Privacy Policy

Date: 26 September 2024

A. General

1. This privacy notice is disseminated by HPL LTD. When we refer to "the Company," "we," "us," or "our" in this document, it is to indicate the specific entity within HPL LTD that is handling your data.

2. We are dedicated to safeguarding your privacy, respecting your personal space, and upholding the trust and confidence of our clientele. This privacy notice ("Notice") delineates the procedures for gathering your personal data, the rationale behind it, and the measures we implement to safeguard it. We are steadfast in our adherence to global data privacy regulations, including but not limited to the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the Virginia Consumer Data Protection Act (VCDPA), and the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), as well as any substantially similar provincial laws.

B. Information We Gather

1. Personal data pertains to any information related to you that reveals your identity or can be reasonably used to ascertain your identity. When previously anonymous data is linked with personal data, the resulting set is also classified as Personal data. Anonymous data refers to information that does not identify and cannot be used to identify an individual. Aggregate data refers to collective information about customers that does not pinpoint or identify any specific individual.

2. We gather two primary types of data: Personal and anonymous. We may also generate aggregate data by combining personal and anonymous data.

3. The data we collect includes:

- Contact information such as your name, email, home address, and phone numbers;

- Demographic details like gender and age, as well as images of you; account credentials including usernames and passwords, and profile pictures;

- Communications exchanged in private or small groups via email, mail, or other communication channels;

- Data received from third parties, like platform providers, regarding your engagement with or interest in our services;

- Location data, including information from mobile devices or your IP address, provided it is legally permissible for us to process;

- Engagement, technical, and device data related to your use of our Game, such as the content you access, the duration of your visits, how frequently you use our services, how you discovered our Game, your preferences, interactions with the content, your device model, type, identifiers, operating system, browser, and IP address;

- Sensitive data like biometric information, precise location, identification documents, and financial data for compliance with legal and regulatory needs.

C. Personal Data Collection Through Technology

1. Our aim is to simplify and enhance your interaction with our Game. We and our partners utilize standard identifiers like cookies and similar technologies.

2. Our Game employs technologies to enrich your experience. These are small files that are stored on your devices when you visit our site. They enable us to track certain information every time you interact with the Game. This data may include, but is not limited to, your browser type, operating system, device type, approximate geographic location derived from your IP address, mobile device location, the page you were served, the time, referring URLs, and other standard HTTP request information. This statistical data helps us understand how you use our services, such as which pages you engage with, the type of content you prefer, and how long you spend on a page. While usage data is generally non-identifying, if we link it to you as a specific individual, it will be treated as Personal data.

3. Examples of these technologies include:

- APIs facilitate communication between different software types, simplifying development and enhancing user experience.

- Cookies are small text files that store your preferences in your browser. Most browsers allow you to block or delete cookies, but doing so may impair service functionality.

- Event tagging tracks actions within the Game, such as app installations and purchases, allowing us to analyze performance and target ads.

- Mobile device identifiers may be shared with advertisers to identify your device for online advertising. For instructions on opting out, refer to the NAI’s Mobile Choices page.

- Pixel tags/web beacons are embedded codes that collect engagement data on web pages, recording visits and clicks, which helps us track user behavior and email interactions.

D. Information Collection Methods

1. We gather information through various means, as detailed below. You confirm that any contact details you provide are accurate.

2. Information you provide directly, such as when visiting our Game, registering, responding to surveys, filling out forms, or engaging with other activities, services, features, or resources.

3. We also collect information through phone, video, or written correspondence, including email, live chat, mail, text, or social media. Phone and video calls may be recorded for training and compliance.

4. We collect data on your product and service usage through technologies present on our Websites or third-party platforms, including cookies, flash cookies, pixels, tags, and APIs.

5. See the "Personal Data Collected via Technology" section for more details. Analytics tools are also used to gather data when you visit our Game or use our services on third-party platforms.

6. We may also use trusted sources to update or supplement the information you provided or that we collected, including for verification purposes.

E. Use of Collected Information

1. We use the collected data to operate our Game, provide products and services, answer inquiries, and meet regulatory requirements.

2. Subject to applicable laws and your choices, we may use your data for specific purposes, including:

- Providing and managing services you request, such as registration, account setup, and fraud prevention.

- Enhancing customer service and our offerings, using your feedback to improve.

- Personalizing your experience by understanding how our user base engages with our services.

- Contacting you about our services, including marketing through various channels.

- Complying with legal and regulatory obligations, detecting and preventing illegal activities.

- Offering dispute resolution services and conducting market research and analysis.

3. We do not engage in automated decision-making as defined by global data protection laws.

4. We may collaborate with third-party service providers for advertising display or management, using technologies like cookies to track your activities and provide targeted ads.

F. Rights

1. You have the right to object to direct advertising at any time, including profiling related to such advertising.

2. You can opt-out of commercial messages by following instructions in those messages or contacting support. We will cease processing your data for direct advertising upon your objection.

3. You have several rights regarding your personal data, including access, objection to processing, updating, correction, and withdrawal of consent. In some cases, you can request deletion of your data.

4. We will not discriminate against you for exercising your rights.

5. If you use an authorized agent to exercise your rights, we may request proof of authority.

G. Information Protection

1. We implement physical, electronic, and operational procedures to safeguard collected information. We adopt secure data practices and regularly review our security measures.

2. We protect your data from misuse, interference, loss, unauthorized access, modification, or disclosure.

3. In the event of a data breach, we will comply with legal requirements to notify you and take steps to contain and investigate the breach.

H. Data Retention

1. We retain your data for as long as necessary to fulfill the purposes outlined in this Notice, or as required by law.

2. We will destroy or de-identify Personal Information when it is no longer needed for the purposes it was collected and not required by law.

I. Information Sharing

1. We do not sell, trade, or rent your personal data. However, we may share it with affiliates, service providers, and third parties involved in our services, ensuring they maintain the same protections.

2. We share information with third parties under limited circumstances, such as with your consent, for product and service provision, in response to legal requests, to enforce our terms, and for customer due diligence.

J. Changes

1. This Notice may be updated to reflect changes in our operations or regulations. We will notify you of significant changes and obtain consent where required.

2. Updated policies will be effective upon posting on our Game.

3. We encourage you to check this page regularly for updates on our data protection efforts.

K. Contact Us

For questions about your personal data or our usage, please contact our Data Protection Officer at [email protected].