Privacy Policy

Please read the terms of this Privacy Policy (this “Policy” or these “Terms”) carefully. The Policy describes to users (“User,” or “Users,” or “you”) how PLAYTIME (“PLAYTIME”, “we,” “us” or “our”) collects, uses, discloses or otherwise processes personal information (the terms “personal data” and “personal information” will be used to mean any information that is able to directly or indirectly identify you, which might differ slightly depending on the laws that apply where you are located) and other data we receive from Users using PLAYTIME’s website, mobile app, products and services (the “Services”). Examples of personal data include your name, email address, gender, age, and other information about you.

This Policy is effective when the User clicks on the “AGREE” button during the PLAYTIME account creation process and by doing so, you agree that you have read and understood the terms of this Policy.

Be sure to return to this page periodically to review the most current version of the Privacy Policy. We reserve the right to change or otherwise modify the Privacy Policy. If we modify it, we will update the "Last Updated" date and will alert users that a change has occurred within the mobile app. If the modified Privacy Policy is not acceptable to you, please do not use the Services.

‍

PERSONAL INFORMATION COLLECTION, DISCLOSURE, AND USE

We do not use cookies (or similar technologies) to collect information about you. We collect information you provide directly or indirectly to us, such as when you create or modify your account, request on-demand services, redeem your rewards in our online shop, contact customer support, or otherwise communicate with us. This information may include: email, age, gender. During the registration process, we will also collect information such as your IP address and Google Advertising ID (together, the “ID”).

I hereby agree that PLAYTIME may use the following personal data:

PLAYTIME collects data about Installed Apps in order to be able to suggest apps available in PLAYTIME that match your interests, that you have not yet in the past & track apps that you newly installed through our platform.
This is needed for the functionality of our app and to protect ourselves from fraudulent attempts, including detecting apps that automate activity on our platform to reach a certain bonus.

The Installed Applications are transmitted to our servers in encrypted form and are linked to your device. The said data will not be shared with anyone and be deleted upon request. For that please send a mail to apps@thespotlight.pro. The data will be automatically deleted if the user becomes inactive for 6 months.

The data will be treated as particularly sensitive data as described in the European General Data Protection Regulation (GDPR).

If you have any inquiries about your data or deletion of your data, please contact us at apps@thespotlight.pro.

We will only collect your personal data as described in this Privacy Policy and will not use or otherwise process your information for any other purposes than described.

If you sign into our Service using a third-party profile, we will import the first name and last name displayed in such profiles, such as information on Facebook or Google, on our platform.

When you use our Services, we will also collect information about how you interact with the games advertised on our platform. The type of information we collect relates to: i) achievements that are unlocked, ii) in-game purchases, iii) other apps on your device, iv) the time you spend playing games, v) the units you’ve earned in PLAYTIME, and vi) the game experience earned (collectively “User Gaming Profile”).

By using our mobile application and accepting our Privacy Policy, you understand that requesting a reward within the Shop on the The Spotlight mobile application will only be possible upon additional user authentication via face verification. Your consent applies to the processing of such biometric data as described below, and is an express acknowledgement that such data is “special category” personal data pursuant to Article 9 of the General Data Protection Regulation (GDPR).

‍AUTOMATICALLY COLLECTED INFORMATION

Upon accessing and when using the Services, certain information will be required to provide the services and automatically collected, such as:

aggregated usage information;
the session ID;
installed apps
the time and date you access the mobile app; and
device information

We use your data for the following purposes:

Account creation;
To provide, maintain, perform and improve the Services;
Analyze which apps you have not tried yet
Enabling you to redeem rewards earned on our platform;
To perform internal operations, including, conducting data analysis, testing and research and to troubleshooting software bugs and operational problems;
To monitor and analyze usage and activity trends;
Personalization of ads to provide you with better recommendations of advertised games in your country and to help you earn rewards; and
To communicate with you about our products, services, promotions and news (we will only send you these materials if we have your consent and you can unsubscribe any time);

Additionally, personal data may be used and disclosed to the extent PLAYTIME may deem reasonably necessary to enforce the terms of any agreement between you and The Spotlight, or to protect the rights, property or safety of any person or entity, or if required by law, specifically in response to a demand from government authorities.

We will also use your information to create de-identified statistical and analytical data.

‍

DELETION OF COLLECTED INFORMATION

We delete your personal information stored in physical form by shredding and personal information stored in electronic files by deleting the files in an irrecoverable manner. Moreover, pursuant to our Terms of Use, if a user does not use the Service for at least one year, the user’s inactive account may be terminated, and the user’s personal data may be destroyed.

‍

DATA RETENTION

We will only retain personal data for as long as you use the Services or for as long as it is required to meet the purposes for which it was collected, or as otherwise required by law. When we delete your account, all personal data will be deleted except as required by law. We may also retain personal data for an additional twelve (12) months after deletion for administrative or accounting purposes. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

RIGHT OF ACCESS

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By applicable law you have rights related to access and correction of the personal information that we hold about you.

You may make requests by writing to privacy@thespotlight.pro (see below for a description of the specific rights with respect to accessing and deleting Information that are provided to California, European, Taiwan and Korean residents). Upon receipt of such request, The Spotlight will endeavor to provide you this information (in electronic readable format) within a reasonable time. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

Information protected by solicitor-client privilege.
Information that is part of a formal dispute resolution process.
Information that is about another individual that would reveal their personal information or confidential commercial information.
Information that is prohibitively expensive to provide.

If you are concerned about our response or would like to correct the information provided, please refer to Contact Information and Challenging Compliance below on how to contact us.

‍

WITHDRAWAL OF CONSENT TO COLLECT PERSONAL INFORMATION

You may withdraw your consent to the collection of personal information at any time by sending a written request to privacy@thespotlight.pro. Upon receiving notice that you have revoked your consent, we will stop processing your personal information within a reasonable time, which will vary depending on what information we have collected and for what purpose. Please note that by choosing to withdraw such consent, you may not be able to continue to use the Services or any of the benefits you have earned. You may also ask us to delete your account. By deleting your account, however, any loyalty points that you have earned and not redeemed will be deleted. Please note that we will send you an email requesting your confirmation before we delete your account (please refer to the Data Retention section above).

‍

PROMOTIONAL COMMUNICATIONS

We will only send you promotional communications if we have your consent to do so. You may opt out of receiving promotional messages from us by following the instructions (unsubscribe mechanism) in those messages. If you opt out, we may still send you non-promotional communications, such as those about your account, about Services you have requested, or our ongoing business relations.