly authorize us to share information
Aggregated/De-identified Data: We may share aggregated or de-identified data that cannot reasonably be used to identify you

5. Cookies & Tracking Technologies

We use cookies and similar technologies to enhance your experience. Categories of cookies we use include:

Strictly Necessary Cookies: Required for the Service to function (authentication, security). These cannot be disabled
Analytics Cookies: Help us understand how users interact with the Service. Used with your consent where required
Functional Cookies: Remember your preferences and settings
Marketing Cookies: Used to deliver relevant advertising. Only activated with your explicit consent

Cookie Consent: When you first visit the Service, we will present a cookie consent mechanism that allows you to accept or reject non-essential cookies. You may update your preferences at any time through the cookie settings link in the Service footer. For users in the EEA/UK, non-essential cookies are not placed until you provide affirmative consent, in compliance with GDPR and the ePrivacy Directive.

6. Data Retention

We retain your personal information according to the following schedule:

Account Data: Retained for the duration of your active account plus 30 days after account deletion to process final payouts and resolve disputes
Transaction Records: Retained for 7 years after the transaction date to comply with tax and financial reporting obligations
Usage & Analytics Data: Retained in identifiable form for up to 24 months, then aggregated or anonymized
Communication Records: Retained for up to 3 years after the date of communication
Legal Hold: Data subject to a legal hold, regulatory investigation, or active dispute will be retained until the matter is resolved

7. Your Rights

Depending on your jurisdiction, you may have the right to:

Access and receive a copy of your personal data
Correct inaccurate personal data
Request deletion of your personal data
Object to or restrict processing of your data
Data portability (receive your data in a structured, machine-readable format)
Withdraw consent at any time (without affecting the lawfulness of prior processing)
Lodge a complaint with a supervisory authority

To exercise any of these rights, please contact us at privacy@pllay.io. We will respond to verified requests within 30 days (or 45 days if an extension is needed, with notice to you).

8. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

Categories of Personal Information Collected

In the preceding 12 months, we have collected the following categories of personal information as defined by the CCPA:

Identifiers: Name, email address, IP address, account name
Internet/Electronic Activity: Browsing history on the Service, interaction data, prediction history, engagement metrics
Commercial Information: Transaction records, participation fees, creator revenue data
Geolocation Data: Approximate location derived from IP address

Sale and Sharing of Personal Information

We do not sell your personal information for monetary consideration. We may share certain information (such as device identifiers and usage data) with analytics providers, which may constitute "sharing" under the CPRA. You have the right to opt out of this sharing.

Your California Rights

Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected about you
Right to Delete: Request deletion of your personal information, subject to certain exceptions
Right to Correct: Request correction of inaccurate personal information
Right to Opt Out of Sale/Sharing: Direct us not to sell or share your personal information
Right to Limit Use of Sensitive PI: Limit our use of sensitive personal information to purposes necessary to provide the Service
Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights

To exercise these rights, contact us at privacy@pllay.io or submit a request through the Service. We will verify your identity before processing your request. You may also designate an authorized agent to make requests on your behalf.

Do Not Sell or Share My Personal Information: To opt out of the sharing of your personal information with analytics providers, please contact us at privacy@pllay.io with the subject line "Do Not Sell or Share."

9. European Data Protection (GDPR)

Data Protection Officer

Our Data Protection Officer can be contacted at dpo@pllay.io for any questions regarding the processing of your personal data or the exercise of your rights under the GDPR.

EU/UK Representative

If you are located in the EEA or UK and have concerns about our data processing, you may contact our designated EU representative by emailing dpo@pllay.io.

International Data Transfers

Your information may be transferred to and processed in the United States and other countries outside the EEA/UK. When we transfer personal data internationally, we use appropriate safeguards including Standard Contractual Clauses (SCCs) approved by the European Commission and, where applicable, supplementary measures to ensure an adequate level of data protection.

Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority in the EU/EEA member state of your habitual residence, place of work, or place of the alleged infringement.

10. Data Security

We implement industry-standard security measures to protect your personal information, including encryption in transit (TLS 1.2+) and at rest, access controls, regular security audits, and incident response procedures. However, no method of transmission over the Internet is 100% secure, and we cannot guarantee absolute security.

11. Children's Privacy

The Service is not intended for users under 18 years of age. We do not knowingly collect personal information from children. If we learn that we have collected information from a child under 18, we will delete that information promptly. If you believe a child has provided us with personal information, please contact us at privacy@pllay.io.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes at least 30 days in advance via email or through a prominent notice on the Service. Your continued use of the Service after the effective date of changes constitutes acceptance of the updated policy.

13. Contact

For questions or concerns about this Privacy Policy, please contact us:

PLLAY Labs, Inc.
12828 Willow Centre Drive, Ste D142
Houston, Texas 77066
Email: privacy@pllay.io
Data Protection Officer: dpo@pllay.io