GOLDEN PLAY LIMITED Privacy Policy

Last Updated: 2026.1.10

Table of Contents

  1. Introduction

    GOLDEN PLAY LIMITED (“we,” “us,” or “our”) is committed to safeguarding the privacy of our users (“you” or “user”). This Privacy Policy governs our collection, use, disclosure, and protection of your personal information (data that can identify you individually) in relation to our games, applications (“apps”), websites, and associated services (collectively, the “Services”). The data is under the control of GOLDEN PLAY LIMITED, with a registered address at 3/F, WORKINGTONTOWER, 78 BONHAM STRAND, SHEUNG WAN HK.

  2. Policy Amendments

    We reserve the right to modify this Privacy Policy at any time and for any reason. For minor changes (e.g., typo fixes, non-material clarifications), we will update the “Last Updated” date at the top of this policy. For material changes (e.g., changes to data collection purposes, sharing practices, or user rights), we will notify you via in-app notification or email at least 30 days prior to the change taking effect. It is recommended that you review this policy periodically to stay informed. Your continued use of the Services following the posting of a revised policy will signify your awareness, acceptance, and compliance with the updated terms.

  3. Information Usage

    1. Service Promotion: We may use your contact information to send you marketing communications, surveys, and to understand your usage patterns to improve our Services. You can unsubscribe from these communications at any time by clicking the “unsubscribe” link in the email or adjusting your notification settings in the app.

    2. Service Provision: We utilize your personal information to deliver the Services you request, including processing transactions, enabling features, synchronizing data across your devices, and providing customer support.

    3. Service Protection: Your information helps us maintain the security and integrity of our Services, including identity verification, fraud prevention, spam and malware detection, and ensuring compliance with legal and regulatory requirements.

    4. Legal Compliance: We may use and disclose your information as required by law, including in response to subpoenas, court orders, or regulatory inquiries.

    5. Push Notifications: We may send push notifications to keep you informed about Service updates, new features, or important announcements. You can manage these notifications in your device settings (e.g., enable/disable, adjust frequency) at any time.

    6. Personalized Advertising: We collaborate with third-party advertising networks to present personalized advertisements. If you are located in the European Economic Area (EEA), Norway, or Switzerland, certain networks may require your consent to process your personal data (including device advertising identifier and IP address) for the purpose of delivering relevant ads. This data is retained for up to 6 months and is not shared with third parties for non-advertising purposes. You will be asked to consent to the collection of your device’s advertising identifier and IP address. To opt out of personalized advertising, see the relevant section below.

  4. Information We Collect

    • Personal Information: When you create an account, we may collect your name, email address, username, password, and other registration details. Additionally, we may collect in-game profile information such as your avatar, player level, and game achievements (this profile information is only linked to your personal identity if you choose to associate it with your account).

    • Device Information: We automatically collect information about the device you use to access the Game, including device type, operating system version, unique device identifiers (such as Android ID or IDFA for iOS), browser type, IP address, and network provider. This information is used to optimize the Service for your device and prevent fraud.

    • Gameplay Information: We collect data related to your gameplay, such as game session duration, in-game actions, progress, and scores. This data is primarily used in anonymized form (data that no longer identifies you individually) to improve the Game and provide a better user experience.

    • Payment Information: If you make in-game purchases, we collect payment details such as credit card information or other payment method data. However, we only use this information for processing payments and do not store it longer than necessary for that purpose (typically 90 days after transaction reconciliation). All payment data is encrypted during transmission and storage.

  5. How We Use Your Information

    • To Provide and Improve the Game: We use your information to operate the Game, personalize your gaming experience, and make improvements and optimizations. For example, we may use your gameplay data (in anonymized form) to balance game difficulty or offer customized in-game content that matches your play style.

    • For Communication: We may use your contact information to send you important notifications about the Game, such as updates, maintenance schedules, or customer support messages. These communications are necessary for the provision of the Service and cannot be unsubscribed from (you may adjust marketing communication preferences separately).

