Planet-X Limited is the data controller and responsible for collection and processing Personal Data in connection with our Services.
Personal Data We Collect
The specific Personal Data we collect depends on the Services you use and how you use them.
Personal Data You Give Us Directly
We collect information directly from you through our Services, including your name, email address, physical address and telephone number.
Other Personal Data We Collect When You Use Our Services
Personal Data we collect automatically when players use our Services include:
- IP address;
- Information about your device, hardware and software, mobile device identifiers, platform type, settings, components, and presence of plugins;
- Approximate geolocation data (inferred from IP address or device settings);
- Browser information, including your browser type and language preference; and
- Other information you may provide (such as your likeness or image).
We may also collect and store information locally on your device, using mechanisms like cookies, browser web storage, and application data caches using Google Analytics.
- Categories of Personal Data Processed
Depending on your use of our Services and other interactions with us (e.g., contacting customer support), the following categories of Personal Data may have been collected, shared, or disclosed in the preceding 12 months:
- Identifiers, such as a real name, user name, account name, email, online identifiers, device identifiers, IP address, or mobile device identifiers;
- Commercial information, such as Services used, payment information, and purchase history;
- Approximate geolocation data, such as location inferred from IP address or other device settings;
- Information concerning your participation in a Hunt, including playing and spending patterns and
Legal Basis for Processing
Our legal basis for processing your Personal Data depends on the type of information we collect about you, the context in which we collect it, and your country of residence (as indicated by you or inferred by us based on your IP address and other information).
We process Personal Data about you where we have your consent, where we have a legitimate interest to do so, where the processing is necessary for the performance of a contract with you, or where we have a legal obligation to process your Personal Data.
How We Collect Personal Data
We use internal and third-party analytics technologies, including Google Analytics, to collect information about how you use our Services, your computer or device, and the health of our Services. Some of these tools include placement of cookies on your computer or device. Your affirmative opt-in consent is required before certain cookies are placed on your computer or device.
The information we collect includes technical and related information about your computer or device and operating and/or network systems (such as IP address and device ID) and information about your engagement with the Services.
How We Use and Disclose Your Personal Data
We use and disclose your Personal Data in the following ways:
- We use and/or disclose identifiers, commercial information, geolocation information, and information about participation in Hunts to operate our business and to enhance and personalize your experience, including to:
- operate, improve, and develop our Services;
- set up and maintain accounts for which you register;
- authenticate and activate your participation in Hunts;
- share information with other participants regarding your participation in a Hunt;
- undertake research and analysis to develop and demonstrate our technology, and to better understand Hunt participants;
- identify, fix, and troubleshoot bugs or functionality errors;
- provide software updates;
- perform audits and detect security incidents;
- help keep our Services fair, resolve disputes, investigate and stop fraud and other illegal behavior, comply with the law, and to enforce our agreements and policies;
- help you find your friends or tell your friends about our Services;
- facilitate sharing on social networks;
- other purposes you consent to, are notified of, or are otherwise disclosed to you when you provide Personal Data.
- We use identifiers, commercial information, and information about participation in Hunts to provide you support, including to:
- help identify and troubleshoot problems with your account or Services;
- facilitate surveys or questionnaires;
- communicate with you and respond to your specific requests or questions;
- communicate with you if you win a Hunt and/or become eligible for prizes; and
- We use identifiers, commercial information, information about participation in Hunts, and geolocation information to personalize our communications with you, including to:
- present offers and/or information relating to games and/or Services you might like; and
- recommend other Services, games or activities in which you may be interested.
We retain Personal Data for as long as necessary to provide our Services, and we may retain that Personal Data beyond that period if necessary for legal, operational, or other legitimate business reasons.
We may also de-identify, anonymize, or aggregate the Personal Data we collect, or collect it in a way that does not directly identify you. We may use and share such Personal Data as necessary for our business purposes and as permitted by applicable law.
Personal Data We Share with Third Parties
Planet-X does not currently sell Personal Data and will not do so without affirmative consent.
Except as described below, we do not share or otherwise disclose Personal Data to third parties:
Service providers. We may employ third parties located in and outside of your country of residence to collect or process Personal Data on our behalf. These purposes include providing IT and related services, sending emails, or delivering and optimizing our Services. We require that any third-party Service Provider (Processor) use the data only on our behalf and for purposes consistent with this policy.
Business partners. From time-to-time, if you consent, we may share your Personal Data with business partners and affiliates for purposes of allowing third parties to offer you other Services that may be of interest to you.
