Version: 1.3
Last modified: April 30th, 2025
REALPLAY TECH INC and its Related Entities including Realplay Ltd (“RealPlay”, “we”, “our” or “us”) provide the websites located at https://www.realplayltd.com/; https://realprize.com/ (“Websites”) and all of their subdomains, subpages and successor sites thereof and the “RealPrize” mobile application (“App”) through which the RealPrize Services are provided (together – the “Services”).
RealPlay also includes Realplay EU Ltd., which is located at Madison Building Midtown, Queensway, Gibraltar – GX11 1AA.
RealPlay is dedicated to protecting your privacy rights and making our practices regarding your personal data more transparent and fairer. Please read this policy, as it includes important information in respect of your personal data.
This Privacy Policy (“Policy”) is designed to help you understand how we collect, store, use and share your personal data. This Policy applies whenever you visit our Websites, install or interact with our App, or otherwise access or use any of our Services.
We strongly urge you to read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue and avoid using our Services. You have the right to cease using our Services at any time.
This Policy is integrated into and forms part of the RealPrize Agreement.
For any questions or concerns, please contact us via our email address: [email protected].
This Policy describes the following –
We collect personal data about you, which refers to any information that could potentially allow to identify you through reasonable means (such as email address or name). This section outlines how and when we collect and process personal data about you.
1.1. Account information:
If you decide to register an account with our Services, we may collect your full name, email address, country, phone number, user nickname, and optionally, your profile picture. If you choose to log in or access our Services through a social networking service (e.g., Facebook, Twitter, Instagram), we collect your user ID, username associated with the social networking service, and any information you make public using that service or that the service permits us to access.
1.2. Payment information:
Our third-party payment processors will collect the billing and payment information required to process your charges. This may include your postal address, email address, or payment information. Our payment processors may collect, process, store, and share information with us related to your purchases and withdrawals.
1.3. Usage information:
When you use our Services, we collect information about your interaction with our Services. Such information includes gameplay recordings, purchase history and data pertaining to your activities on our Services, as well as information generated when you interact with our App (for instance, how and when you use our App) and with the advertising served in our App (for instance, number of ads served, potential clicks).
1.4. Identifiers and technical information:
When you use our Services, we collect technical information such as IP address, your Mobile Advertising ID (such as Apple IDFA or Google AAID – which are technical identifiers created by mobile operating systems for advertising purposes, which you can control, reset, or erase through your device settings), device identifiers (e.g., IDFV for iOS devices and Android ID for Android devices), information about your device and connection, including user agent, connection type, timestamp, system language, device model, screen resolution and settings, battery level, available storage space, time zone, and operating system.
1.5. Communication information:
When you contact us via email or through the support channels in our App or Websites, we collect the personal data you provide, which include your name, email address, and any other information you choose to provide.
We do not knowingly collect, process or disclose any sensitive personal data.
When you visit or access our Services, we use cookies, pixels, beacons, local storage and similar technologies (“Tracking Technologies”). These Tracking Technologies allow us to automatically collect information about you, your device, and your online behavior, in order to enhance your navigation in our Services, improve our Services’ performance, perform analytics, customize your experience and offer you, for example, tailored content and advertisements that better correspond with your interests.
2.1. What types of Tracking Technologies do we use?
When you use or access our Services, we use the following categories of Tracking Technologies:
(a) Strictly necessary Tracking Technologies: these Tracking Technologies are automatically placed on your computer or device when you access or take certain actions on our Services. These Tracking Technologies are essential to enable you to navigate around and use the features of our Services.
(b) Tracking and advertising Tracking Technologies: these Tracking Technologies collect information about your browsing habits in order to make advertising more relevant to you and to your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The Tracking Technologies remember the websites you visit, and that information is shared with other parties such as advertisers and publishers. Publishers, advertisers, and third-party ad networks also utilize Tracking Technologies or similar technologies to deliver ads and monitor the performance of such ads. The collection of information through Tracking Technologies by such third parties will be governed by their own privacy policies/cookies policies and principles, which the Company does not control;
(c) Functionality Tracking Technologies: these Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services; and
(d) Performance Tracking Technologies: these Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services), including behavioral data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).