    • Analytics and Research: We analyze aggregated and anonymized data to understand user behavior, preferences, and trends. This helps us develop new features and enhance the overall quality of the Game. Aggregated data (e.g., “80% of users complete Level 5 in 10 minutes”) does not identify any individual user.

  6. Information Retention

    We retain your personal information only for as long as necessary to fulfill the purposes outlined in this policy or as required by law. Specific retention periods are as follows:

    • Account information (name, email): Retained for 14 months after your last active use (including login, gameplay, or in-app purchase) of the Services; deleted if no activity is recorded within this period.
    • Payment information: Retained only until the transaction is completed and reconciled (typically 90 days), and then anonymized (no longer linked to your account).
    • Gameplay information (non-personalized): Retained for up to 2 years for analytics and service improvement (anonymized after 14 months).
    • Legal compliance data: Retained for the period required by applicable laws (e.g., tax, regulatory reporting).
    After the retention period expires, personal information will be permanently deleted or anonymized. Once deleted, you will no longer have access to the data or the ability to exercise rights such as access, erasure, rectification, or data portability.

  7. Your Rights and Choices

    1. Data Correction and Deletion: You have the right to request the correction of inaccurate or incomplete personal information, or the deletion of your personal information if it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent (where applicable).

    2. Object and Restrict: You can object to or restrict our use or sharing of your data under certain circumstances (e.g., if you believe the data is being used unlawfully, or if you contest the accuracy of the data).

    3. Consent Withdrawal: If you have previously consented to the processing of your data (e.g., for personalized advertising), you may withdraw that consent at any time, such as by disabling camera access in your device settings or opting out of ad tracking. This will not affect data processed prior to the withdrawal.

    4. Opt-Out of Targeted Advertising: To opt out of personalized advertising, you can follow these steps:

      • For iOS Devices: Open Settings, select Privacy & Security, then Advertising and enable “Limit Ad Tracking” (iOS 13 and earlier) or select Tracking and turn off “Allow Apps to Request to Track” (iOS 14+).

      • For Android Devices: Open Settings, select Google > Ads, then enable “Opt out of Ads Personalization” and reset your advertising ID.

      After opting out, you will receive contextual advertisements (based on the content of the app/website) instead of personalized ones (based on your behavior). Note that you may still see non-personalized ads and may receive personalized ads from third-party networks on other apps or websites where you have given consent. For more information, refer to Appendix A below.

      To exercise any of these rights, please contact us atadmin@goldenmindplay.com with the subject line “Privacy Rights Request - [Your Account ID/Email]”. We will verify your identity (to ensure we are disclosing data to the correct person) and process your request free of charge within 45 days (or 90 days if necessary, with written notice to you). If you have unresolved concerns, you may also contact your local data protection authority in the European Economic Area.

      You can also use the Digital Advertising Alliance’s (DAA) tool to opt out of the sale of personal information by some or all of its participating companies. Visithttps://optout.aboutads.info/ (web) or download the DAA’s AppChoices mobile application (iOS/Android).

  8. Information Sharing

    • Service Providers: We may share your information with third-party service providers who assist us in operating the Game, such as hosting services, payment processors, analytics companies (e.g., Google Analytics), and customer support platforms. These providers are bound by strict confidentiality agreements and data processing terms, and are only permitted to use your information for the purposes we specify (they cannot use your data for their own marketing purposes).

    • Legal Requirements: We may disclose your information if required by law, in response to a valid legal request (e.g., subpoena, court order), or to protect our legitimate rights, privacy, safety, or property, or that of our users or the public (e.g., to investigate fraud or prevent harm).

    • Business Transfers: In the event of a merger, acquisition, bankruptcy, or sale of all/part of our assets, your personal information may be transferred to the acquiring entity. We will notify you via email and/or prominent notice on our Services before your data is transferred and becomes subject to a different privacy policy.

  9. Minors

    Our Services are not intended for use by individuals under the age of sixteen (16) (or under 13 if you are in the European Economic Area (EEA)/United Kingdom, or under 14 if you are in China). We do not knowingly collect personal information from minors without verifiable parental/guardian consent. If you are under the applicable age limit, please refrain from providing any personal information (including name, email, or device identifiers) to us.

