Terms of Service & Privacy Policy – Groupy Inc
Last updated: 30 April 2025
Groupy Inc(Groupy Inc or "we," "us," "our") is a technology company that designs and develops mobile games. With this Privacy Policy, we aim to explain how and why we gather, store, share, and use your personal data in a manner consistent with the laws of the countries where we do business.
This Privacy Policy applies to websites, mobile applications, our marketing and advertising activities on all platforms, and other services that we may provide to you from time to time (collectively, the "Services").
We are the controller of the personal data we hold about you in connection with your use of the Services. This means that we determine and are responsible for how your personal data is used. Under this Terms of Service & Privacy Policy, your personal data shall be processed in order to provide the Services once you download our mobile applications, access and/or play our games, or interact with our Services.
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### 1. Data We Collect
Personal Data Collected Directly from You
We process your personal data in order to provide the Services by downloading, accessing and/or playing our games or using our other Services. Most of this data comes directly from you. We collect the following information you provide in connection with our Services:
• Information collected via our customer support channels: when you interact with us via our customer support provider, we ask you to provide your username and email, and any information you choose to provide to allow us to assist you like Game ID, team/club name, device brand and model, advertising ID, transaction records or device language.
• Information you provide when using the Games: when you play the Games, we may ask you to choose a username.
• Feedback and ratings you provide relating to our Services.
We use this data to provide our games and Services to you, including optimizing our Services, customization of in-game offers and verifying purchases. We may also use it for the other purposes set out in this Privacy Policy.
Information we collect automatically through the Services
We collect several different types of information for various purposes to provide and improve our Service to you, including:
• Log Information: We log information about your use of the Services, including the type of device you use, the features you use, access times and your location based on your Internet Protocol ("IP").
• Device Information: We collect information about the device you use to access the Services, including information about the device manufacture, device model, device's OS, time zone of device, language of device.
• Device identifiers: We collect online identifiers of the device you use to access the Services, including IDFA, Google Ads ID, Google Play Account ID.
• Usage Information: We collect information relating to your use of the Services, including your game progress, scores, achievements and interactions with other players.
• Consumption information: We collect information about your consumption habits relating to your use of the Services, including which purchases you make with both virtual and real currencies and the reception of virtual goods in-game.
Information we collect from third-parties
If you log into the Services using a third-party site or platform such as Facebook, Apple Game Center and Google Sign-In, we access information about you from that site or platform, such as your screen name, profile information and friend lists, in accordance with the authorization procedures determined by such third-party site or platform provided that you have given the third-party site in question such consent.
You can learn more about how such third-party sites or platforms process your personal data in the relevant privacy policy:
• Facebook: https://www.facebook.com/about/privacy/
• Game Center: https://www.apple.com/legal/internet-services/itunes/gamecenter/
• Google Play Games: https://policies.google.com/privacy
If you log into the Services using a third-party site or platform, you represent and warrant that your access and use of such features in connection with the Services will comply with the applicable terms and policies of such site or platform; and that you are over the minimum age limit that is prescribed for such third-party site or platform by the legislation in the individual jurisdictions.
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### 2. How We Use Your Data
We use information about you for the following purposes in accordance with the legal bases for each type of personal data as described below:
• To provide and maintain the Services and the game experience;
• To enable us to provide our games (Services), to ensure that your purchases are activated in the games, and to provide you with player support if you need it;
• To enable us to optimize our Services for you and for the device that you are using, as well as to deliver customized in-game events, offers and promotions;
• To communicate with you regarding App-related information, including confirmations, technical notices, updates, security alerts and support and administrative messages;
• To personalize and improve the Services and provide tailored content and features;
• To respond to your comments and inquiries and provide customer support services;
• To gather analysis or valuable information so that we can improve our Services;
• To monitor and analyze trends, usage and activities in connection with the Services;
• To detect, prevent and address technical issues and bugs;
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
• To enable players to communicate with each other in games or on our social media accounts;
• To serve advertising;
• To provide and deliver the products and services you request and send you related information.
We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.
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### 3. Sharing and Selling of Data
#### Do We Sell Your Data?
We do not sell your personal data. If this changes in the future, we will notify you and provide you with the opportunity to opt-out of the sale of your data.
