Trueplay Inventions Inc.

Privacy and Cookies Policy

Lastly updated: 12/04/2023

This Privacy and Cookies Policy explains how information is collected, used and disclosed by Trueplay Inventions Inc., (hereinafter – “Trueplay”, “we”, “us”, “our”), a company, duly incorporated and existing under the laws of Republic of Seychelles, when you access or use our website, or other products or services, including TRUEPLAY Widget which is included in our digital service on tokenization of reward system and loyalty programs (collectively, the “Services”), or when you otherwise interact with us. By reaching our website https://trueplay.io/ (hereinafter – the “Website”) you may access our Services provided that you accept our Terms of Use and our respective policies and you successfully pass onboarding procedure. For details on the information we may collect about you or your device, please read further.

By continuing to access and use the Website you accept our use of your personal data and cookies.

Information We Collect

We may collect the following types of personal data from you when you use our Website and interact with our Services:

• Name: We may collect your full name when you provide them to us during registration, account setup, or other interactions.

• Email address: We may collect your email address when you provide it to us for the purpose of communication, account setup and account verification, use of our Services, and updates.

• IP address: We may collect your IP address automatically when you visit our Website, which helps us understand how our Website is used and improve its functionality.

• Other Log Information: We may collect other log information when you access our Website such as including access times, pages views and the website navigation paths.

• Survey responses: If you choose to participate in surveys or provide feedback, we may collect your responses to those surveys.

• Device Information: We may collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, your web browser, and device identifiers (including a network ID used to communicate with other nodes on the platform).
• Usage Information: If you use our Website, we will collect information contained in or relating to any communication that you send to us or send through our Website (including shard size, number of shards and frequency of access), and metadata associated with the communication. 
• Information Collected by Cookies and Other Tracking Technologies via Our Services: We use cookies on Website to collect information about your visit and to allow you to navigate from page to page without having to re-login each time, count visits, and see which areas and features of our Website are popular. Cookies are small text files that are usually stored on computer’s hard drive by websites that you visit. With this knowledge, we can improve the quality of your experience with or services by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties. Web beacons (or pixel tags) are electronic images that may be used in our web Services or emails to help deliver cookies, count Website visits, understand usage and determine the effectiveness of email marketing campaigns.

Our use of cookies and other technologies may allow us and third parties to collect information about your browsing activities over time and across different websites following your use of our Services.

• Other information: We may collect any other information that you choose to provide to us during personal communication, such as through email or other means of communication.

Information You Provide to Us

We may collect information you provide directly to us. For example, we collect information you provide when you subscribe to our updates, respond to a survey, fill out a form, request customer support or communicate with us. The types of information we may collect include your name and surname, email address, IP address, survey responses and any other information you choose to provide during personal communication with Trueplay manager.

If you use our Website, our third-party service provider may collect your payment method information for use in connection with your payments.

How We Use Your Personal Data

We use your personal data for the following purposes:

• Providing Services: We use your personal data to provide and deliver our digital Services, including tokenization of reward systems and loyalty programs, as well as to communicate with you about your account, respond to your inquiries, monitor and analyze trends, usage and activities in connection with our Services, and provide customer support.

• Developing new products and services: We may use your personal data to develop new products and services.

• Improving our Services: We may use your personal data to analyze how our Services are used, improve their functionality, and enhance user experience.

• Communicating with you: We may use your personal data to communicate with you about our Services, updates, promotions, technical notices, events and other relevant information.

• Legal compliance: We may use your personal data to comply with applicable laws, regulations, and legal obligations, including General Data Protection Regulation (GDPR) requirements (if they apply in your case) as well as detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Trueplay and others.

• Terms of Use Compliance: We may use your personal data to verify your compliance with the Terms of Use governing the use of our Website and Services.

Legal Basis for Processing Your Personal Data

We process your personal data based on the following legal bases:

• Contractual necessity: We process your personal data to fulfill our contractual obligations in providing our Services to you, including registering your account and delivering the requested Services.

• Legitimate interests: We may process your personal data based on our legitimate interests, such as improving our Services, communicating with you about our Services, and ensuring the security and integrity of our Website and Service.

• Consent: In some cases, we may rely on your consent to process your personal data, such as when you provide us with your email address for communication or participate in surveys.

Data Sharing and Disclosure

We do not sell or rent your personal data to third parties. However, we may share your personal data with the following types of recipients:

• Service providers: We may share your personal data with third-party service providers who may be engaged by us to help in providing our Services, such as hosting, data storage, customer support, and others.

• Legal requirements: We may disclose your personal data as required by applicable laws, regulations, legal processes, or governmental requests. We may disclose your personal data in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process.

• Business transfers: In the event of a merger, acquisition, or other business transfer, we may transfer your personal data to the relevant third party.

• Trueplay’s rights protection: We may disclose your personal data to the public authorities concerned if we believe your actions are inconsistent with our user Terms of Use or policies, or to protect the rights, property and safety of Trueplay.

• Internal sharing: We may disclose your personal data between and among Trueplay and its current and future parents, affiliates, subsidiaries and other companies under common control and ownership.

International Data Transfers

As part of providing our Services, your personal data may be transferred to, stored, and processed in countries outside of your own country of residence, including countries that may have different data protection laws than those in your jurisdiction. We will take appropriate safeguards to protect your personal data when it is transferred internationally, including ensuring that the recipients of your personal data provide an adequate level of data protection or obtaining your explicit consent, where required by applicable laws.

