Privacy Policy and Terms of Use



Privacy and Data Policy

Issued by PenPlay

Introduction and General Terms

These terms apply to the use of games and other products developed by PenPlay Group (‘Penplay’ / ‘we’ / ‘us’). Our office is at 4608 - 2200 Lake Shore Boulevard, Toronto, M8A 1A4. This privacy and data policy (‘Privacy Policy’) applies and has effect in respect of the PenPlay game. 

If you have any questions or comments about this Privacy Policy, please contact us at

We are committed to protecting and respecting your privacy.  The Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Online Services is processed. We will comply with all applicable data protection laws, including the Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5), General Data Protection Regulation (GPDR) 2016/679, California Consumer Privacy Act (CCPA) and Australia’s Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth). Please read this Privacy Policy carefully as it contains important information about the following:

  1. What information we may collect about you;

  2. How we will use information we collect about you;

  3. Whether we will disclose your details to anyone else; and

  4. Your choices and rights regarding the personal information you have provided to us.

This Privacy Policy forms a part of and should be read in conjunction with our terms of use. 

We may make changes to this Privacy Policy in future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. 


We collect and process the following information which may include your personal data.  

Information provided by you when using Penplay (“Basic Information”)

We will collect the following information from you when you play Penplay:


Information used for the purposes of serving advertisements (“Advertising Data”)

Through our third party advertising network partners, we may gather information about your devices when you install or play Penplay, depending on the permissions you’ve granted. This may include:


Information collected for the purposes of providing analytics (“Analytics”)

We may collect technical information about your use of the Penplay game through the use of tracking technologies and analytics. Personal data we may collect includes the following:


Information about you collected from third parties (“Third Party LogIn Information”)

When you access our game platform via a third party social media provider such as Facebook, Twitter or Game Center, we may collect and store personal and non-personal information which is available on that third party social media provider, such as your Facebook or Twitter name, your profile picture or its URL, your third party account ID and other public data of your friends (or connections), provided that you have expressly agreed to the use of that third party platform cookies within the game. We will also receive technical data in order to ensure Penplay connects to the correct third party account.


To provide our game platforms to you

We will use information about you (including Basic Information, Third Party Log In Information and Analytics) for delivering our game platforms to you under the terms of use agreed between us. The processing of information in this way is necessary for us to record your progress and current status within our game platforms, and to ensure Penplay delivers the features promised and function properly, so that you have the best experience when playing Penplay.


To help us improve our digital platforms and fix any problems

We may process non identifiable analytics so that we can analyse and improve our digital platforms and solutions. This processing is also necessary for us to pursue our legitimate interests of (i) ensuring that our services function properly so that you and other users have the best experience when playing our game(s); (ii) improving the quality of our services, and providing a better experience to our users; (iii) identifying and correcting any bugs in Penplay and similar products iv) understanding the effectiveness of our marketing to attract new users and re-engage our current users at an aggregated level.


To improve the monetisation via in-app purchases

We may process information (including Basic Information, User Content, Advertising Data and Analytics) to understand how users use our Games, and to compile statistical reports regarding that activity, as well as understanding how users progress, and their current status within a Game. This processing is necessary for us to pursue our legitimate interests of improving the Games and increasing the amount of revenue generated via in-app purchases. This may include segmenting and analysing users according to various relevant factors, such as geography, gameplay progression and playing behaviour so that we can offer personalised and temporary promotional discounts and offers. We will not pass your information to third parties for the purposes of dynamic pricing unless you give your consent should we ask for it. After you have given your consent, you may withdraw it at any time.


For advertising purposes 

We may process Advertising Data to show you advertisements for third party services; including advertising that may reward you with benefits during your use of the Games. The information we collect about you may be used to understand how advertisements placed in our Games have performed or how many people have viewed certain advertisements. We aggregate this information so that it does not personally identify you or permit you to be treated individually. We may also use this information to reward users with benefits that can be used for further enjoyment of the Games from the viewing of certain advertising placed in our Games. We will not pass or process your information for the purposes of marketing by third parties unless you give your consent should we ask for it. After you have given your consent, you may withdraw it at any time. We may use the information we collect about you to serve you targeted advertisements in our Games. We do this to provide you with more relevant advertising content. We work with the following third party advertising network: Google Admob


To prevent fraud and illegal activity

We process personal data for our legitimate interests of ensuring that any use of the Digital Services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, to enforce our legal rights and also in order to comply with our legal obligations. Where we reasonably believe that you are or may be in breach of any applicable laws or our terms of use, we may use your personal information to inform relevant third parties such as your law enforcement agencies about the content. We reserve the right to disclose your identity to any third party who is claiming that any User Content posted by you constitutes a violation of their intellectual property rights, or of their right to privacy. 


To respond to your enquiries and requests for support 

We may process Contact Information so that we are able to properly respond to your enquiries and support requests through



We use automated decision making methods which do not involve human involvement to process your information only in the ways that are described in this Privacy Policy. We process your personal information via automated decision making methods in order to identify users who are suspected of cheating in the Games. Our automated decision making methods are designed to detect cheating by looking out for (i) excessive currency stores against actual completed gameplay; and (ii) excessive content against actual purchases made and completed gameplay. If users are determined to be or suspected of cheating the following actions may be taken and which will be unknown to the user: an increase in the number of advertisements displayed within the Games; and an increase in the frequency of suspected cheats playing against other suspected cheats. We may block users from the Games and/or the Online Services who are determined to be cheating following an automated decision process. In this scenario the user will be notified of the outcome and will have the right to obtain human intervention to express his or her point of view and to contest the decision to block access to the Games and/or the Online Services.


If you do not wish to be part of a lookalike campaign or receive notifications from us you can opt-out by changing your advertising and notification settings on your device directly. You can opt-out from analytics performed by emailing us: You can withdraw your consent to targeted advertising by changing your advertising settings on your device at any time. You can opt-out of any personalised in-game discounts and offers through the options settings provided in our Games.



You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay, and within one month at the latest. To make a request, please let our Data Protection Officer know by sending an email to


Ask for a copy of data we are processing about you and have inaccuracies corrected. You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected. We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).

Object to us processing data about you

You can ask us to restrict, stop processing, or to delete your personal data if:

Obtain a machine readable copy of your personal data, which you can use with another service provider

If we are processing data in order to perform our obligations to you, or because you consented, or if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems. If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

Make a complaint to a Supervisory Authority

If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services. If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.


We will hold your personal information and your game play information on our systems for as long as is necessary for the relevant service, or as otherwise described in this Privacy Policy.


We do not use our services to knowingly solicit information from or market to children under the age of 13. Our terms of use prohibit users aged under 13 years from accessing our Online Services. In the event that we learn that we have collected personal information from a child under 13 years of age we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age please contact us at


We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information.Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.


It is possible that your personal information may be transferred outside Canada by Third parties we are using in our platforms. We recommend that you refer to the privacy policies and/or terms and conditions of these third parties if you are concerned about your data being transferred outside Canada. Where we transfer your information outside of Canada, we will do our best to put agreements in place with those parties which include standard data protection clauses in accordance with data protection laws we comply with. If you would like to find out more about these safeguards, please let us know by writing to


All questions, comments or enquiries should be directed to Penplay at   We will endeavour to respond to any query or questions within three business day.