Privacy Policy

Effective Date: 09.09.2026

VeroPlay Limited ("we," "us," or "our") values your privacy. This Privacy Policy explains how we collect, use, share, retain, and protect personal information in connection with the VeroPlay website, accounts, and related services provided by us that link to this Privacy Policy (the "Services"), and the rights and choices available to you. Personal information means information that identifies you, relates to you, or can be linked to you, as defined under applicable law.

We are responsible for the processing described in this Privacy Policy, except where another responsible entity is identified for a particular Service or processing activity. Our contact details are in Section 12.

This Privacy Policy describes the personal information we process, its purposes and legal bases, recipients, international transfers, and retention. Where additional information is needed for a particular Service or feature, we provide it at the relevant point of collection or before processing begins, as required by applicable law.

1. Personal Information We Collect

The information we collect depends on the Services and features you use, your settings, and how you interact with us. The categories below describe information that may be processed where relevant to your use of the Services and necessary for the purposes explained in this Privacy Policy. Not all categories apply to every Service or user. Any additional information specific to a feature is explained when we collect it.

Information You Provide Directly

When you create an account, purchase a product, contact us, or use a feature that allows you to submit information, you may provide:

Account and profile information: account identifiers, name or nickname, password where applicable, date of birth, country or region, and profile information.

Contact and verification information: email address, telephone number, and information needed to verify identity, age, or the authority of a parent or legal guardian, including relevant verification results and consent records.

Purchase and transaction information: purchase history, payment method type, order and refund information, and transaction identifiers. The payment information we receive depends on the payment method and payment provider used.

Inquiries, reports, and user content: inquiry or report details, attachments, posts, messages, voice or other content you choose to submit through the relevant features.

Where information is required by law or needed to enter into a contract or provide a particular Service or feature, we explain the requirement and the consequences of not providing it at collection. Providing optional information is voluntary.

Information Generated or Collected When You Use the Services

Depending on the Service, the following information may be generated or collected automatically:

Service activity information: usage records, feature and content activity, user relationship or group information, and service settings.

Device, network, and connection information: IP address, device identifiers, advertising identifiers where used, operating system, browser, language, access dates and times, access logs, and information collected through cookies or similar technologies.

Error, diagnostic, and security information: crash and performance data, error and diagnostic records, suspected misuse indicators, and security and enforcement records.

Section 6 explains cookies and similar technologies and the choices available to you.

Information from External Businesses or Other Sources

Where relevant to the Services, we may receive:

External platform information: platform identifiers, profile information, account-linking status, and service or purchase information made available through platform features and settings and in accordance with applicable law.

Transaction and service operation information: transaction confirmations from payment providers and information from affiliates or providers involved in operating the Services or providing customer support.

Analytics, advertising, and security information: measurement and analytics information from relevant partners and information about suspected fraud or misuse from security providers.

Information from public sources: information you have made public or information from other publicly available sources that we may lawfully use for the purposes described in this Privacy Policy.

Where required by applicable law, we provide information about the sources, categories, purposes, and other relevant details of indirectly collected personal information within the required period. Relevant details are included in this Privacy Policy or the notice provided at collection, or provided directly to you.

Information Requiring Special Protection

Some information is subject to additional protections under applicable law, such as sensitive information, certain biometric information, precise location information, or children's personal information. Where we process such information, we establish the required legal basis, meet any additional legal conditions, obtain separate or explicit consent where required, and apply the required safeguards. Relevant details are provided in the applicable notice. Section 8 describes our general approach to children's personal information.

Details Relevant to VeroPlay Services

When you use an external account to sign in or link accounts, we may receive account identifiers, profile information, and contact information made available through the relevant platform and your settings. For promotional subscriptions, we process the contact information you provide. Refunds, events, or prize delivery may require payment, contact, or delivery information. We explain any additional information needed for a particular inquiry, verification, or legal requirement when it is requested.

Service records may include character information, progress, purchases, chats, and reports where the relevant features are available. Device information may include model, operating system, language, country, network information, IP address, and advertising identifiers. The actual identifiers used depend on the Service and device permissions.

For business inquiries submitted through our website, we process your name, email address, company or role where provided, and message to respond and discuss the proposed business relationship.

We process personal information for the purposes below where the relevant activity applies to the Services you use. We use only the information reasonably necessary for each purpose.

Where applicable law requires a legal basis for processing, we identify the basis that applies to the relevant activity in this Privacy Policy or the notice provided at collection. Depending on the activity and applicable law, this may be your consent, the necessity of entering into or performing a contract with you, compliance with a legal obligation, or a legitimate interest recognized by applicable law.

