Privacy Notice

Last updated on: Dec 12th, 2025

  1. INTRODUCTION.

    About Playgap.

    Playgap Ltd (company number: 14949926) is a company incorporated in England with its registered address at 20 Wenlock Road, London, England, N1 7GU ("Playgap", "we", "us", or "our").

    Playgap provides advertising solutions for developers ("Services").

    About this Privacy Notice.

    The purpose of this privacy notice is to explain, among other things:

    • The personal data Playgap collects about you when we are acting as a data controller and how we collect it.
    • How we use that personal data, including when we may share it with third parties.
    • Certain rights you may have concerning your personal data.

    By"personal data", we mean information that can be used to identify you as an individual.

    It is important that you read this privacy notice, together with the documents that are linked to from this privacy notice, and any other privacy notice or information we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we use your personal data. This privacy notice supplements other notices and privacy policies and is not intended to override them.

    Additional provisions of this privacy notice applicable to individual residents of various states within the United States of America that have enacted data privacy laws are included in our U.S. State Law Privacy Notice.

    For those Playgap customers (developers) that have entered into Playgap's Terms please refer to our Data Processing Agreement which outlines Playgap's role when acting as data processor on behalf of developers.

    Contact

    If you have any questions about this privacy notice or our privacy practices, or wish to exercise any legal rights you may have with respect to your personal data, please email us at privacy@playgap.io.

  2. PLAYGAP'S DATA USES.

    When you interact with our Services, such as when you download and use an application which contains our software, or interact with advertisements containing our software, we may collect certain types of personal data from you acting as a data processor on behalf of our customers (developers) who are the data controllers. For more information about how the developers use your personal data, please see the privacy information provided to you by the developers.

    When acting as a data controller, we may collect and process the following types of personal data:

    • Identity Data includes first name, last name, username or similar identifier, and title.
    • Contact Data includes billing address, email address and telephone numbers.
    • Financial Data includes bank account and payment card details.
    • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
    • Technical Data includes general technical information about the devices you use, such as the device's time zone setting and location, operating system and platform name and version, the language of the operating system, the name of the mobile carrier, your login data, browser type and version, browser plug-in types and versions, internet connection type (e.g. WiFi), and other technology on the devices you use to access our website and/or our services.
    • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
    • Usage Data includes information about how you use our website, products and services.
    • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

    We will only use your personal data when the law allows us to: where we have a"lawful basis". In cases when Playgap is a data controller, this includes:

    • Where the processing is necessary to perform the contract we are about to enter into or have entered into with you (Contract).
    • Where the processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests (Legitimate Interests).
    • Where you have given your consent to process your personal data for one or more specific purposes (Consent).
    • Where the processing is necessary for us to comply with a legal obligation (Legal Obligation).

    We have set out below, in a table format, a description of all the ways we may use your personal data when we are a controller, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    We may process your personal data relying on more than one lawful basis depending on the specific purpose for which we are using your personal data. Please contact us if you need details about the specific lawful bases we are relying on to process your personal data where more than one lawful basis has been set out in the table below.

    Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
    Developers registering for an account via our website including access to the Playgap Dashboard.
    1. Identity
    2. Contact
    3. Technical
    4. Profile
    		Consent (where we place non-essential cookies to collect Technical personal data). Performance of a contract with you.
    Developers registering for an account via the Website.
    1. Identity
    2. Contact
    3. Technical
    4. Profile
    		Consent (where we place non-essential cookies to collect Technical personal data). Performance of a contract with you.
    To administer and protect our website and services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
    1. Identity
    2. Contact
    3. Technical
    		Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
    To send you marketing messages about our products or services. You can ask us or the third parties we partner with to stop sending you marketing messages at any time by emailing us at privacy@playgap.io.
    1. Identity
    2. Contact
    3. Technical
    4. Profile
    5. Marketing
    6. and
    7. Communications
    		Necessary for our legitimate interests, where you have previously expressed an interest in our Services. Consent, where you have asked us to send you marketing.
    To deliver relevant website, services content and advertisements to you (outside of the Services) and to measure or understand the effectiveness of these actions.
    1. Identity
    2. Contact
    3. Profile
    4. Usage
    5. Marketing
    6. and
    7. Communications
    8. Technical
    		Necessary for our legitimate interests (to understand how customers use our services, to develop them, to grow our business and to inform our marketing strategy). Consent (where we place non-essential cookies to collect Technical personal data).
    Improving our data models and algorithms.
    1. Transaction
    2. Technical
    		Necessary for our legitimate interests (to train and improve the accuracy of our data models and analytics and to improve our Services). Consent (where we place non-essential cookies to collect Technical personal data).
    To monitor information about the devices used by users of our website and Services to help us make improvements.
    1. Technical
    2. Usage
    3. Profile
    		Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy). Consent (where we place non-essential cookies to collect Technical personal data).
    In connection with the sale, transfer or merger of our business to / with a third party.Identity Contact Financial Transaction Technical Profile Usage Marketing and CommunicationsNecessary for our legitimate interests (to facilitate the restructure and continue our business following the restructure).

    Change of Purpose.

    We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. We will update this privacy notice to describe the processing for the new purpose.

    If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.

    Please note that we may process your personal data without your knowledge or consent where this is required by law.

  3. INTERNATIONAL TRANSFERS.

    We store your data on third party servers which are based both in the UK and EEA and outside of the UK and EU. When working with third parties we may need to transfer your personal data outside of the UK and / or EU.

    Playgap has implemented and maintains a framework consistent with applicable law for transfers of personal data outside of the UK and EU. You can contact us at privacy@playgap.io for more information about this.

  4. DATA RETENTION.

    We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

    To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

    In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

  5. YOUR LEGAL RIGHTS.

    Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may have a right to:

    • Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
    • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
    • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no lawful basis for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
    • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
    • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data's accuracy.
    • Where our use of the data is unlawful, but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
    • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
    • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
    • Complain to your regulator for data protection. In the UK, the regulator is the Information Commissioner's Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

    How to Exercise Your Legal Rights.

    • Contact us. If you wish to exercise any of the rights set out above, please contact us at [privacy@playgap.io](mailto:privacy@playgap.io). If you are dissatisfied with our response to your request to exercise your legal rights, you can submit an appeal by contacting [privacy@playgap.io](mailto:privacy@playgap.io).
    • No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
    • What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
    • Time limit to respond. We will respond to all legitimate requests within the time limits set out in applicable data protection legislation.
  6. CHANGES TO PRIVACY NOTICE.

    We keep our privacy notice under regular review. Any changes we make to this privacy notice in the future will be posted to our website. Any such changes will ensure that your rights are fully safeguarded. In any event, we encourage you to check the updated privacy notice published on our website from time to time.

  7. MISCELLANEOUS.

    Aggregated Data. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. "Aggregated Data" could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or services feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

    Third-party Links. The Website and Playgap's Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

    Sale of Data. Playgap does not 'sell' or 'share' any personal data as those terms are defined under the privacy laws of the United States and its states, including the California Privacy Rights Act, Virginia Consumer Data Protection Act, Colorado Privacy Act, Connecticut Data Privacy Act, and Utah Consumer Privacy Act. For more information, please see our U.S. State Law Privacy Notice.

    Cookies. We do not use any tracking cookies on our website. We only utilise necessary cookies to ensure that users remain logged in for a specified duration while navigating the website or when leaving and returning to the site. These necessary cookies are essential for providing a seamless user experience and do not track user activities beyond the scope of session management.