We at Plinga GmbH (“Plinga”, “we”, “us” or “our”) respect your privacy and recognise the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process your personal data.
The purpose of this privacy notice (“Privacy Notice”) is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you, “Personal Data”) when you visit www.plinga.com (“Website”). This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing.
This Privacy Notice applies whenever you visit our Website or play the games, all of which together we refer to as “Services”.
In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you use our Services. For specific information with more details about our processing activities, please see the service specific information below.
1. Who is responsible for the processing of your Personal Data
Plinga GmbH, Engeldamm 62-64b, 10179 Berlin, Germany is responsible (“the data controller”) for the processing of your Personal Data when you use our Services.
2. What types of Personal Data do we process and how do we collect it?
When you use our Services, as further explained, we collect, use, store and transfer different kinds of Personal Data via cookies, beacons, pixels, tags, and other non-cookie technologies which will be triggered by a Software Development Kit (“SDK**”). As a general principle, we do not collect and do not ask you to provide any “special categories of Personal Data”, which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation.
**SDK is a collection of software programs for the purpose of creating applications across web and/or mobile platforms for a particular operating system.
The information we collect depends on which of our Services you use and how you use them. We process the following types of your Personal Data:
2.1 Personal Data provided by you
When you use our Services, you provide or be asked to give us certain information, including:
● Your birth date: When you enter our Website for the first time, we ask you to provide your birth date for the purposes described below.
● Account information: For social games, you have the option to sign up for an account. If you choose to create an account, we collect your log-in data (your email address, username and password).
● Game ratings: We collect rating information if you use the voting button on our Website.
2.2 Personal Data we receive or generate from your use of our Services
When you use our Services, we also process device-related information and information about how you interact with our Services, including:
● Technical information: We collect information about your device/device settings you use for the purposes described below. The information we obtain from your devices includes the type of your device, online identifiers (your IP address), game/site ID, geolocation data (based on your IP address), browser settings, screen resolution and other technical information.
● Cookie data: We use cookies and similar technology such as pixels, SDK or local storage and allow third parties to use cookies and similar technology for the purposes described below.
● Your usage: We collect and aggregately process information about how you use our Services. This information includes your preferences, such as your interests in certain categories of games, the actions you take, the time and duration of your activity, the time that you spend while playing the games, your in-game purchases, your interaction with advertisements.
2.3 Personal Data we collect from other third parties
In certain scenarios, we will also obtain your Personal Data from third parties, in strict compliance with applicable data protection laws and regulations. Your Personal Data be provided by the following third parties:
● Payment Providers: If you make an in-game purchase, the transaction will be processed by a third-party payment provider and will be subject to privacy policies of third-party payment providers. For these transactions, we do not receive any complete financial information (such as your full credit card information) but receive information which is related to your transaction, for example the payment method, amount, status and date.
● Analytics: Google Analytics employs cookies that are stored to your computer in order to facilitate an analysis of your use of the site. The information generated by these cookies, such as time, place and frequency of your visits to our site, including your IP address. Google uses this information to analyze your use of Website and in game events, to compile reports for us on internet activity.
● Social Networks and connected third-party platforms: If you choose to connect our Services with Azerion Connect, it offers a single platform from where users can obtain the necessary login data for all participating. After registration, the SSO authentications service is available to the participating portals and to users as a single tool for logging in to the various participating specialist portals. We receive your name, surname, your email address and your authentication token.
To learn more about which data is processed, please see the section with service specific information below.
3. Do we collect data from minors?
When you use our Service for the first time, we will ask you to provide your date of birth. For accessing the Website, you must be at least 16 years old to create an account and play the games. Only if you indicate being at least 16 years of age, you will be able to proceed. Please note that some of the games offered are for adults only and require to be at least 18 years or older to play. If you believe that a user might be under the age of 16, please contact us.