Account Creation and Authentication

We use account, profile, and verification information to register users, enable sign-in and account linking, verify identity or age where needed, and manage parental or guardian consent where required.

Providing Services and Features

We use relevant account information, service activity information, and content to provide the Services and the features you request, maintain your settings, store content, and support communication or community features where available.

Purchases, Payments, and Refunds

We use transaction information and relevant account information to process orders, confirm payments, issue refunds, maintain required transaction records, and address payment issues. Information used to prevent payment fraud is also processed for the security purposes described below.

Inquiries, Reports, and Customer Support

We use contact and account information, inquiry or report details, service records, and relevant supporting materials to respond to requests, investigate reports, provide assistance, and resolve disputes.

Service Operation, Analytics, and Improvement

We use service activity, device, network, and diagnostic information to maintain performance, identify and resolve errors, understand how features are used, and improve or develop Services and features. Where analytics involve optional technologies or processing requiring consent, we obtain that consent before the relevant processing. Details of applicable analytics practices and choices are available in the relevant notice and Section 6.

Security and Prevention of Misuse

We use relevant account, activity, connection, device, and security information to protect accounts and systems, detect and investigate fraud or other misuse, prevent unauthorized access, and protect users and the Services.

Enforcing Terms and Operational Policies

We use relevant account, activity, report, and enforcement information to investigate suspected violations, take proportionate action where appropriate, and handle appeals or disputes. The relevant notice describes the scope of this processing and its applicable legal basis.

We use account identifiers and contact information to communicate information needed for the Services, such as operational updates, security alerts, transaction messages, and notices of changes to terms or policies. Choices about promotional messages do not prevent us from sending necessary service-related communications.

Marketing and Advertising

Where applicable, we use contact information to send promotional communications; relevant activity, device, or advertising information to measure advertising performance; and, where offered, information about interests or activity to personalize advertising. The relevant notice explains which activities apply, the information involved, the applicable legal basis, and how to exercise your choices. We obtain consent before processing where required by law and respect applicable opt-out rights. Marketing messages, advertising measurement, and personalized advertising may have different controls, as explained in Sections 6 and 7 and the relevant notice.

Events and Business Inquiries

We use application and contact information to administer events, notify selected participants, and deliver prizes; payment or tax information is used where necessary for applicable tax obligations. We use business-contact information and correspondence to answer partnership inquiries and manage business communications.

We use relevant personal information to meet legal and regulatory obligations, respond to lawful requests from authorized public bodies, establish, exercise, or defend legal claims, and protect the lawful rights and safety of us, our users, and others.

Where we rely on legitimate interests, we assess the necessity of the processing and whether users' interests, rights, or freedoms override those interests. The interests pursued are identified in the relevant notice, and users may exercise applicable rights to object.

Before using personal information for a new purpose, we provide information about that purpose and other relevant details where required by applicable law. We also assess whether the new processing is lawful and obtain any required consent or satisfy other applicable conditions before proceeding.

3. How We Share Personal Information

We disclose personal information where necessary for the purposes described in this Privacy Policy and permitted by applicable law. The information shared and the recipient's role depend on the relevant Service and processing activity.

Businesses Supporting the Services

We use businesses that provide cloud, hosting and network services; payment and refund services; customer support and communications; analytics and advertising; and security, verification, and technical support. We share the information needed for the relevant activity, subject to applicable choices and legal requirements.

Where a business processes personal information on our behalf, we require appropriate contractual protections and processing in accordance with our instructions, subject to applicable legal requirements. Some businesses, including certain payment, advertising, or platform providers, may act independently for particular activities. We identify the relevant role and provide additional details where required in the applicable notice or recipient information.

Affiliates

We may share information with affiliates involved in providing the Services, customer support, security, or technical support. The relevant information identifies applicable purposes and, where required, the affiliate's role. Where an affiliate acts on our behalf, the protections for service providers apply. Where it acts independently or jointly determines processing with us, we provide the information required about that relationship and the respective responsibilities.

External Platforms and Independent Third Parties

When you use an external login, account-linking, payment, or sharing feature, information needed for that feature may be exchanged with the relevant business. Its privacy policy explains processing for which it is independently responsible. Our processing of information received from or shared with it remains subject to this Privacy Policy and any applicable supplemental notice.

Information You Make Available to Others

Where the Services offer profiles, posts, messages, or other sharing features, information you submit may be visible to other users, your selected recipients, or the public, depending on the feature and your settings. Others may copy or reshare information they can access. Our ability to control those copies may be limited, without affecting our obligations under applicable law.

