# PRIVACY POLICY

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#### Introduction

This Privacy Policy (“Policy”) applies to playnance.com, including its GitBook documentation and any related pages or interfaces that provide information about Playnance technology, the G Coin ecosystem, and, where applicable, the ability to acquire G Coin (collectively, the “Website”).

This Policy explains how Playnance OÜ (“Playnance”, “we”, “our”, or “us”) collects, uses, processes, and protects Personal Data when you access or use the Website.

This Policy does not apply to gameplay, user accounts, or in-platform activities conducted on independent gaming portals within the Playnance ecosystem. Such activities are governed by the privacy policies of the respective portals.

We are committed to protecting your privacy and processing Personal Data in accordance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR) and, where applicable, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).

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#### 1. Scope of This Policy

This Policy describes:

* The categories of Personal Data we collect through the Website;
* How and why we process such Personal Data;
* The legal bases for processing under applicable laws;
* How Personal Data may be shared with third parties;
* The security measures we implement to protect Personal Data;
* Your rights in relation to your Personal Data and how to exercise them.

“Personal Data” means any information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, to an identifiable natural person.

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#### 2. Data Controller

The Website and related services are operated by:

Playnance OÜ\
Registered in the Republic of Estonia\
Registration number: 16692081\
Address: Harju maakond, Kristiine linnaosa, Seebi tn 1-1501, 11316 Tallinn, Estonia\
Email: <legal@playnance.com>

Playnance OÜ acts as the data controller for Personal Data processed under this Policy.

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#### 3. Collection of Personal Data

We collect Personal Data in the following contexts:

* When you browse or interact with the Website or GitBook documentation;
* When you contact us via official communication channels (e.g., email or support forms);
* When you choose to acquire G Coin through the Website (if available);
* When we automatically collect technical and usage data through cookies or similar technologies.

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#### 4. No Obligation to Provide Personal Data

Providing Personal Data is not mandatory to browse the Website or access documentation. However, certain features (such as contacting us or acquiring G Coin) may require the provision of limited Personal Data.

Where processing is based on consent (e.g., non-essential cookies), you may refuse or withdraw consent at any time without affecting your ability to access core informational content of the Website.

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#### 5. Types of Personal Data We Collect

We collect and process the following categories of Personal Data:

**5.1 Website & Technical Data**

* IP address
* Device type, operating system, and browser
* Language and general location (derived from IP)
* Pages visited and interaction timestamps

**5.2 Contact & Communication Data**

* Name and email address (if provided)
* Content of communications and inquiries

**5.3 G Coin Acquisition & Transaction Data (if applicable)**

* Crypto wallet address
* Transaction hash and timestamp
* Purchase amount and confirmation status

Playnance does not collect or store private keys or wallet credentials.

Where the Website provides an option to acquire G Coin, such transactions are processed by independent third-party payment service providers (“PSPs”). Playnance does not process payments, does not store payment credentials, and does not control the verification or approval of transactions.

In connection with such transactions, Playnance may receive limited transactional information (such as confirmation status, transaction reference identifiers, or compliance flags) solely for record-keeping, compliance, and operational purposes.

Any personal data processed by PSPs in connection with payment or identity verification is governed by the privacy policies of the respective PSPs.

**5.4 Payment & Compliance Data**

Where required for transactions or compliance purposes, we may receive limited information from payment service providers or compliance partners, such as:

* Payment status or reference identifiers
* Verification or risk flags

**5.5 Business & Partnership Data (KYB)**

In the context of partnerships, licensing, or commercial relationships, we may process Personal Data relating to individuals acting on behalf of legal entities, including:

* Name, role, and contact details
* Identification and verification data required for due diligence or compliance

**5.6 Identity Verification (KYC) Data (Where Applicable)**

In certain circumstances, including where required by applicable law, regulatory obligations, or the policies of third-party payment service providers, users may be required to complete identity verification procedures (commonly referred to as “Know Your Customer” or “KYC”).

Such verification is conducted by independent third-party service providers. Playnance does not collect or store copies of identity documents and does not control the verification process or decision-making outcomes.

Where applicable, Playnance may receive limited information confirming the completion or status of verification (e.g., pass/fail or risk flags) solely for compliance and record-keeping purposes.

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#### 6. Purposes of Processing Personal Data

We process Personal Data for the following purposes:

* To operate, maintain, and secure the Website and GitBook;
* To provide information about Playnance technology and the G Coin ecosystem;
* To facilitate the acquisition and delivery of G Coin (where applicable);
* To communicate with users and respond to inquiries;
* To comply with legal, regulatory, and compliance obligations (including AML/KYC where required);
* To prevent fraud, abuse, and security incidents;
* To improve Website performance, content, and user experience.

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#### 7. Legal Bases for Processing

Depending on the context, we rely on one or more of the following legal bases under GDPR:

* Performance of a contract (Art. 6(1)(b));
* Compliance with a legal obligation (Art. 6(1)(c));
* Legitimate interests (Art. 6(1)(f));
* Consent (Art. 6(1)(a)), where required.

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#### 8. Data Sharing & Third-Party Services

We do not sell Personal Data.

We may share Personal Data with trusted third parties solely for the purposes described in this Policy, including:

* Hosting and cloud infrastructure providers;
* Analytics and performance service providers;
* Payment service providers;
* KYC / AML and compliance service providers;
* Professional advisers or authorities where required by law.

All third parties are required to implement appropriate data protection and security measures.

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#### 9. Cookies and Similar Technologies

We use cookies and similar technologies to operate the Website, analyze usage, and improve functionality.

Where required by law, we obtain consent before placing non-essential cookies.\
For more information, please refer to our Cookie Policy.

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#### 10. Data Retention

We retain Personal Data only for as long as necessary to fulfill the purposes described in this Policy or to comply with legal obligations.

Retention periods may vary depending on the type of data and applicable legal requirements. When data is no longer required, it is securely deleted or anonymized.

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#### 11. International Data Transfers

Playnance operates globally, and Personal Data may be transferred to and processed in countries outside your country of residence.

Where Personal Data is transferred outside the EEA or other protected jurisdictions, we ensure appropriate safeguards, such as Standard Contractual Clauses or adequacy decisions, in accordance with applicable law.

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#### 12. Data Security

We implement appropriate technical and organizational measures to protect Personal Data against unauthorized access, loss, misuse, or disclosure, including encryption, access controls, and monitoring.

However, no system can be guaranteed to be completely secure, and users should take appropriate measures to protect their own information.

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#### 13. Your Rights

Subject to applicable law, you may have the right to:

* Access your Personal Data;
* Rectify inaccurate or incomplete data;
* Request erasure of Personal Data;
* Restrict or object to processing;
* Request data portability;
* Withdraw consent where processing is based on consent;
* Lodge a complaint with a supervisory authority.

Requests may be submitted to <legal@playnance.com>.

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#### 14. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on the Website with an updated “Last Updated” date.

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#### 15. Contact Information

For questions or requests relating to this Privacy Policy or our data practices, please contact: <legal@playnance.com>.
