Privacy Policy

Version 1.0

PRIVACY POLICY FOR PLAYGATE.ONLINE
Version 1.0 - Effective Date: 27 June 2026
Playfable Limited - New Zealand Limited Liability Company

NOTE: This is a summary Privacy Policy. A comprehensive Privacy Policy will be published at this location prior to PlayGate's commercial launch. The commitments below are binding.

1. WHO WE ARE

Playfable Limited is a New Zealand limited liability company operating PlayGate.Online.

General enquiries: contact@playfable.com
EU / GDPR enquiries: eu.gdpr@playfable.com

2. WHAT INFORMATION WE COLLECT

We collect only what is necessary to operate your account and provide Portal features:

• Account information: username, display name, and password (passwords are hashed - never stored in plain text)
• Gameplay data: game progress, Taluns balance, quest completions, achievements, virtual items
• Profile data (optional): legal name, address, phone number, date of birth, language preference
• Session data: basic information needed to maintain your login and protect account security

For children under 13: we collect only the minimum necessary for account creation, and only after verifiable parental or guardian consent has been obtained.

3. WHY WE COLLECT IT

We use your information to:
• Operate your account and provide gameplay features
• Process virtual rewards and track game progress
• Protect the security and integrity of the Portal
• Comply with our legal obligations (including children's privacy laws)

We do NOT use your data for behavioural advertising. We do NOT sell your personal information to third parties. We do NOT employ psychological manipulation or targeted advertising techniques toward minors.

4. WHO WE SHARE YOUR DATA WITH

We share your data only with the following trusted processors, each bound by a data processing agreement:

• Microsoft PlayFab: account management, authentication, and virtual economy
• Microsoft Azure: server infrastructure and cloud functions
• Shopify: purchase processing (only where purchases are made)

We do not share your personal information with any other third parties without your consent, except where required by law.

5. HOW LONG WE KEEP YOUR DATA

We retain your account data while your account is active. If you close your account or request deletion, we will delete your personal data within a reasonable period, except where we are legally required to retain it (for example, financial transaction records).

6. YOUR RIGHTS

New Zealand users - under the Privacy Act 2020, you have the right to:
• Access the personal information we hold about you
• Request correction of inaccurate information

EU / EEA users - under the GDPR, you additionally have the right to:
• Erasure of your personal data ("right to be forgotten")
• Restriction of processing
• Data portability
• Object to processing based on legitimate interests

To exercise any of these rights, contact eu.gdpr@playfable.com (EU users) or contact@playfable.com (all other users). We will respond within the timeframes required by applicable law.

7. CHILDREN'S PRIVACY

For children under 13, personal data is processed only on the basis of verifiable parental or guardian consent. Parents may request access to, correction of, or deletion of their child's personal data at any time. Withdrawal of consent will result in restriction of the child's account and deletion of their data.

We do not serve targeted advertising to children. We do not employ behavioural tracking or psychological manipulation toward minors. General, non-targeted promotional banners for Playfable's own products may appear on the Portal with prior parental consent.

8. SECURITY

We implement reasonable technical and organisational measures to protect personal information against unauthorised access, loss, or disclosure. In the event of a notifiable privacy breach, we will:
• Notify the New Zealand Privacy Commissioner as required by the Privacy Act 2020
• Notify affected individuals as required by law
• Take reasonable steps to contain and remediate the breach

9. COOKIES AND TRACKING

PlayGate.Online uses minimal, essential cookies required to maintain your login session. We do not use tracking cookies, advertising cookies, or third-party analytics cookies without your explicit consent. A full Cookie Policy will be published prior to commercial launch.

10. CHANGES TO THIS POLICY

If we update this Privacy Policy materially, you will be prompted to review and accept the new version upon your next login. The version number and effective date at the top will be updated accordingly.

11. CONTACT US

General enquiries: contact@playfable.com
EU / GDPR rights: eu.gdpr@playfable.com
Ban appeals: appeal@playfable.com
Disputes: dispute@playfable.com

Playfable Limited - New Zealand - Version 1.0 - 27 June 2026

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