Professional Advisers, Corporate Transactions, and Public Authorities

We may disclose relevant information to legal, accounting, and other professional advisers and to parties involved in the assessment or completion of a merger, acquisition, transfer of business, or similar transaction, subject to appropriate confidentiality and other safeguards. We provide notice and obtain consent where required by applicable law.

We may also disclose information to authorized public bodies or other appropriate recipients where legally required or otherwise lawfully necessary to respond to valid legal requests or protect lawful rights and safety.

Information about specific recipients or recipient categories, their purposes and roles, and other required details is provided in this section or before the relevant processing where required by law. Where we jointly determine processing with another entity, we make information about the relevant allocation of responsibilities available as required by law.

4. International Transfers of Personal Information

In providing the Services or using businesses that support them, we may store, remotely access, or otherwise process personal information in a country other than your country of residence. The laws of that country may differ from those in your country.

Transfers may involve affiliates or providers supporting service delivery, storage, communications, payments, customer support, verification, analytics, advertising, security, or technical support, where those activities apply. Information about the applicable processing countries, recipients, purposes, and transfer arrangements is available in this section or before the relevant processing where required by law.

Where a transfer is subject to legal restrictions, we use a transfer basis and safeguards recognized by the applicable law. Depending on the transfer, these may include an applicable adequacy decision, approved standard contractual clauses, approved binding corporate rules, or another legally recognized mechanism whose conditions are met.

The relevant notice identifies the mechanism used where required. You may contact us under Section 12 for further information or a copy of applicable safeguards. We may redact information protected by law or legitimate confidentiality interests, without withholding information you are legally entitled to receive. We provide additional notice, obtain consent, and take supplementary protective measures where required by applicable law.

5. Retention and Deletion of Personal Information

We retain personal information only for as long as necessary for the relevant purpose and as permitted or required by applicable law. In determining retention periods, we consider the duration of the service relationship, the nature and purpose of the information, legal retention obligations, applicable claim periods, and proportionate needs to address disputes, security, and misuse.

The criteria above govern retention. Where a specific period or more detailed criteria must be provided, we state them in this Privacy Policy or at collection.

When information is no longer needed or its retention period expires, we securely delete it or, where permitted by applicable law, anonymize it so that individuals can no longer be identified by means reasonably likely to be used. Where law requires deletion, we comply with that requirement. Information retained for a legal obligation or a lawful claim-related purpose is restricted to that purpose and protected against unrelated use.

Where immediate deletion from backups is not technically feasible and delayed deletion is permitted by law, we protect the information from ordinary use and delete it within the applicable backup retention cycle. If a backup is restored, we take measures to reapply relevant deletion requirements before returning the affected information to ordinary use. More specific deletion procedures or time limits are described where required by applicable law.

Pseudonymized information remains subject to applicable personal information protections where it can still be linked to an individual. We do not treat pseudonymization alone as anonymization or deletion.

6. Cookies and Similar Technologies

Where relevant to the Services, we use cookies, pixels, software development kits (SDKs), local storage, and similar technologies for the purposes described below.

Strictly necessary technologies: enable functions such as authentication, security, and transmission of communications that are necessary for the relevant Service or feature.

Functional technologies: remember preferences such as language, display, or other settings.

Analytics technologies: help understand usage, diagnose errors, and measure performance.

Advertising technologies: support advertising delivery, frequency controls, measurement, or personalization where used.

This section describes the technologies, providers, purposes, and choices relevant to our Services. Where more detailed information, including technology duration, is required, we provide it in the relevant technology settings or consent interface before use.

Where consent is required, we obtain it before using the relevant technologies. You can change or withdraw your choices through account settings. Browser and device settings may provide additional controls, although they may not control all technologies or processing. Blocking technologies needed for a feature may prevent it from working.

We honor legally recognized opt-out signals where required by applicable law. Additional information about applicable signals and other advertising choices is provided in the relevant settings or consent interface.

Where advertising or analytics features are used, we and the relevant providers may process service activity and advertising identifiers to deliver and measure advertising, understand referral sources, and support advertising mediation and optimization. The processing depends on the features used, your settings, and applicable legal requirements. Identifiers and activity records may constitute personal information even without your real name. Limiting personalized advertising does not necessarily stop other advertising.

