Effective Date: May 25, 2018

Last Updated Date: May 25, 2018

If you are a User having your usual residence in EU Member Countries, instead of the below you shall refer to the Privacy Policy specifically drafted for such Countries (which follow the below general Privacy Policy)


This privacy policy (“ Privacy Policy ”) is incorporated by this reference into the End User License Agreement and Terms of Service located at (“ EULA ”).

The terms “ phlay ”, “ we ”, and “ us ” refer to Emoticron s.r.l., an exempted company duly incorporated with limited liability and validly existing under the Laws of Italy, and its affiliates and/or subsidiaries. All other terms not defined in this Privacy Policy will have the meanings set forth in the EULA.

This Privacy Policy explains how phlay may collect, use, and disclose information we obtain through the Service.

As used in this Privacy Policy, “Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as your name, address, email address, or phone number. We do not consider Personal Information to include information that has been aggregated and/or de-identified so that it does not allow a third party to easily identify a specific individual.


The Service Collects Your Information.

We collect information, including Personal Information, when you:

i.·register to use the Service;

ii.·log in with social networking credentials;

iii.·submit information to us when you use the Service; and

iv.·communicate with us.

We also collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology as you use the Service.


Personal Information Collection.

You may browse the public-facing portions of the Service without registering an Account with phlay. If you register an Account with us to use the Service, then you must provide us with certain Personal Information, such as your email address, or you may register using your User credentials to certain social media sites, such as Twitter or Facebook.


Social Sign-On.

We may collect Personal Information from a social media website when you use your social media credentials to log into the Service. For example, when you log in with your Twitter or Facebook credentials, we may collect the Personal Information you have made publicly available on those websites, such as your User name and profile picture. We may also obtain other non-public information with your permission.


Using the Service.

We collect information that you Post to the Service. For example, when you Post comments, a short biography or UGVs on the Service, we will collect the information you include in these submissions, including any Personal Information.



We collect and process information you provide, including any Personal Information, in the context of composing, sending, or receiving messages through our Service’s messaging functionality, and we may collect information about your use of our messaging functionality. Please be aware that messages sent to other Users of our Service will be accessible by those other Users and that we are not responsible for the manner in which those Users use or disclose messages.


Location Information.

We collect information about your location if you grant us permission to do so. If you change your mind and do not want us to collect your location information, then you can choose to hide your location under the “Settings” tab within the App.


Customer Support.

We collect all information that you provide to us, including any Personal Information, when you contact us for customer-support purposes.


Cookies, Automatic Data Collection, and Related Technologies.

The Service collects and stores information that is generated automatically as you use it, including your preferences and anonymous usage statistics.

When you visit the Service, we and our third-party service providers receive and record information on our server logs from your browser, including your IP address, and from cookies and similar technology. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service. Please review your web browser “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete, or choose not to accept, cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential. We may use third party cookies on our Service as well. For instance, we use Google Analytics to collect and process certain analytics data. Google provides some additional privacy options described at regarding Google Analytics cookies. By using the Service, you are authorizing us to gather, parse, and retain data related to the provision of the Service.


How phlay Uses Your Information.

We use Personal Information to:

i. facilitate and improve our Service; and

ii. communicate with you.

We may use de-identified and aggregated information for any lawful purpose, including for marketing purposes.


Internal and Service-Related Usage.

We use information, including Personal Information, for internal and Service-related purposes and may provide it to third parties to allow us to provide and improve the Service.



We may send email to the email address you provide to us (a) for customer service related purposes, (b) to provide you with updates or information relating to the Service, including promotions and other opportunities, or (c) for enforcement of the EULA or this Privacy Policy.


Aggregate Data.

We may de-identify and aggregate information collected through the Service and use it for any lawful purpose.


Phlay May Disclose Your Information.

We may share your information:

i. with our third-party service providers;

ii. to comply with legal obligations;

iii. to protect and defend our rights and property and the rights, property and safety of our Users; and

iv. with your permission.

We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission.


We Use Vendors and Service Providers.

We may share any information we receive with vendors and service providers retained in connection with the provision of the Service.


Social Networking and Other Websites.

The Service may allow you to share information, including Personal Information, with social networking websites, such as Twitter, Facebook and Instagram. We do not share your Personal Information with these social networking sites unless you direct the Service to share your Personal Information. The use of your Personal Information by any social networking websites will be governed by their privacy policies, and you may be able to modify your privacy settings on their websites.