2.2. How and by who are Tracking Technologies stored on your device?
We store Tracking Technologies on your device when you visit or access our Services – these are called “First Party Tracking Technologies”. In addition, Tracking Technologies are stored by other third parties (for example, our analytics service providers, business partners and advertisers), who run content on our Services – these are called Third-party Tracking Technologies. Both types of Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits.
There are various ways in which you can manage and control your Tracking Technologies settings. You can change your preferences using our cookie settings tool (however, please note that this tool may only be available in certain jurisdictions). Other methods of managing your Tracking Technology preferences include changing your browser settings to send a “Do-Not-Track” signal. In such case, your browser will send us a special signal to stop tracking your activity. However, please note that certain features of the Services may not work properly or effectively if you delete or disable cookies.
Below is a list of useful links that can provide you with more information on how to manage your cookies:
(a) Google Chrome;
(b) Mozilla Firefox;
(c) Safari (Desktop);
(d) Safari (Mobile);
(e) Android Browser; and
(f) Microsoft Edge
You can learn more and turn off certain third-party targeting and advertising cookies by visiting the following third-party webpages:
(a) The Interactive Advertising Bureau (EU); and
(b) European Interactive Digital Advertising Alliance (EU)
If you are accessing our services through a mobile device app, you can withdraw your consent to personalized advertising experience on your device at any time by using your device settings as follows:
(a) On iOS, depending on the applicable iOS version, you may withdraw consent across all App by either enabling the “Limit Ad Tracking” setting or disabling the “Allow App to Request to Track” permission in your iOS device settings. Depending on the applicable iOS version, instead of withdrawing consent on a device-wide basis, you may also have the option of withdrawing consent on a per-app basis by disabling tracking permissions for specific App that appear under the “Allow App to Request to Track” setting in your iOS device settings (precise directions may differ depending on the applicable iOS version).
(b) On Android devices, you may withdraw your consent in the Google Ads settings within your Android settings by enabling the “Opt-out of Ads Personalization” setting (precise directions and the name of the setting may differ depending on the applicable Android versions and device manufacturer).
Any personal data we collect is being used in a way that is consistent with this Policy, and is used as follows:
| Purpose | Legal basis |
|---|---|
| Provision of our Services; customer support. We use your personal data, such as your name and email address, to provide you with our services and provide customer support. This includes, for example, allowing you to log-in or responding to your inquiries. | The legal bases for processing this data are the performance of our contractual obligations towards you; your consent (where legally required); and our legitimate interests. Our legitimate interests in this case are the provision of our Services and supporting our customers. |
| Payments. We collect certain information about your payment instruments from our third-party payment processors, for the purposes of connecting your payment method to your account on the Services, billing and sending invoices. | The legal basis for processing this data is the performance of our contractual obligations; and our legitimate interests. Our legitimate interests in this case are provision of our Services. |
| Improve our Services. We collect and analyze information about you and your usage of our Services for the purposes of usability, quality, functionality and effectiveness of our Services, including debugging to identify and repair errors and undertaking internal research for technological development and demonstration. | The legal basis for processing this data is our legitimate interest. Our legitimate interests in this case are providing and improving our Services. |
| Marketing and advertising. We use personal data (including Tracking Technologies) in order to provide you with advertisements (either on our Services or on other third-party assets), including personalized and non-personalized advertising. | The legal bases for processing this data are your consent (where legally required) and our legitimate interests. Our legitimate interests in this case are providing you with tailored services, content and advertisements that better correspond with your interests. |
| Integrity. We process certain information about you and your usage of our Services to keep the integrity and security of our Services, prevent fraud, verify your identity and enforce our policies. | The legal bases for processing this data are compliance with our legal obligations and our legitimate interests. Our legitimate interests in this case are keeping the integrity of our Services; detection of fraudulent activities; and the safety of our end-users. |
| Compliance with applicable laws; assistance to law enforcement agencies; exercising and defending legal claim. We may process your personal data in order to comply with our legal obligation under applicable laws and to exercise legal claims | The legal basis for processing this data is compliance with our legal obligations and our legitimate interests. Our legitimate interests in this case are compliance with our legal obligations, assisting law enforcement agencies and defending and exercising our legal claims. |
We may share your personal data with:
4.1. Payment processors:
Third-party payment processors, for the purpose of facilitating your payments when using our Services. These third parties have access to your personal data, so they perform these tasks on our behalf.
