Welcome to ELEMENT PLAY COMERCIO LTDA ("we," "us," or "our"). This Privacy Policy describes how we collect, use, store, and protect your personal data when you use our casual gaming products and services. By accessing our platform, you agree to the terms outlined herein. Your trust is important to us, and we are committed to safeguarding your information through transparency and best practices.
To deliver secure, responsive, and personalized gaming services, we collect a wide range of data
from our users. The data we gather helps us tailor content, improve functionality, ensure system
integrity, and comply with legal obligations. This section outlines the different categories of
information we collect, how they are obtained, and why they are essential to your experience.
(I) Personal Identifiable Information (PII) We collect personally identifiable
information when you create an account, make purchases, subscribe to newsletters, or contact
customer support.
Types of data collected include:
1.Full name
2.Email address
3.Date of birth
4.Gender
5.Country and region
6.Contact number (if voluntarily provided)
7.Billing and payment details (e.g., credit card info, digital wallet ID)
8.Login credentials (username and password)
Third-Party Sign-In: When logging in through social media platforms like Facebook,
Google, or Apple ID, we may receive additional public data such as your display name, profile
image, friend list, and region settings, subject to your authorization.
(II) Gameplay and Behavioral Data To better understand how you interact with our
services, we collect data directly related to your gaming behavior.
This includes:
1.Game titles accessed
2.Session duration and frequency
3.Levels completed, scores achieved, and in-game progress
4.In-app purchases, rewards, and item usage
5.Player communication (e.g., chat logs, team coordination)
6.Event participation and referral activity
These data points help us improve game mechanics, balance features, and deliver content
aligned with user preferences.
(III) Technical and Device Data When you access our games and services, we automatically
collect technical data about your device and network environment.
This includes:
1.IP address
2.Device type and model
3.Operating system name and version
4.Unique device identifiers (e.g., IMEI, MAC address)
5.Language settings and time zone
6.Internet service provider (ISP)
7.Crash reports and diagnostic logs
This information is used for troubleshooting, device compatibility checks, and to ensure
platform performance across a range of hardware and software configurations.
(IV) Location Information Depending on your device settings and permissions, we may
collect and process location information such as country, region, or GPS-based data. This allows
us to:
1.Comply with regional regulations (e.g., age restrictions or content localization)
2.Provide region-specific content or promotions
3.Detect fraudulent or anomalous behavior patterns
(V) Cookies and Similar Technologies We use cookies, web beacons, and similar tools to
collect behavioral data, enhance user sessions, remember login states, and deliver targeted
advertising. These technologies help us measure usage patterns and improve the overall user
experience.
Users can manage or disable cookies through browser settings. However, this may limit
the functionality of certain features.
(VI) Data from Third Parties We may receive additional data from:
1.Analytics service providers (e.g., user interaction metrics)
2.Advertising platforms (e.g., ad click and conversion data)
3.Payment processors (e.g., transaction status and verification results)
4.Community platforms or forums hosted by us or affiliated partners
This data helps enrich our understanding of user preferences and provides insights to
refine our services.
(VII) Purpose of Collection All data collected serves one or more of the following
purposes:
1.To verify user identity and secure accounts
2.To personalize the user interface and gameplay recommendations
3.To monitor system performance and usage trends
4.To identify and respond to technical issues quickly
5.To enhance marketing efforts and promotional relevance
6.To fulfill legal, tax, and fraud-prevention responsibilities
We maintain a policy of minimal and purposeful data collection. Only the data necessary
to deliver services and maintain platform security is gathered. All processing is done in
accordance with applicable privacy laws and user consent preferences.
At ELEMENT PLAY COMERCIO LTDA, we use the data we collect to ensure
you receive a high-quality, personalized, and secure gaming experience. This section outlines
the specific purposes for which your data is used, the legal basis that allows such use, and the
detailed practices surrounding how your data is stored, protected, and retained.