User Content and Information.

User Content you Post to the Service, such as UGVs, comments and your short biography, will be displayed on the Service and viewable by other Users. In addition, your profile information, such as any photograph of you and your User name, will also be searchable and accessible by other Users. We are not responsible for the privacy practices of the other Users who will view and use this information, so you should carefully consider whether to Post any User Content on the Service or how you identify yourself on the Service. You should not disclose your home address or the address of your place of business, school or other locations you frequent on a regular basis in any User Content.



We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission.


Location Information.

We may share your location information with other Users by tagging your UGVs with your location information. We will not share your location with other Users, aside from location information that you choose to share.


As Required By Law and Similar Disclosures.

We may access, preserve, and disclose your Personal Information or other account information if we believe doing so is required or appropriate to (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our or others’ rights, property, or safety.


Merger, Sale, or Other Asset Transfers.

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy or liquidation where the business will not continue as a going concern, receivership, sale of phlay assets, or transition of the Service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. The use of your Personal Information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable Personal Information was collected.



We may also disclose your Personal Information with your permission.


Security of Your Information.

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional access, use or disclosure.


Children’s Privacy.

We do not knowingly collect information from children under 13 and we do not want it. We will take steps to delete it if we learn we have collected it.

We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of the Service is directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, then you may alert us at If we learn that we have collected any Personal Information from children under 13, then we will promptly take steps to delete such information and terminate the child’s account.


International Users.


By choosing to visit the Service or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the State of Italy and the adjudication of any disputes arising in connection with phlay or the Service will be in accordance with the EULA located at


Update Your Information or Pose a Question or Suggestion.

If you would like to update or correct any information that you have provided to us through your use of the Service or otherwise, or if you have suggestions for improving this Privacy Policy, then please send an e-mail to


Changes to our Privacy Policy and Practices.

We may revise this Privacy Policy, so please review it periodically.


Posting of Revised Privacy Policy.

We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective when it is posted. If you are concerned about how your information is used, then bookmark this page and read this Privacy Policy periodically.


New Uses of Personal Information.

From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, then we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.


Contact Information.

Emoticron s.r.l.

Via dei Mille 16, 80121- Naples (Italy).

for EU Member Countries

Effective Date: May 25, 2018

Last Updated Date: May 25, 2018

If you are a User having your usual residence in EU Member Countries, the following Privacy Policy shall apply.


Welcome to phlay (the “App”). The App is provided or controlled by Emoticron s.r.l, a company duly incorporated and validly existing under the Laws of Italy (“Emoticron” or “we” or “us”). We are controller of your personal data in the sense of Art. 4.7 of the EU General Data Protection Regulation 2016/679 (“GDPR”) and other data protection or data privacy laws in the Member State of the European Union and other Guidelines with a data protection nature regarding the platform and as such, we are committed to protecting and respecting your privacy.

Our contact details are: Emoticron s.r.l., Via Dei Mille 16, 80121 – Naples (Italy).

The Data Protection Officer of Emoticron may be contacted at

To provide our services to you, we offer you a website and a free App that you can download onto your mobile phone. This policy sets out the basis on which any Personal Data from you will be processed, collected, used, and disclosed by us when you access or use our website, applications, products and content (collectively, the “Services”).

Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.

Capitalized terms that are not defined in this policy have the meaning given to them in the EULA available at


The Personal Data we process within our Service.

We collect and process Personal Data either directly from you (e.g. when you provide certain information to us) or indirectly (e.g. through our platform’s technology).

“Personal Data” means any information relating to an identified or identifiable natural person (“Data Subject”); a Data Subject is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.


Information you give us as a User.

You may not use our Services if you are under 13 years old. Therefore, we ask you to provide us with your birthdate to verify that you are 13 years or older before you may register for an account on our App. If you are under the age of 18 (or applicable legal age) and if required by applicable law, we will ask you to provide approval of your parents or legal guardians that you are allowed to use our services via e-mail in accordance with our EULA.

If you register an account with us to use the App, you must provide us with certain Personal Data, including your name, unique account name and, if provided, your e-mail address, telephone number and your photograph as well as your language selection. You may also be able to register using your User credentials to certain social media sites, such as Twitter, Facebook, Instagram or Google. This information also allows us or other Users to find you on the App.