4.2. Service providers:
Service providers working on our behalf and who need access to certain personal data in order to provide their services to us. These companies include, but are not limited to, cloud storage providers, analytics services, fraud prevention etc.
4.3. Advertising partners:
Advertising partners to either display advertising on our Services or to manage our advertising on other websites or App. Our third-party advertisers use Tracking Technologies to gather information about your activities on our Services and other websites and App in order to provide you with advertising based upon your browsing activities and interests.
4.4. Third-party integrations:
Our Services allow you to integrate with certain third-party services, in order to connect your account to our Services or to place purchases (e.g., Apple, Google or Facebook accounts).
4.5. Law enforcement agencies:
We may disclose some data about you to government or law enforcement officials or private parties. The disclosure will be made in our sole discretion, as we believe it necessary or appropriate to respond to claims and legal procedures (including but not limited to subpoenas), to protect our or a third-party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s personal data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
4.6. Auditors and advisers:
We share your data with our external auditors, advisors and professional service providers (e.g., lawyers, accountants, insurers etc.) to ensure our compliance with regulatory requirements and industry standards, auditing, managing disputes etc.
4.7. Mergers and acquisitions:
We may transfer or otherwise share your data in case of entering into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets.
In the 12 preceding months, we have collected, disclosed or shared the following categories of personal data:
| Category of personal data | Personal data processes | Categories of third parties to whom personal data was disclosed | Categories of third parties to whom personal data was shared |
|---|---|---|---|
| Identifiers | Internet protocol address, email address, account name, telephone number, credit card number and any other unique personal identifier including online identifier. | – Payment processors; – Service providers; – Thiry party integrations. |
N/A. |
| Commercial data | Records of products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies. | Service providers. | N/A. |
| Internet or other electronic network activity data | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | – Service providers. | N/A. |
The above-mentioned personal data was collected and obtained from the following categories of sources:
We use your personal data ourselves or by using our third-party subcontractors for the purpose of providing you with promotional materials, ads, products, services, websites and applications which relate to our affiliated companies or our business partners (collectively: “Marketing Affiliates”), which we believe may interest you.
You can decline receiving further marketing offers from us or from our business partners and Marketing Affiliates at any time, by contacting us at [email protected].
Please note that even if you unsubscribe from our marketing-mailing list, we can continue to send you service-related updates and notifications.
7.1. Depending on the jurisdiction in which you reside, you may have certain rights under relevant applicable laws regarding the collection and processing of your personal data. To the extent these rights apply and concern you, you can contact us via the contact details available below and ask to exercise the following rights.
7.1.1. Rights of access to your personal data:
You have the right to receive confirmation as to whether or not personal data concerning you is being processed, and access your stored personal data, together with supplementary information.
7.1.2. Right of data portability:
You have the right to request us to move, copy and transfer your personal data easily from one IT environment to another, in a safe and secure way, without affecting its usability.
7.1.3. Right of rectification:
You have the right to request rectification of your personal data in our control in the event that you believe the personal data held by us is inaccurate, incomplete or outdated.
7.1.4. Right of deletion/erasure:
You have the right to request that we erase or delete personal data held about you at any time.
7.1.5. Right to restriction or objection to processing:
You have the right to request that we restrict or cease to conduct certain personal data processes at any time.
7.1.6. Right to withdraw your consent:
To the extent we process personal data on the basis of your consent, you have the right to withdraw your given consent at any time.