(I) Purposes of Data Use We process your personal data for a wide range of operational,
functional, and analytical purposes, including but not limited to:
1.Creating and managing user accounts, including secure authentication and account
recovery
2.Enabling purchases, in-game payments, and transaction processing
3.Enhancing game functionality and optimizing in-game features based on player activity
4.Analyzing behavior to develop new features or games tailored to user interests
5.Delivering personalized content and targeted advertisements
6.Providing timely notifications, including updates, promotions, and gameplay tips
7.Ensuring compliance with legal obligations and regulatory requirements
8.Detecting, investigating, and preventing fraud, security breaches, or misuse of
services
(II) Legal Basis for Processing We process your data based on one or more of the
following legal grounds, depending on the context and your jurisdiction:
1.Consent: When you agree to data collection for optional features such as marketing
personalization or third-party data sharing.
2.Contractual Necessity: When data processing is required to fulfill our service
agreement with you (e.g., delivering gameplay or support).
3.Legitimate Interest: When we use data to improve service delivery, prevent fraud, or
analyze user behavior, provided these actions do not override your privacy rights.
4.Legal Obligation: When necessary to comply with applicable laws, such as data
retention rules or tax documentation.
(III) Data Storage and Infrastructure Your data is stored in secure server environments
provided by internationally certified data centers. These environments are designed with
redundancy, disaster recovery capabilities, and physical protections, including 24/7 monitoring,
biometric access controls, and restricted entry zones.
Our digital protection measures include:
1.AES-256 or higher encryption for data-at-rest
2.TLS/SSL encryption for all data in transit
3.Firewall systems and intrusion detection mechanisms
4.Role-based access management for internal data access
Additionally, regular system audits, access logging, and third-party security
assessments are conducted to ensure compliance and detect vulnerabilities.
(IV) Backup and Disaster Recovery We perform routine, automated backups of your personal
data to prevent accidental loss. These backups are stored in geographically distributed
locations and are encrypted to maintain security and confidentiality. Our disaster recovery plan
includes system redundancy, off-site replication, and recovery simulations to ensure minimal
disruption in the event of failure.
(V) Retention and Archival We retain personal data only as long as necessary to achieve
the specific purposes outlined in this policy, unless a longer retention period is mandated by
law or required for regulatory compliance.
Typical retention periods include:
1.Active use: As long as your account remains active and you engage with our services
2.Inactive accounts: Up to 5 years following your last activity
3.Financial records: Retained for the period required under accounting or taxation laws
Once the retention period has expired, data is either anonymized for research and
analytical purposes or permanently deleted using secure erasure tools.
(VI) Data Deletion and User Requests You may request deletion of your personal data at
any time by contacting our data protection team at [email protected]. Following identity
verification, we will:
1.Remove your data from active systems
2.Delete any associated backups within a reasonable timeframe
3.Confirm completion of the process unless restricted by legal exceptions
Note: Deletion may result in the loss of your game progress, purchases, and account
settings.
(VII) Data Access and Logging All access to user data is recorded and monitored for
compliance, troubleshooting, and accountability. Only authorized employees with specific job
responsibilities are granted access to sensitive data, and such access is regularly reviewed.
By implementing comprehensive administrative, technical, and physical safeguards, we
ensure your data is protected throughout its lifecycle—from collection to deletion.
At ELEMENT PLAY COMERCIO LTDA, we recognize the importance of
individual rights in relation to personal data. We are committed to ensuring transparency,
control, and accessibility so that you can manage your information effectively. This section
outlines your legal rights, how you can exercise them, and the processes we have in place to
support your choices.
(I) Right to Access
You have the right to request access to the personal data we hold about you. This
includes information about how your data is used, the categories of data collected, and with
whom it has been shared.
How to Exercise: Submit a request via our support email ([email protected]) with
sufficient identification. Once verified, we will respond within the legally required timeframe,
typically within 30 days.
(II) Right to Rectification
If any of the personal data we hold is inaccurate or incomplete, you have the right to
request correction. This ensures we maintain accurate records and you receive services that
reflect your true preferences.
How to Exercise: You may directly update certain details through your account settings,
or contact our support team to correct more sensitive data (e.g., birthdate, email address).