Information we collect about you when you use the Services.

When you use our Services we automatically collect your IP address (not using GPS data), device information, or other unique device identifiers, Cookies (as defined below), browsing records, mobile carrier, time zone and locale setting, mobile or device model, operating system and platform as well as information regarding your use of the Services, e.g. the comments you make on our App or any other User-generated content and video content that you broadcast on our App.

Furthermore, we collect behavioral information, for example, collecting engagement scores (likes, comments, repeated views) and relate Users based on your behavior, alongside marketing information such as opt-ins and communication preferences. We also collect information about linking your contact or subscriber information with your activity across our Services or by linking your activity on our App across all your devices using your email or social media log-in details.

When you use our App we may collect your account name, e-mail address, telephone number, photographs, and any Personal Data in connection with videos that you upload as well as the mobile phone model and the mobile phone operating system version. We further process information about your location based on IP address once to select the videos that we display according to your place of residence.


Information you choose to share from your social networks.

If you choose to link the App to your social network or public forum account (such as Facebook), you may provide us or allow your social network to provide us with information from your social network or public forum accounts. This data may include your use of the App on such public forums and/or social networks (e.g. your public profile information, e-mail address and friends list). For further information as to how and for what purpose the social network provider processes your Personal Data, please see their privacy policies.


Find other Users and invite your friends.

You may find other Users of the App either through (i) your phone contacts or (ii) Facebook contacts. If you chose to find other Users through (i) your phone contacts, we will access your phone contacts, including the names, phone numbers, addresses and any other information that you have stored on your phone about your contacts in order to determine if they are using the App by matching them with existing Users of the App. If you want to find other Users through (ii) your Facebook contacts, we may process your public Facebook information as well as names and profiles of your Facebook contacts in accordance with the privacy provisions of Facebook. You may also invite selected recipients to join our App by sending them an e-mail with your profile, including you profile information.



We collect and process information you provide, including any Personal Data, in the context of composing, sending, or receiving messages (that means the content as well as the information when the message has been sent, received and/or read and the participants of the communication) through our Service’s messaging functionality. Please be aware that messages sent to other Users of our Service will be accessible by those other Users and that we are not responsible for the manner in which those Users use or disclose messages.



When you upload a video to the App (User Content) you automatically upload certain metadata that is connected to the User Content. In essence, metadata describes other data and provides information about your User Content that may not always be evident to the viewer. In connection with your video the metadata can describe how, when and by whom the piece of User Content was collected and how that content is formatted. It further includes Personal Data such as your account name that enables other User to trace back the video to your User account. Metadata may further consist of additional Personal Data that you chose to provide with the video, e.g. any hashtag to mark keywords to the video or comments.


Information from third parties.

We may receive information if you use any of the other websites we operate or other Services we provide. We may also receive information from third party SDKs, and from other sources, including business directories and other commercially or publicly available sources. The list of the information that we receive from third parties, including the respective third parties are indicated in the last paragraph of this Privacy Policy.



We use cookies and other similar technologies (e.g. web beacons, Flash cookies, etc.) (“Cookies”) to enhance your experience using the Services. Cookies are used to indirectly collect information, including Personal Data, from you. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

Although most Web browsers automatically accept Cookies, the decision of whether to accept or not is yours. You have the choice to accept or decline Cookies by way of consent (we may drop Strictly Necessary Cookies even without your consent). If you do not accept Cookies, we will not be able to tailor the ads shown to you and you will receive only ads without customized content. Cookies placed by us will expire when you terminate the website session or after 90 days.

There are different types of Cookies:

i. Strictly necessary Cookies. These are Cookies that are required for the operation of the Services. They include, for example, Cookies that enable you to log into secure areas of the Services.

ii. Functionality Cookies. These are used to recognize you when you return to the Services. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

iii. Targeting Cookies. These Cookies record your visit to the Services, the pages you have visited and the links you have followed. We will use this information to make the Services and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

iv. Analytics Cookies. Analytics are statistical audience measuring systems that we use for our Services.


Analytics information.

On our website, we use third-party analytics tools to help us measure traffic and usage trends for the Services. Traffic refers to the different data flows surrounding activities of the Users on the Services. These tools, for example, collect information sent by your device or our Services, including the web pages you visit, add-ons, and other information that assists us in improving the Service. The information will be used to report and evaluate your activities and patterns as a User of the platform to provide services in accordance with these activities.