7.1.7. Right not to be subject to automated decision making:
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly effects on you
7.1.8. Right to opt-out of the sale or share of personal data:
In the event that we sell or share your personal data for behavioral advertising purposes, you have the right to submit a request to opt-out of the sale or share of your personal data. After you opt-out, we may continue disclosing some personal data to our partners to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services are working correctly and securely, providing aggregate statistics and analytics and preventing fraud.
7.1.9. Right to non-discrimination:
You have the right to be free from any discrimination for exercising your rights, such as offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request.
7.1.10. Right to lodge a complaint:
All requests, complaints or queries may be addressed to the Company to the following email address: [email protected]. We will consider any requests, complaints or queries and provide you with a reply in a timely manner. We take our obligations seriously and we ask that any concerns be brought to our attention first, so that we can try to resolve them. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.
Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. You are welcome to contact us for any questions or requests through our contact details below.
7.2. Verification and authorized agent
7.2.1. You can use an authorized agent to make a request to exercise your right under applicable laws on your behalf if:
i) The authorized agent is a natural person or a business entity; and
ii) You sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request to exercise your right, please provide us with a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.
7.2.2. The request must:
i) Provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal data or an authorized agent. We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you; and
ii) Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
7.2.3. We will only use personal data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
7.2.4. Making a verifiable consumer request does not require you to create an account with us.
Certain aspects of our operations, such as our payment processing, are handled globally. Thus, any information that we collect, disclose or share, including your personal data, can be stored and processed in various jurisdictions around the world, including (but not limited to) Gibraltar, the European Economic Area, United Kingdom, Israel and United States, for the purposes detailed in this Policy.
To the extent that the Gibraltar GDPR is applicable, we will only transfer or share your personal data to data recipients: located in Gibraltar, the EEA or in the UK; located in other countries which have been approved as providing adequate level of data protection; or who have entered into legal arrangements ensuring an adequate level of data protection.
We are strongly committed to the protection of your personal data and information, and we will take reasonable technical steps, which are accepted in our industry, to keep your Information secured and protect it from loss, misuse or alteration. However, if you notice a risk or any security violations, we advise you to report to us on [email protected], so we can resolve it as soon as possible.
We do not knowingly collect or solicit personal data from anyone under the age of 18. By accessing, using or interacting with our Services, you certify to us that you are not under the age of 18. In the event we learn that we have inadvertently gathered personal information from minors under the age of 18, we will take reasonable measures to promptly delete such information from its records in a secure manner. If you believe that we may have any information from or about minors under the age of 18, please let us know at [email protected].
We will retain your personal data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined while taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.
From time to time, the Company reserves the right to modify the Policy through:
(i) posting a modified version on the Services. Such modified version will take effect immediately upon being posted and you agree to be bound by such modifications;
(ii) asking that you accept the modified Policy. Such modified version will take effect immediately upon your acceptance;
(iii) posting a notice about the modifications on the Services. Such modifications will take effect immediately upon the notice being posted and you agree to be bound by such modifications; or
(iv) sending you a notification via the e-mail address associated with your User Account at the time of such modification Such modification will take effect upon your continued use of the RealPrize Services.
If you do not agree to the modified Policy your sole remedy will be to terminate your User Account in accordance with Clause 13.1 (TERMINATION OF YOUR USER ACCOUNT) in the General Terms and Conditions and immediately cease accessing and using the Services and the Services Content and if you have downloaded the RealPrize application, you must delete the RealPrize application from your device.
We reserve the right to change this Policy at any time. The most current version will always be posted through our Services (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.
This Policy has been drafted in English, serving as the original and controlling version of this Policy. Any translations of this Policy into other languages are provided for convenience only and shall not dictate the meaning or application of this Policy. In the event of any discrepancy between the meanings of any translated versions of the Policy and the English language version, the interpretation of the English language version shall prevail.
If you have any questions about this Policy, please contact us at: [email protected]
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Delaware
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