7. Your Rights and Choices

Depending on applicable law and the circumstances, you may have rights to:

  • Confirm whether we process your personal information, receive information about that processing, and access your information.
  • Correct inaccurate or incomplete information, request deletion, restrict processing, or object to processing.
  • Receive eligible information in a structured, commonly used, machine-readable format and, where applicable, have it transmitted to another controller or business.
  • Withdraw consent at any time where processing is based on consent. Withdrawal does not affect the lawfulness of processing based on consent before withdrawal.
  • Opt out of promotional communications, the sale or sharing of personal information, or targeted advertising, as applicable.
  • Exercise rights relating to certain automated decisions, including requesting information, human intervention, or review where applicable.
  • Appeal a refusal of a request or complain to a competent supervisory authority.

The scope of these rights, applicable conditions and exceptions, and response periods depend on applicable law and the circumstances of processing. We explain the procedure relevant to your request when you contact us. Where we engage in automated decision-making that requires specific notice, we explain the processing, its significance and expected effects, and the information about its logic required by law before the relevant processing.

You can submit a request through the customer support channel in the relevant Service or contact us using Section 12. We request only information reasonably necessary to verify a request and protect personal information, using measures proportionate to the request and its risks. We do not require identity verification for requests where applicable law prohibits such verification.

Where applicable law permits an authorized agent to act for you, we may request appropriate evidence of authority and any identity verification permitted by law. If required verification cannot reasonably be completed, we may decline the request to the extent permitted by law.

We respond within the legally required period and explain any permitted extension. If we deny a request wholly or partly, we provide the reason and information about available appeal or complaint procedures as required by law. We do not unlawfully discriminate against you for exercising your rights.

You can stop promotional messages through the unsubscribe or other opt-out instructions in the message, through relevant account settings, or by contacting us. Cookie and advertising choices are described in Section 6 and the relevant notices. Withdrawing consent or withholding information needed for a particular feature may affect our ability to provide that feature; we explain the relevant consequences where required.

8. Children's Personal Information

Age requirements and safeguards may vary by Service and country or region. We provide information about applicable age requirements in the relevant Service. Where appropriate or required by law, we request information or use verification measures to determine a user's age and whether parental or guardian involvement is required.

Where applicable law requires consent or authorization from a parent or legal guardian, we obtain it before collecting, using, or disclosing the child's personal information for the relevant activity, subject to any limited exceptions permitted by law. We take reasonable measures to verify that the person providing consent or authorization is the child's parent or legal guardian, as required by applicable law.

We apply age-appropriate safeguards where required and may provide additional settings or restrictions depending on the Service. Information about relevant verification and consent processes, the personal information involved, and applicable safeguards is provided in this Privacy Policy or the notice provided at collection. We limit the information used for verification and consent management to what is necessary for those purposes and other purposes permitted by applicable law.

If we become aware that we have collected or processed a child's personal information without legally required consent or authorization, we stop the processing that requires it and take steps to delete the affected information promptly, except to the extent applicable law permits or requires another course of action.

Parents and legal guardians may contact us using Section 12 to exercise applicable rights regarding their child's information, including access, deletion, withdrawal of consent, or refusal of further collection or use. We verify authority as appropriate and explain any effect on the child's ability to use the relevant Services or features. We explain applicable requirements and procedures when handling such requests.

9. How We Protect Personal Information

We apply appropriate administrative, technical, and physical safeguards, taking account of the information involved, the nature and purposes of processing, and the risks to individuals. Depending on the circumstances, these include access restrictions and reviews, authentication, encryption and other transmission and storage protections, monitoring and security assessments, incident response, staff training, provider security requirements, and physical safeguards.

No transmission or storage method can guarantee absolute security. Where your account uses a password, use a secure password and avoid sharing it. Please contact us promptly if you suspect unauthorized access or other suspicious activity affecting your account.

The Services may link to or integrate with external platforms, websites, or services. An external business's privacy policy describes processing for which it is independently responsible. We encourage you to review that policy before using the external service.

An external business's policy does not replace this Privacy Policy for processing for which we are responsible. Information about businesses acting on our behalf or jointly with us is provided as described in Section 3.

11. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in law, the Services, or our processing practices. We publish the updated version and effective date through the Services or our official website.

For material changes affecting your privacy, we provide additional notice before the changes take effect as required by applicable law. These may include changes to the responsible entity, processing purposes, sensitive information practices, or sharing, international transfers, advertising, or profiling that materially affect users' rights. We obtain consent before implementing a change where required by law.

12. Contact Us

If you have questions, requests, or complaints about this Privacy Policy or our processing of personal information, please contact us:

Responsible company: VeroPlay Limited

Contact address: Metochiou 37, Agios Andreas, 1101 Nicosia, Cyprus

Email: support@veroplay.com