Our third party analytics tool is Google Analytics provided by Google, Inc (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). Google Analytics uses Cookies, small text files containing a string of alphanumeric characters and being stored on your computer. Google will use this information including your truncated IP address to assemble statistics on the use of our Service or to provide other related services as described above. For further information on how Google Analytics collects and processes information about you and information on how to opt out from Google's collection of information from you, please see

You may also find further information in the Google Anallytics Terms of Services and Privacy available at

We further use “Facebook Pixel” of Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA (“Facebook”). This tool is solely used for retargeting purposes in order to reveal if you have seen our advertisement on Facebook. If you do not want Facebook to collect the described information about you, you can opt-out Facebook’s use of cookies and Facebook Pixel on Facebook.

Please note that our websites do not respond to “do-not-track” signals in your web browser. “Do-not-track” signals are preferences that Users can set on their web browser to limit how their activity is tracked across third-party websites or online services.


Information for Users in Germany.

If you use our friend finder in the App in Germany and want to find other Users through your phone contacts, we will not access and upload your phone contacts, including the names, phone numbers, addresses or any other information that you have stored on your phone about your contacts. We only access this data in an encrypted form. In order to determine if your contacts are using the platform we will only upload hashed names and mobile numbers and align these hashes with hashes of names and mobile numbers with existing Users of the platform. Mismatches will be dropped instantly while we will show matching Users to you as the User who uploaded the hashed contacts. We will not access unhashed contact details stored on your device. Accordingly, we will also not use your mobile number, if you have provided such number to us, to let Users find you on phlay. We will not disclose your mobile number to anyone but only allow Users on their request to upload hashed name fields and mobile numbers from their address book to us (hashed on the Users' device).


How we use your Personal Data.

We will use your Personal Data for the following purposes.

Personal Data that we collect from your visit on our website is processed for system administration (e.g. to improve our website and Services to you), for statistical or security proposes (e.g. to guarantee the website’s stability and security) of our website as well as to solicit your feedback. The processing of this Personal Data is necessary for the purposes of our legitimate interests pursuant to Art. 6.1.f) of the GDPR.

We are required by law to verify your age and ensure that you are old enough to use our Services and therefore ask you for your birthdate prior to your registration on the Services pursuant to Art. 6.1.c) of the GDPR.

The e-mail address and content of the e-mail, including the names and addresses, if provided, concerning the approval from your parents or legal guardians for your use of the Services will be processed by us to verify that we are allowed to provide you with the Services, Art. 6.1.c) of the GDPR.

When you register as a User of our Services, we obtain Personal Data to create your User account, which is necessary to provide you with the Services according to Art. 6.1.b) of the GDPR. We may further use your Personal Data from your registration in accordance with Art. 6.1.b) of the GDPR to:

i. notify you about changes to our Services;

ii. provide you with User support;

iii. enforce our terms, conditions and policies; or

iv. communicate with you.

We may use your Personal Data from your registration that identifies you as a User of the Services also to allow other Users to identify you via the “Find other friends” function as a User of the Services as well as your phone contacts to find other Users and to connect you on the platform and support the socializing function of the Services in accordance with our legitimate interest to provide Users the ability to connect on the Services for a more lively community, Art. 6.1.f) of the GDPR. Furthermore, in the “Find other friends” function you may send an e-mail to anyone via your e-mail provider and invite him/her to use the App. In order to fulfil our legitimate interest according to Art. 6.1.f) of the GDPR to expand our Services and increase your User friends, we provide you with your profile information to send to anyone you choose.

We collect and process the Personal Data of your User Content in order to provide you the Services and to enable you to participate on the platform and interact with other Users, Art. 6.1.b) of the GDPR. Without the submission of your Personal Data such as your name, User account name or the Personal Data within your User Content we may not be able to provide you with our Services. We further use your Personal Data to make the Personal Data available to other Users in accordance with the privacy settings you chose for the respective Personal Data. If you upload a video to the App for the first time, you will be notified that you are using our Services on a public account, meaning that you Post a video that may be viewed by every User of phlay regardless your connection to the User. You may limit the audience having access to the Personal Data included in the information that you Post to the Service in your privacy settings as specified in the information window. Changes to the privacy settings in the App will immediately apply and also affect information that you have posted in the past. We will delete your Personal Data from your use of the Service once you decided to delete the respective UGV or Broadcast Content or other information you provided in your profile.