Transfer of Information to Republic of Seychelles and Other Countries

Trueplay is based in Republic of Seychelles and the information we collect is governed by the law of Republic of Seychelles. By accessing our Website or using our Services or otherwise providing information to us, you consent to the processing and transfer of information in and to Republic of Seychelles and other countries, where you may not have the same rights as you do under local law. Where this is the case, we will take appropriate measures to protect information about you in accordance with this Privacy and Cookies Policy. 

Correct/Update/Delete Information

You have right to access to your personal information and to require the correction, updating or deletion of incorrect or/and inaccurate data by contacting us, please email us at [email protected]. Nevertheless, this request must comply with legal obligations. Upon the accepted request, we will provide you with the personal information that we collect and store about you and general disclosure of your personal information.

Data Retention

In accordance with applicable laws and regulations and as needed to provide Services to you, we may hold your personal information. This requirement is conditioned by the need of complying with legal obligations and resolving possible disputes. We may retain your personal information so long as your account is active. Moreover, your information may be held beyond the abovementioned period till it is indispensable for us to have relevant information to respond to any issues that may arise later.

In case you have lawful demand on deletion of your personal information from our Services, please contact us at [email protected].

Your Rights

As a personal data subject, you have certain rights regarding your personal data. These rights may include:

• Right to access: You have the right to request access to the personal data we hold about you and receive information about its processing.

• Right to rectification: You have the right to request the correction of inaccurate or incomplete personal data we hold about you.

• Right to erasure: You have the right to request the deletion of your personal data under certain circumstances, such as when it is no longer necessary for the purposes for which it was collected.

• Right to restrict processing: You have the right to request the restriction of processing of your personal data under certain circumstances, such as when you contest its accuracy or object to its processing.

• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller where technically feasible.

• Right to object: You have the right to object to the processing of your personal data under certain circumstances, such as when it is processed for direct marketing purposes or based on legitimate interests.

• Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

• Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority if you believe that our processing of your personal data infringes applicable data protection laws.

Security Measures

We take appropriate technical and organizational measures to protect the privacy of the information you provide to Trueplay from loss, misuse, disclosure, alteration and destruction. Please note that transmission of data or information (including communications by e-mail) over the Internet or other publicly accessible networks is not one hundred percent secure. Please note that we are not liable for the security of any data you are transmitting over the Internet, or third party content.

Links to Third-Party Websites

Our Website may contain links to third-party websites or services that are not operated or controlled by us. This Privacy and Cookies Policy does not apply to such third-party websites or services, and we are not responsible for their privacy practices. We recommend reviewing the privacy policies of third-party websites or services before providing any personal data.

Minor’s Privacy

Our Services are not intended for minors under the age of 18, and we do not knowingly collect or process personal data from minors without appropriate parental consent. If you believe that we have inadvertently collected personal data from a minor, please contact us immediately, and we will take steps to delete the information as required by applicable laws.

Cookie policy

Cookies pixels, and other technologies (collectively, “cookies”) are small files that contain information which is transferred to and from your computer’s or mobile device’s hard drive.

These technologies help us better understand user behavior, tell us which parts of our Website people have visited, and facilitate and measure the effectiveness of advertisements and web searches.

By continuing to access and use the Website you accept our use of cookies.

However, you are free to explore the Website without providing any personal data, if you have disabled cookies in your internet browser. If you have not disabled cookies, our Website may use cookies to track your use of the Website and collect navigational information.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of the Website.

• Analytical/performance cookies. These allow us to recognize, count the number of visitors, and see how visitors move around the Website when they are using it. This helps us to improve the way the Website works.

• Functionality cookies. These are used to recognize you when you return to the Website. They enable us to personalize content for you, greet you by name and remember your preferences, for example, your choice of language.

• Targeting cookies. These cookies record your visit to the Website, the pages you have visited and the links you have followed. We will use this information to make the Website more relevant to your interests. We may also share this information with third parties for this purpose.

Why we use cookies

We use cookies to recognize your browser, your computer or your mobile device, learn more about your interests, provide you with essential features and Services, and for other purposes. More specifically, these include:

• Recognizing you when you sign in to use our Services. This allows us to provide you with product recommendations, display personalized content, and provide other customized features and Services.

• Conducting research and diagnostics to improve Services.

• Preventing fraudulent activity.

• Improving security.

• Reporting. This allows us to measure and analyze the performance of our Services.

• Cookies allow you to take advantage of some of the Website’s essential features. For instance, if you block or otherwise reject our cookies, you may not be able to use any of our products or services that require you to sign in.

Approved third parties may also set cookies when you interact with Website and related Services. Third parties include search engines, providers of measurement and analytics services, and advertising companies. Third parties use cookies in the process of delivering content, including ads relevant to your interests, to measure the effectiveness of their ads, and to help us to perform Services.

Managing cookies

You can manage browser cookies through your browser settings. The ‘Help’ feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable cookies, and when cookies will expire. If you disable all cookies on your browser, neither we nor third parties will transfer cookies to your browser. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some features and Services may not work.

For additional, more detailed information about cookies and how they can be managed and deleted, please visit www.allaboutcookies.org.

Changes to this Privacy and Cookies Policy

We may update this Privacy and Cookies Policy from time to time to reflect changes in our data practices or legal requirements. We will notify you of any material changes by posting the updated Privacy and Cookies Policy on our Website or through other means of communication. We encourage you to review this Privacy and Cookies Policy periodically for the latest information on our privacy practices.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy and Cookies Policy or our data practices, please contact us using the following contact information:

Trueplay Inventions Inc. 

House of Francis, Room 303, Ile Du Port, Mahe, Seychelles 

[email protected]

Thank you for reading our Privacy and Cookies Policy. By using our Website and Services, you acknowledge that you have read, understood, and agreed to the terms of this Privacy and Cookies Policy.