#### Do We Share Your Data?
We may share your personal data with trusted service providers, such as those helping us with analytics or advertising. We may also share data for business transactions like mergers or acquisitions. If we share your data with any third parties, we will notify you.
#### Opt-Out Rights for California Residents:
Under the California Consumer Privacy Act (CCPA), you have the right to opt-out of the sale of your personal data. If we decide to sell your personal data in the future, you will have the option to exercise this right. For more information, please contact us.
#### Opt-Out of Data Sharing and Sale:
You can opt-out of the sharing or sale of your personal data by contacting us directly at weichenyu63322@gmail.com. Additionally, you can manage your data-sharing preferences through the settings on your mobile device.
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### 4. User Rights Under the CCPA, VCDPA, and GDPR
- CCPA (California Consumer Privacy Act): California residents have the right to:
- Request to know what personal data we have collected about them.
- Request the deletion of their personal data.
- Opt-out of the sale of their personal data.
- Non-discrimination for exercising their CCPA rights.
- VCDPA (Virginia Consumer Data Protection Act): Virginia residents have the right to:
- Access, correct, delete, and obtain a copy of personal data.
- Opt-out of the processing of personal data for targeted advertising, sales, and profiling.
- GDPR (General Data Protection Regulation): For EU residents, we comply with the GDPR rights:
- Right to access, rectification, deletion, portability, and withdrawal of consent.
- Right to object to processing and to restrict processing.
- Right to lodge a complaint with the relevant supervisory authority.
If you are located in California, Virginia, or the EU, you can exercise your rights by contacting us at weichenyu63322@gmail.com.
### 5. Children
Use of the Services is limited to users aged 13 years and above, except in the European Economic Area, where the Services are limited to users aged 16 years and above. If you are accepting this Privacy Policy and using the Services, you warrant you are 13 (or 16, depending what is applicable) or more years old.
If you have additional questions about our privacy practices related to children under the applicable minimum age, please contact us at weichenyu63322@gmail.com.
### 6. Security
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
### 7. Push notifications
We send push notifications or alerts to your mobile device to provide game-related information, service updates, promotional communications and other related messages, if you have agreed to such notifications. You can deactivate these notifications by changing your notification settings on your device.
### 8. Payments
We may provide paid products and/or services within the Services. In that case, we use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
The payment processors we work with are:
• Apple Store In-App Payments. Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/
• Google Play In-App Payments. Their Privacy Policy can be viewed at https://policies.google.com/privacy
You agree to pay all fees and applicable taxes incurred by you or anyone using an Account registered to you. We may revise the pricing for the goods and services offered through the Service at any time. YOU ACKNOWLEDGE THAT WE ARE NOT REQUIRED TO PROVIDE A REFUND OR ANY REASON THAT YOU WILL NOT RECEIVE MONEY OR OTHER COMPENSATION FOR UNUSED VIRTUAL RESOURCES WHEN AN ACCOUNT IS CLOSED, WHETHER SUCH CLOSURE WAS VOLUNTARY OR INVOLUNTARY.
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### 9.. Data Retention
We will retain your personal data as long as necessary to fulfill the purposes outlined in this policy. Afterward, your data will be securely deleted.
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### 10. Data Controller and DPO
- Data Controller: THB LAB. For inquiries, contact weichenyu63322@gmail.com.
- Data Protection Officer (DPO): Please contact us at weichenyu63322@gmail.com for any privacy-related questions.
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### 11. Changes to This Policy
This Privacy Policy may be updated from time to time. We will notify you of any significant changes by updating the date at the top of this policy. By continuing to use the app, you agree to the revised policy.
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### 12. Contact Us
If you have any questions about this Privacy Policy, wish to exercise your rights, or if you have concerns about the handling of your data, please contact us at weichenyu63322@gmail.com.
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### 13. Compliance with Applicable Laws
We comply with applicable data protection laws, including the General Data Protection Regulation (GDPR) for users in the EU, the Lei Geral de Proteção de Dados (LGPD) for users in Brazil, and the California Consumer Privacy Act (CCPA) for users in California. If you are located in these regions, you have additional rights under these laws.
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This Privacy Policy ensures your data is handled responsibly and in accordance with Google Play’s requirements. If you have further questions or need clarification, feel free to contact us.
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