We may also process your Personal Data of your use of the Service to show you content that is similar to content you liked or interacted with (by comments and/or watching), content from your region as well as by Users you follow. This processing of Personal Data of you helps us to improve the content of the Service in accordance with Art. 6.1.f) of the GDPR.

In particular, we will process your Personal Data to be responsive to you and to ensure the proper functioning of our products and organization, Art. 6.1.f) of the GDPR. As it is in our legitimate interests, we may use your Personal Data to:

i. improve the Services and to ensure content from the Services is presented in the most effective manner for you and your device;

ii. administer the Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

iii. allow you to participate in interactive features of the Services, when you choose to do so;

iv. personalize the content you receive and provide you with tailored content that may be of interest to you;

v. keep the Services safe and secure;

vi. develop our Services and conduct product development;

vii. measure and understand the effectiveness of the advertising we serve to you and others;

viii. provide you with Services based on the Country settings you have chosen, such as advertising and other content that is related to the Country settings;

ix. make suggestions and recommendations to you and other Users of the Services about goods or services that may interest you or them; or

x. provide you – or permit selected third parties to provide you – with information about goods or services we feel may interest you. Where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this (Art. 6.1.a) of the GDPR).

If you provide your consent, we may promote the Services and use information that you give to us, such as User-generated content and video content that you may choose to broadcast on our App, as part of our advertising and marketing campaigns to promote the Services in accordance with Art. 6.1.a) of the GDPR.

The processing of your Personal Data in relation to the usage of the messenger function is solely for the purpose to provide this functionality of the Services to you pursuant to Art. 6.1.b) of the GDPR, in order for you to contact other Users of the Services. It will only be processed if you choose to use this function. You may choose to delete any Personal Data in this regard on your discretion via the clear cache function within the App’s settings.


How we share your Personal Data.

We may share your personal data with selected third parties in or outside your country, including:

i. our business partners so that we can make you special offers via the Services;

ii. with respect to on-screen advertisements, advertisers and advertising networks that require the data to select and serve advertisements to you and others. We will not share your contact details with our business parties so they will not contact you directly, but we will share other information so that they can make you offers tailored to your requirements;

iii. our suppliers and subcontractors who help us run the Services; or

iv. analytics and search engine providers that assist us in the improvement and optimization of the Services.

We may also share your information with any member or affiliate of our group, which includes our subsidiaries, our ultimate holding company and its subsidiaries, and companies that we control, are controlled or under common control, and our service providers and strategic business partners, and their respective subsidiaries, in each case in or outside your Country, for the purposes set out above (“How We Use Your Personal Data”).

We may further share your information with law enforcement agencies, public or tax authorities or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

a. comply with a legal obligation, process or request (including tax and related reporting requirements);

b. enforce our EULA and other agreements, policies, and standards, including investigation of any potential violation thereof;

c. detect, prevent or otherwise address security, fraud or technical issues; or

d. protect the rights, property or safety of us, our Users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).

We may also disclose your information to third parties:

1. in the event that we sell or buy any business or assets, in which case we may disclose your data to the prospective seller or buyer of such business or assets; or

2. if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, User information may be among the transferred assets.


Where we store your Personal Data.

The Personal Data that we collect from you will also be transferred to, and stored at, a destination outside of your Country and the European Economic Area (“EEA”), specifically, to third party servers in the United States of America. We transfer your Personal Data to the servers of our host providers Amazon Web Services, Inc. in the United States of America. We also transfer any video content of the Users to the servers of our host providers Amazon Web Services, Inc. in the United States of America.

It may also be processed by staff operating outside your country or the EEA who work for us, for one of our suppliers or one of our business partners. Please refer below to “The Security of your Personal Data” for the security of your Personal Data in connection with the storage.


The Security of your Personal Data.

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your information transmitted through the platform; any transmission is at your own risk. We do have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other Users. We maintain these technical and organizational measures and may amend them from time to time to improve the overall security of our systems. We also ensure that our third party vendors will provide the same level of protection as provided in the terms of this Privacy Policy.

The transfer of your Personal Data to our host providers Amazon Web Services, Inc. in the United States of America is conducted under an adequate level of data protection as compared to the GDPR.

