Privacy Policy

Your privacy matters. Learn how we protect and handle your data under GDPR and CCPA regulations.

Last Updated: January 1, 2026

1. Introduction & Data Controller Information

Welcome to PirateGirly Play ("we," "our," or "us"). We are committed to protecting your personal information and your right to privacy, fully complying with the EU General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA).

Official Data Controller

The entity responsible for processing your personal data is: PirateGirly Play Co., Ltd.

If you have any questions or concerns about our policy or practices, please contact us at [email protected] or our dedicated DPO.

2. Information We Collect & GDPR Legal Basis for Processing (Article 6)

We collect several different types of information for various purposes, with clear legal grounds defined under GDPR Article 6:

  • Personal Data (Account registration forms): Email address, username, password
    Legal Basis: Performance of contract (Art.6(1)(b)) to create and maintain your game account; explicit consent (Art.6(1)(a)) for optional marketing.
  • Usage Data: IP address, browser type, device information, pages visited, gameplay records
    Legal Basis: Legitimate interest (Art.6(1)(f)) for platform security, performance optimization, anti-fraud detection.
  • Cookies & Tracking: Session storage, analytics and advertising trackers
    Legal Basis: Explicit consent (Art.6(1)(a)) for non-essential analytics/marketing cookies; legitimate interest for essential functional cookies.
  • Game Data: Game progress, high scores, achievements
    Legal Basis: Performance of contract (Art.6(1)(b)) to deliver game services you request.

3. How We Use Your Information

We use the collected data for various purposes:

  • To provide and maintain our gaming services
  • To notify you about changes to our platform or services
  • To allow you to participate in interactive features when you choose to do so
  • To provide customer support for form submissions and account issues
  • To gather analysis or valuable information so we can improve our platform
  • To monitor the usage of our platform and detect technical issues
  • To personalize your gaming experience with recommendations
  • To send you updates, newsletters, and promotional content (only with your separate opt-in consent)
  • To fulfill legal and regulatory compliance obligations (Art.6(1)(c) GDPR)

4. Cookies & Tracking Technologies & EU Consent Rules

We use cookies and similar tracking technologies to track activity on our platform and hold certain information. All non-essential cookies will only activate after your explicit opt-in via our cookie consent banner required for EU/EEA visitors.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of our platform may not function properly without essential cookies.

Types of cookies we use:

  • Essential Cookies: Required for core platform functionality and security (no consent required).
  • Preference Cookies: Remember your settings and preferences for a better experience.
  • Analytics Cookies: Help us understand how you interact with games and our platform.
  • Advertising Cookies: Used to deliver relevant ads and measure campaign effectiveness.

5. Data Sharing & Third Parties

We do not sell your personal data as prohibited under CCPA. We may share your information with:

  • Service Providers: Third-party companies that help us operate our platform (hosting, analytics, email delivery).
  • Game Developers: Anonymous aggregated gameplay statistics for game improvement.
  • Legal Requirements: When required by law, court order, or governmental regulation.
  • Business Transfers: In connection with a merger, acquisition, or sale of assets.

All third parties are contractually obligated to protect your data and comply with applicable privacy laws including GDPR.

6. Data Security

We implement industry-standard security measures to protect your personal information, including:

  • SSL/TLS encryption for all data transmission
  • Passwords hashed using modern secure algorithms
  • Regular security audits and vulnerability scanning
  • Restricted role-based access controls to personal data

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

7. Full Data Subject Rights (GDPR) & Dedicated DPO Contact

7.1 Complete GDPR User Rights

You have the following full enforceable rights regarding your personal data under GDPR:

  • Access: Request a full copy of all personal data we hold about you.
  • Rectification: Request immediate correction of inaccurate or incomplete personal data.
  • Erasure (Right to be Forgotten): Request full permanent deletion of your personal data where no valid processing ground remains.
  • Restriction of Processing: Request us to pause all data processing under specific legal conditions.
  • Data Portability: Request structured machine-readable transfer of your data to another data controller.
  • Objection: Object to processing of your personal data for marketing or legitimate interest grounds; we must cease processing unless we prove overriding legitimate grounds.
  • Withdraw Consent: You may withdraw any previously given consent at any time without penalty.

7.2 Data Protection Officer (DPO) Mandatory Contact

Our independent Data Protection Officer oversees all GDPR/CCPA compliance, processes all data rights requests, and liaises with EU data protection authorities.

DPO Exclusive Email: [email protected]

All formal data rights requests must be sent to the DPO mailbox. We are legally required to provide a full response within 30 calendar days of receipt.

7.3 CCPA California Consumer Rights

If you are a California resident, you hold additional rights under CCPA:
1. Request disclosure of all categories of personal data we collect about you;
2. Request full deletion of all your stored personal records;
3. Opt out of any third-party personal data sharing;
4. Receive equal service without discrimination when exercising your privacy rights.
Submit all CCPA requests directly to our DPO email address.

8. Children's Privacy

Our platform is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13 via registration, contact or feedback forms. If you are a parent or guardian and believe your child has provided us with personal data, please contact our DPO immediately, and we will permanently remove all such information.

9. International Data Transfers

Your information may be transferred to and maintained on servers located outside the EEA/UK. We implement EU Standard Contractual Clauses (SCCs) as legally approved safeguards to ensure your data remains protected in accordance with this Privacy Policy and GDPR.

10. Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this policy. When your data is no longer needed, we will securely delete or anonymize it. Account data is retained while your account is active and for a limited period after account deletion to satisfy legal compliance requirements; anonymized analytics data is stored up to 36 months.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page, updating the "Last Updated" date, and sending advance email notice to registered users 30 days before new terms take effect. Continued platform use after updates constitutes acceptance of revised policy.

12. Contact Us

If you have any general questions about this Privacy Policy, please contact us:

You may also submit a formal complaint to your local national data protection supervisory authority if you believe we violate GDPR or CCPA rules.

13. Data Collection Form Privacy Disclosure

All registration, contact, feedback and support forms on our website collect personal data solely to process your submitted request. Any information entered into data collection forms is fully governed by this Privacy Policy. You are not required to fill optional fields. You may request access or full deletion of all form-submitted records by contacting our DPO. We never use form personal data for unsolicited marketing unless you tick a separate opt-in checkbox on the form.