4. For what purpose do we process your data?
Depending on which Services you are using and which privacy settings you have selected, we process your Personal Data for the following purposes:
Provision and improvement of our Services
● to allow you to play the games, including third-party games available on our Website
● to allow you to use our Services
● to identify and correct any bugs/errors
● to gain insights into the popularity of our Services
● to assess the quality of our Services
● to analyze the performance of our Services
● to understand and improve your online experience
● to facilitate your purchase, to verify and confirm your payment
● to recognize you when you visit our Services from different devices
Personalization of your game experience
● to remember you next time you visit our Services
● to personalize advertising for you
● to remember your preferred game settings
Marketing and analytics
● to deliver (targeted and non-targeted) advertising in our Services
● to measure the effectiveness of advertising
● to understand usage of our Services across all our group companies to support strategy and growth
Prevention of fraud and illegal activity
● to investigate fraud and illegal behaviour
● to enforce our policies and terms of use
Compliance with our legal or regulatory obligations
● to determine the legal requirements for processing of your Personal Data (based on your location such as your country)
● to respond to your requests related to your data subject rights
● to comply with our legal obligations (e.g. tax and accounting obligations)
● to inform you about any changes to this Privacy Notice
Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data.
5. Do we engage in profiling activities?
If you consent to this via the cookie consent pop-up, we use tracking mechanisms to track your activities in the games and while using our Services. We receive aggregated data from our tracking mechanism. We do not use this data for profiling purposes. This data allows us to analyze performance of our services and improve our services. You have the right to object to this type of processing. You can also go to your privacy settings to review and amend your privacy choices related to this type of processing at any time.
6. On which legal basis do we process your Personal Data?
We process your Personal Data for the purposes described in this Privacy Notice, based on the following legal grounds:
● Your consent: We process your Personal Data if you have provided your consent for a specific purpose. For example, when you use our Services for the first time, your consent is asked for the data processing in the context of personalized advertising and analytics. We also show you just-in-time contextual notifications and consent pop-ups to obtain your consent for further processing activities. You have the right to withdraw your consent at any time, for example by changing your privacy settings. Please note that this will not affect any processing carried out before you withdraw your consent.
● Performance of a contract: We process your Personal Data for the performance of a contract to which you are a party, for example, to support the operation of our games or facilitate the delivery of requested services.
● Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations. for example, for tax and accounting purposes or legal disputes.
● Legitimate interests: We also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we process your Personal Data for improvement of the service provided to you or to provide you with a better user experience and we transfer your personal data across all our group companies for administrative transfers as well as to identify/determine the size of the user base of our Services. We kindly remind you that you have the right to object to processing of personal data.
Please see for additional information the section with service specific information below.
7. With whom do we share your Personal Data?
We will not disclose your Personal Data to any party who is not authorised to process them. To manage our services, we will share your Personal Data internally with members of our responsible departments and technical support involved in the gaming process and in each case only if access to your Personal Data is necessary for the performance of their roles.
Moreover, and only when necessary to fulfil the purposes mentioned above, we disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our Services:
● External service providers: We share your Personal Data with external service providers who perform services on our behalf, like IT services, hosting and content delivery services. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.
● External advertising companies: With your consent, we share your Personal Data with third-party advertising companies or allow third-party advertising companies to collect your Personal Data when you use our Services. If you choose not to receive personalised ads at all, we will still show you ads, but they may not reflect your interests as those ads will be content specific and not user specific. Please note that by clicking on a third-party advertisement, you are redirected to the third-party advertiser’s environment over which we have no control.
● In-Game Event Analytics Platform: With your consent, we share your Personal Data with our in-game event analytics platform to receive standardized tracking for business intelligence teams who use the data for analytics & reporting.
● Payment providers: If you make in-app or website payments, the transaction will be processed by a third-party payment provider and will be subject to the third-party payment providers’ privacy policies.
● Law enforcement, government authorities or courts: We disclose your Personal Data in response to lawful requests to public authorities, including law enforcement, government authorities, or courts.
● Group companies: We share your personal data with our group companies which are responsible for internal analytics for the purposes of cross-product audience measurement. Where we share your personal data with our group company, we have appropriate agreements (an intra-company data sharing agreement) in place to ensure that your personal data is processed in compliance.
● Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).
Please see the section with service specific information below for more information about the third parties we may share your data with.
8. Where will my Personal Data be processed?
In general, if you are accessing our Services from the European Union (EU) / the European Economic Area (EEA) your data is stored on servers within the EU / EEA. However, with regard to certain activities described in this Privacy Notice, your data may also be shared outside the EU / EEA. We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission’s standard data protection clauses (also known as Model Clauses) to provide safeguards for your Personal Data.
9. How do we protect your Personal Data
We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.
10. How long do we store your Personal Data?
We will not retain your Personal Data longer than necessary to fulfil the purposes for which the data was collected or to fulfil our legal obligations or necessary for the establishment, exercise of defence of legal claims or resolving disputes. Afterwards, we will delete or anonymize your Personal Data.
11. What are your rights in respect of your Personal Data?
To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:
● Access the Personal Data we hold about you, including information such as the source and categories of data, the processing purposes, the recipients (or categories thereof), and the respective retention period.
● Request an update or correction of your Personal Data so that it is always accurate.
● Receive your Personal Data in a structured, commonly used and machine-readable format, including the right to transfer your Personal Data to another data controller.
● Request the deletion of your Personal Data if you believe that retention is no longer necessary for the purposes indicated above.
● Restrict the processing of your Personal Data, for example, if you have contested the accuracy of your Personal Data, and for a period of time that is sufficient to allow us to verify its accuracy.
● Withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the lawfulness of data processing based on consent granted prior to its withdrawal.
You can exercise these rights by sending a request to the contact details set out below, providing your name, your email address as well as a description of your request. If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example, the Autoriteit Persoonsgegevens in the Netherlands.
12. How can you contact us?
If you have any queries about this Privacy Notice or how we use your Personal Data, please contact our Data Protection Officer via e-mail to [email protected].
13. How often do we update this Privacy Notice?
We regularly review and update this Privacy Notice. When there is an important change that will have a relevant impact on the processing of your Personal Data, we will inform you by email if we have your email address. If we do not have your email address, for example because you did not create an account, we will inform you with a banner on our Website.
This Privacy Notice was last updated on: April 19, 2023
Additional Information for California Residents
This section for California residents supplements the information provided in this Privacy Notice and applies solely to players, and others who reside in the State of California. We provide this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and the regulations issued under it; accordingly, this section addresses the specific requirements of the CCPA and should be read together with this Privacy Notice.
We do not sell your Personal Data. However, we may share or provide access to each of the categories of Personal Data we collect as necessary for our business purposes. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, we have collected the following categories of personal information (envisaged by the CCPA) from consumers within the last twelve (12) months:
Category A – Identifiers (such as your device identifier, demographic information -such as your country, your username, email address, any information you may choose to provide -such as your age or your language-)
Category B- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D – Commercial information (such as purchase history)
Category F – Internet or other similar network activity (such as your interaction with our ads, your IP address)
Category G – Geolocation data
Category H – Audio, electronic, visual, thermal, olfactory, or similar information.
The CCPA provides consumers (California residents) with specific rights regarding their personal information.
You have the right to access specific information i.e. you may request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.
You have the right to know. Under the CCPA you have the right to request that we disclose to you what Personal Data we process about you.
You have the right to deletion which means that you may request that we delete any of your personal information we collected from you and retained, subject to certain exceptions.
Under the CCPA, you have the right to opt out of any sale of your personal data. Please note that your right to opt out does not apply to our sharing of personal data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal data only for that function.
Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.
You can exercise these rights by sending a request to the contact details set out above, providing your name, your email address as well as a description of your request.
Additional Information for Brazil Residents
Under the Brazilian General Data Protection Law (the “LGPD”), you have the right to access, rectify, port, erase, and confirm that we process your data. If you have given consent about processing your data, you have the right to withdraw consent anytime.
In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed. For general information about data processes that apply, please see above.