The transfer of your Personal Data to members or affiliates of our group as well as our host providers occur under an adequate level of data protection as compared to the GDPR because it is conducted on the basis of standard contractual clauses in accordance with Art. 46 of the GDPR.

For a copy of these standard contractual clauses, please contact us at

We may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.


Data Retention.

We will retain your information for so long as we are required to retain such information under applicable laws.

We delete your Personal Data concerning the in-app message function if your account is terminated, for any reason, after 30 days.

We delete your browser behavior information after 90 days. We installed a periodic review for the deletion of your browsing information and designated someone who is responsible for the review and deletion.

After you have terminated your use of our Services, we may store your information in an aggregated and anonymized format. Notwithstanding the foregoing, we may also retain any personal information as reasonably necessary to comply with our legal obligations, allow us to resolve and litigate disputes, and to enforce our agreements.


Information relating to Children.

The Services are not directed at children under the age of 13. Users under the relevant legal age are not allowed to use the Services or register an account on the App without the consent of their parent of guardian. If we become aware that Personal Data has been collected from a person under such age in the relevant jurisdiction and parental or guardian consent has not been provided, we will delete this information and terminate the person’s account. If you believe that we may have Personal Data about or collected from a child under the specified age in the relevant jurisdiction without the consent of their parent or guardian, please contact us at


Your Rights.

You have the right to access your Personal Data that we hold about you and to correct, update, amend, suppress, delete or otherwise modify any Personal Data where it is inaccurate, or has been processed in violation of the applicable data protection regulations, unless we have to keep the Personal Data for legitimate business or legal purposes. Prior to the fulfilment of your request concerning your Personal Data, we may ask you to verify your identity before we can act upon your request.

You may object to the use or processing of your Personal Data or withdraw consent to use your Personal Data at any time You have the following rights:

i. the right to require free of charge (a) information whether your Personal Data is retained and (b) access to and/or (c) duplicates of the Personal Data retained. However, if the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request;

ii. the right to request proper rectification, removal or restriction of your Personal Data;

iii. where processing of your Personal Data is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the Personal Data concerning you in a structured, commonly used and machine-readable format or to have your Personal Data transmitted directly to another company, where technically feasible (data portability);

iv. where the processing of your Personal Data is based on your consent, the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal or to any other existing legal justification of the processing activity in question;

v. the right not to be subject to any automatic individual decisions which produces legal effects on you or similarly significantly affects you; and

vi. the right to take legal actions in relation to any breach of your rights regarding the processing of the Personal Data, as well as to lodge complaints before the competent data protection regulators.

As far as we process your Personal Data on the basis of our legitimate interests (Art. 6.1.f) of the GDPR), you may object to processing (Art. 21.1 of the GDPR) at any time. You may find a detailed description of our processing activities and the legal basis in the section before. If you object to such processing, we ask you to state the grounds of you objection in order for us to examine the processing of your personal data and decide whether to adjust the processing accordingly.

Please note that the processing of your Personal Data may involve direct marketing activities as described above. If you do not want to have your activity on phlay’s Services processed for direct marketing activities, you can object to any data processing free of charge at any time via e-mail (Art. 21.2 of the GDPR) (, for the other contact details see above).

Please send an e-mail to us if you would like to exercise any of your rights (



In the event that you wish to make a complaint about how we process your Personal Data, please contact us in the first instance at 

 and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority or follow the dispute resolution process provided in the EULA.



We will use commercially reasonable efforts to generally notify all Users of any material changes to this Privacy Policy, such as through a notice on our Services, however, you should look at this Privacy Policy regularly to check for such changes. We will also update the “Last Updated” date at the top of this Privacy Policy, which reflects the effective date of such Privacy Policy. Your continued access to or use of the Services after the date of the updated Privacy Policy constitutes your acceptance of the updated Privacy Policy. If you do not agree to the updated Privacy Policy, you must stop accessing or using the Services.



Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to


List of third parties that collect Personal Data.

Third party

Personal Data


email, friends list, public profile info (based on User setting e.g., age, name, gender)


email, friends list, public profile info (based on User setting e.g., age, name, gender)


email, friends list, public profile info (based on User setting e.g., age, name, gender)


email, friends list, public profile info (based on User setting e.g., age, name, gender)

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