    Parents and guardians are encouraged to monitor their children’s online activities and discuss safe internet practices with them. If you are a parent/guardian and suspect that we have inadvertently collected information from a minor, please contact us immediately atadmin@goldenmindplay.com with the subject line “Minor Data Removal Request”. We will verify your relationship to the minor and delete the relevant data within 7 working days.

  10. Third-Party Links

    Our Services may contain links to third-party websites, apps, or services (e.g., social media sharing buttons, affiliate links). We do not control these third parties and are not responsible for their privacy practices, content, or security measures. We recommend that you review their privacy policies and terms of service before providing any personal information or interacting with them.

  11. California Privacy Rights

    California residents have specific rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including:

    • The right to know what personal information we collect, use, disclose, or sell about you (we do not sell your personal information to third parties);
    • The right to request deletion of your personal information (subject to certain exceptions, e.g., legal retention requirements);
    • The right to opt out of the sale of your personal information (we do not sell personal information, so this right does not apply);
    • The right to non-discrimination for exercising your privacy rights (we will not deny you access to the Services or charge you higher fees because you exercised your rights);
    • The right to correct inaccurate personal information;
    • The right to data portability (receive a copy of your personal information in a machine-readable format).
    To exercise these rights, please submit a request toadmin@goldenmindplay.com with the subject line “California Privacy Rights Request - [Your Name/Email]”. We will verify your identity and respond to your request within 45 days (or 90 days if necessary, with notice). For more information about our data practices for California residents, contact us at the email above.

  12. Advertising Policy

    • Advertising Partners: We work with reputable third-party advertising partners (listed in Appendix A) to display ads in our Services. These partners may collect device information (e.g., advertising ID, IP address) to deliver ads, but they are prohibited from collecting personal information (e.g., name, email) without your consent.

    • Ad Data Collection: All ad-related data collection is subject to your consent (where required by law, e.g., EEA). We do not share your personal account information (e.g., email, payment details) with advertising partners.

    • Ad Transparency: If you see an ad that you believe is inappropriate or in violation of our policies, please report it to us atadmin@goldenmindplay.com with the subject line “Ad Complaint - [Ad ID/Description]”.

  13. Data Security

    We take reasonable technical and organizational measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction, including:

    • Encryption of personal data in transit (HTTPS/TLS 1.3) and at rest (AES-256);
    • Role-based access control (only authorized employees can access personal information, and only for necessary business purposes);
    • Regular security audits and vulnerability assessments (conducted quarterly by internal and external auditors);
    • Employee training on data protection laws and privacy best practices (mandatory annual training);
    • Secure data storage (data is stored in ISO 27001-certified data centers).
    However, no data transmission over the internet or electronic storage method is completely secure. We cannot guarantee the absolute security of your information. If a data breach occurs that affects your personal information (as defined by applicable law, e.g., GDPR, CCPA), we will notify you and relevant regulatory authorities within 72 hours of discovery (or as required by law) and provide steps you can take to protect yourself.

  14. Contact Us

    If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

    • Email:admin@goldenmindplay.com
    • Postal Address: 3/F, WORKINGTONTOWER, 78 BONHAM STRAND, SHEUNG WAN HK (Attn: Privacy Team)
    • Response Time: We will respond to your inquiry within 10 business days.
    If you are not satisfied with our response, you may escalate your concern to your local data protection authority (e.g., ICO in the UK, CNIL in France, CCPA in California).

Appendix A: Third-Party Advertising Networks

We work with the following third-party advertising networks (subject to change; we will update this list periodically):

These networks comply with self-regulatory frameworks such as the Digital Advertising Alliance (DAA) and the Interactive Advertising Bureau (IAB). They offer their own opt-out mechanisms, which can be accessed via their privacy policies linked above.

Need Further Assistance?

Our privacy team is available to address any questions you may have about your personal data or this policy. Reach out to us atadmin@goldenmindplay.com – we’re here to help!