(III) Right to Erasure ("Right to Be Forgotten")
You may request that we delete your personal data when it is no longer needed, when you
withdraw your consent, or when processing is unlawful.
Scope: Deletion includes removal from all active systems and backups, provided no legal
or contractual obligations prevent such deletion.
(IV) Right to Restrict Processing
You may request temporary or permanent restrictions on data processing under certain
conditions—for example, when data accuracy is contested or processing is unlawful but deletion
is not preferred.
Effect: Restricted data will only be stored and not used for processing without your
explicit consent, except for legal purposes.
(V) Right to Data Portability
You are entitled to receive your personal data in a structured, commonly used, and
machine-readable format. This enables you to transfer your data to another service provider.
Application: Applies primarily to data processed by automated means and provided by you
under consent or contract.
(VI) Right to Object
You may object to the processing of your data for direct marketing or based on our
legitimate interests. Once an objection is raised, we will cease processing your data for the
stated purpose unless we demonstrate compelling legitimate grounds.
(VII) Right to Withdraw Consent
If data processing is based on your consent, you may withdraw it at any time. This will
not affect prior processing but will prevent further use of your data under that consent.
How to Exercise Any Right: Please email your request to [email protected]. For
security, we will verify your identity and provide guidance on the next steps. Requests will be
handled in accordance with local laws and within reasonable timeframes.
(VIII) No Discrimination
Exercising your data rights will not result in any unfair treatment or denial of
services, although some features may become unavailable depending on the nature of the request.
We handle all data disclosures with strict caution and transparency. While we do not sell your
personal data under any circumstances, we may share it in the following controlled situations:
(I) Service Providers
We partner with carefully vetted third-party providers who support essential business
functions such as payment processing, data analytics, customer support, infrastructure hosting,
and fraud prevention.
Safeguards: All such partners are bound by strict data protection agreements and may
only use your data to provide agreed-upon services.
(II) Advertising and Analytics Partners
We may share anonymized or pseudonymized data with advertising networks and analytics
services to enhance marketing relevance and platform insights.
Control: You may opt out of personalized advertising through in-app settings or
device-level controls.
(III) Legal Compliance
We may disclose your information when legally required to comply with judicial
proceedings, court orders, law enforcement requests, or other legal obligations.
(IV) Corporate Transactions
In the event of a company merger, acquisition, asset transfer, or reorganization, your
data may be transferred as part of the transaction. We will notify you in advance where required
by law.
(V) Protection of Rights
We may use or disclose your information if necessary to protect the rights, property, or
safety of the Company, our users, or the public. This includes fraud prevention, risk
management, and enforcing our policies.
Our services are not designed for or directed to children under the age of 13. We do not
knowingly collect or solicit personal data from minors.
Actions: If we become aware that a child under 13 has provided personal data, we will
delete it immediately. Parents or guardians who believe their child may have submitted data can
contact us at [email protected] for prompt removal.
We use cookies, pixel tags, and similar technologies to enhance functionality, personalize user
experience, and gather analytics.
Types of Cookies:
1.Essential: Required for platform functionality (e.g., session cookies)
2.Performance: Helps us understand how users interact with our services
3.Targeting: Supports advertising relevance
User Control: You can manage your cookie preferences through browser settings. Note that
disabling certain cookies may limit platform performance or functionality.
We may revise this Privacy Policy from time to time to reflect technological developments, legal
requirements, or operational needs. All updates will be posted on our platform with a new
effective date.
Notification: If changes materially affect your rights or how we use your data, we will
provide prominent notice via email or in-app notification.
Review Encouragement: We recommend reviewing this policy regularly to stay informed
about how your personal data is protected.
We welcome your questions, concerns, and feedback regarding this Privacy Policy or your personal
data. Please reach out using the details below:
Email: [email protected]
Address: Rua MELO FREIRE 874, SAO PAULO (TATUAPE ), 03314-030, Brazil
We are committed to responding promptly and responsibly to all inquiries and ensuring
your privacy is respected in every interaction.