Hosting and content delivery
Plinga is hosted by external companies providing web servers and web content delivery. Every time you make a request, for example by clicking on a link on our platform, the information allowing this request (e.g. device information and information on requested content) as well as online identifiers (your IP address) will be sent to the external servers. This data is used to show you the content you requested in a faster way. We process this data on the basis of our legitimate interest, to provide and improve our service and ensure its functionality.
Analytics
We use analytics services to understand which features you like in our Services and how popular our games are on social media and to monitor traffic of our Website, for example following changes to the website. For this purpose, we process information about your device, request data (including the URL of the current webpage and the website visited before). By activating IP anonymisation on this Website, the IP address is shortened prior to transmission within the EEA or in other states party to the Agreement on the EEA. We process this information based on your consent, provided in the consent pop-up which will be shown to you when you access Plinga for the first time.
We also collect information from the games via SDK which is embedded into them in order to see insights on how the games are played. This helps us provide players with more popular games. We also process your IP address and user id to determine the number of unique users of our Services within our group companies. We process your personal data in connection with this activity based on legitimate interest.
If you make in-app purchases, you will be redirected to an external payment provider for the transaction of your payment.
The transactions will be processed by the third-party payment provider. While we do not collect and do not receive any financial data (such as your bank account data), we collect or receive from third-party payment providers the following information related to your transaction: the purchased amount, the purchased item, the price and currency, your IP address, country, device information (user agent), time stamp payment/transaction id, and the status of your payment.
Advertising
In our Games, we show advertising from different advertising companies. These adverts can be targeted or non-targeted content related ads. In order to show you personalized ads and only if you have provided your consent, we will share your Personal Data (your IP address, advertising identifiers and the information that you have provided your consent for personalized ads) through our advertising platform provider with third-party advertisers and ad networks.
We also use this information to measure how effective these ads are. In our consent pop-up which will be shown to you the first time you enter our Website, you can choose from which advertising company you would like to receive personalised ads or choose not to accept receiving personalised ads at all. You can adjust your preferences at any time in your privacy settings. If you choose not to receive personalised ads at all, we will still show you ads, but they may not reflect your interests as those ads will be content specific and not user specific.
Games offered on our Website also reward players on a regular basis and offer them awards in the form of either in-game currency or in-game items. In order to claim such rewards, players are required to watch an advert that could be either targeted or contextual based on the above.
Azerion Connect
Azerion Connect provides a single sign on (SSO) service by generating a unique user ID for each user. The user ID is recognised and verified by all third-party platforms, portals and services that are part of the Azerion Connect ecosystem. Azerion Connect collects full name, date of birth, email address, password and authentication token.
Azerion Connect doesn’t share any personal data with any third party platforms. The legal basis of processing the Personal Data is in Azerion Connect’s legitimate interest.
Age Verification
When you use our Service for the first time, we will ask you to provide your date of birth. For accessing the Website, you must be at least 16 years old to create an account and play the games. Only if you indicate being at least 16 years of age, you will be able to proceed. Please note that some of the games offered are for adults only and require to be at least 18 years or older to play. If you believe that a user might be under the age of 16, please contact us. Your date of birth is stored based on our legitimate interests.
Like and Dislike Buttons
You can rate the games on our Website, by choosing a thumbs up or thumbs down icon. It is in our legitimate interest to provide our users an overview which games are most popular and best rated. When you click on a rating button, we will store the aggregated voting data. We will then use the result of all the submitted ratings to determine an average rating for the game.
Fanpage Administration on Social Media Platforms
We have social media pages on Facebook, Twitter and Youtube to publish posts, updates and events to increase the engagement with our users. We do not collect, receive or process any personal data for this process as any interaction such as likes and shares are collected by Facebook or Instagram. Based on the type of the post on social media, you may be able to comment on the post. Please be aware that such comments may be read, copied, collected or used by other users. Never share information or personal data that is harmful for yourself or others.
Search Functionality
In order for the users to search games based on keywords or phrases they prefer, we offer a search functionality on our Website. For this purpose, we process IP address and phrases that are searched based on performance of a contract.
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