Disclosures to protect us or others. We may access, preserve, and disclose any information we store that is associated with you to external parties if we, in good faith, believe doing so is required or appropriate to:
- comply with law enforcement or national security requests and legal process, such as a court order or subpoena;
- protect your, our or others' rights, property, or safety;
- enforce our policies or contracts;
- assist with an investigation or prosecution of suspected or actual illegal activity.
Disclosure in the event of merger, sale, or other asset transfer. In the event of a reorganization, divestiture, merger, sale, or bankruptcy, we may transfer all information we collect to the relevant third-party.
Third-party plugins. When third-party technologies or social tools are integrated into our Services (“Third-Party Plugins”), the providers of those Third-Party Plugins may collect information about your use of our Services. Information collected by these Third-Parties is governed by their privacy policies.
Where We Hold Your Personal Data
How We Protect Your Personal Data
We take a range of technical and organizational measures to protect your Personal Data. We also make sure that third parties who need to handle your data when helping us to deliver our services are subject to suitable confidentiality and security standards. However, no security measures are 100% perfect, especially with respect to systems connected to the internet. Thus, we cannot guarantee the security of your Personal Data and recommend you use care in deciding what information to share with us.
Links to Third Party Websites
Our Platform may contain links to enable you to visit websites or other online services maintained by third parties. We are not responsible for the data protection and privacy practices of those third parties and encourage you to review the data protection and privacy protections of those websites before you use them or provide information to them.
Personal Data of Children
Our services are not intended for use by any person under the age of 18 (or the age of majority in the user’s country of residence, whichever is older).
If we become aware that a person under the age of majority in that person’s country of residence has provided us with Personal Data, we will delete any Personal Data we have collected, unless we have a legal obligation to keep it.
Your Choices and Controls regarding all users
If you no longer want to receive marketing emails from Planet-X, you may click the unsubscribe link included in the footer of any marketing email we send Please note that you cannot opt-out of Service notifications relating to operation of the game or terms of play while you are an active participant or maintain an active account with us.
Your right to deletion. You may deactivate your Planet-X account by contacting us in the App. If you do so, you will no longer have access to the Services associated with your Account. If a user self-deletes an account data will be preserved for a period of six months. Note that Planet-X may not always be able to comply with your request to delete Personal Data and may retain Personal Data needed to resolve disputes, enforce our user agreements, protect our legal rights, and comply with technical and legal requirements and constraints related to the security, integrity and operation of our Services. Otherwise, we will retain your Personal Data for as long as reasonably necessary to provide you with, create, and improve our Services, and to comply with law.
Your right to access. You can request access the Personal Data we hold about you by contacting us at the addresses in Section 11, below.
Your right to correction. You can request correction of your Personal Data where it is inaccurate by contacting us at the addresses in Section 11, below.
Your right to restriction of processing. You can request that we restrict processing of your Personal Data in certain circumstances or object to our processing of your Personal Data where we are relying on a legitimate interest by contacting us at the addresses in Section 11, below.
Your right to withdraw consent to processing. You may withdraw your 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Planet-X does not currently sell Personal Data and will not sell your Personal Data, in the future, without your consent. However, you still have the right to opt out or object to certain processing, including disclosing or sharing your Personal Data to third parties where such disclosures are permitted by law. Please contact us at the addresses set forth in Section 11 to exercise your rights.
You have a right not to receive discriminatory treatment for the exercise of these privacy rights.
To protect your account security and Personal Data, you may be asked to verify your account ownership in connection with exercising the rights above. Once you have verified your account ownership, you may also be required to provide your confirmation authorizing an agent to exercise these rights on your behalf. If you have additional questions about exercising your privacy rights, you may contact us at the addresses in Section 11, below.
You may also exercise the rights above through an authorized agent, who may contact us at the addresses in Section 11, below. If you use an authorized agent, the agent must provide verifiable proof of authority to act on your behalf.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You will not normally have to pay a fee to access your personal data or to exercise any of your 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.
About us and contact Us
E-mail via the website
If you are in the EU/EEA, you may also contact us through our Article 27 Representative
Right to Contact Data Protection Authority
If you have a concern about how we collect and use Personal Data, please contact us. You also have the right to contact your local Data Protection Authority if you prefer.
To contact the UK Information Commissioner’s Office (“ICO”) please visit this website at https://ico.org.uk/global/contact-us/.
Contact details for Data Protection Authorities in the EEA are available at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
To contact the Swiss authorities please visit this website at https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.
Last Updated: 18 October 2022