Last Updated: January 25, 2021

Papaya Gaming (N.I) Ltd. (“Papaya” or “us” “we” or “our”) is dedicated to protecting the privacy rights of our online users ("users" or "you"). This Privacy Policy has been crafted to inform you as to the ways we collect, store, use, and manage the information you provide in connection with the website, (the “Website”), and any services, materials, or content provided through the Website (the “Services”). Please note that the scope of this Privacy Policy is limited to only information collected by Papaya through use of the Website.


Any personal information you may provide through your use and/or access of the Website is subject to the terms of this Privacy Policy, as may be updated by Papaya from time to time. Please read this Privacy Policy carefully before using the Website and/or accessing the Services. This Privacy Policy does not apply to any third-party websites, services, providers, or applications, even if such are available or accessible through the Website and/or our Services


 By using the Website, you agree to the collection and use of your personal information as outlined in this Privacy Policy. IF YOU DO NOT AGREE TO THE PROVISIONS CONTAINED IN THIS PRIVACY POLICY, PLEASE DO NOT USE THIS WEBSITE OR ANY SERVICES WE MAY PROVIDE. The terms contained in this Privacy Policy shall be read in conjunction with our Terms of Use (the “Terms”), found at


Information Collected and Used


Your personal profile will automatically be populated with your selected username, which you are allowed to change in accordance with the provisions set forth on the Website. Any information and content that you voluntarily add to your profile, such as your personal image, will be made public by default and will not be subject to this policy. Your username and profile will be publicly searchable, and your personal image will appear in search.


Papaya's primary objective in collecting user information is to provide and enhance the Website and to enable users to easily navigate and enjoy the Website. We will only collect information that is relevant for the purposes of providing the Services, including, without limitation: (i) provide, test, promote, and improve the Services; (ii) gather usage statistics for the Services; (iii) administer your use of the Services and provide a customized user experience; (iv) provide access to third party content or services; and (v) fight spam, fraud, and/or other abuse of the Services.


If you choose to log in, access or otherwise connect to the Website and/or Services through a social networking service (such as Facebook, Twitter, Instagram, etc.), we may collect your user ID and/or username associated with that social networking service, as well as any information you make public using that social networking service or that the social networking service allows us to access. We may also collect information you have authorized the social networking service to share with us on your behalf. This supplemental information allows us to verify information that you have provided through use of the Website and/or Services and to enhance our ability to provide you with information about our business, products, and Services. Please note that your social media profile may be made available to other Papaya users should you participate in Services by logging on and/or connecting to the Website via your social media profile.


The types of personal information collected in accordance with your use of the Services, including, without limitation, the Website, may vary depending on the activity. This "personal information" is defined as information about you that can be used to contact or identify you. Personal information may include, without limitation, your: (1) full name, (2) email address, (3) mailing address,  (4) date of birth, or (5) social security number. For the avoidance of doubt, the social security number shall not be stored or saved in any way by Papaya. Additionally, we may acquire information from you through, without limitation, your: (1) access and participation in message boards on the Website (2) emailing of a question to our customer support, or (3) your purchase of a virtual product of any type. When you send a communication via the Website or directly to use via email, you agree Papaya is free to use the content of any communications submitted by you for any purpose, including developing and/or providing the Services. Papaya may also invite you to share non-personal information about yourself that may include but is not limited to: (1) your gender; (2) information about the hardware you may own; (3) your favorite websites, friend information and fan pages (collectively referred to as "non-personal information"). If non-personal information is collected for an activity that also requires personal information, Papaya may combine your non-personal information with your personal information in an attempt to provide you with a better user experience, to improve the quality and value of the Website, and to analyze how the Services are used. All personal and non-personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is used. It shall be your sole responsibility to update any and all personally identifiable information provided for use of the Website and/or Services


The Website will also record game play information such as your high scores, win/loss record and percentage, and other game play data and/or information.


In addition to information collected as described above, you may choose to share additional information about yourself throughout the Website, such as in games or on message boards. Any actions you perform with other players are considered public, and are provided and/or performed your sole discretion.


Finally, any time you access the Website, we may collect aggregate information including but not limited to internet protocol addresses, browser type, browser language, referring / exit pages and URLs, operating system, mobile carrier, and/or device information automatically assigned to your computer or device used by you to access the Website and/or Services, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, and the date and time of this activity. We use this information to better tailor the Website to your interests, to provide you more efficient customer support, and to overall enhance the Website.


How Your Information is Processed


Papaya uses the information received from you in connection with the Services and features provided via the Website, including, without limitation, in order to:


  • Process and respond to customer service / user inquiries;

  • Alert users to new services, content and/or features;

  • Prevent fraudulent or other criminal activity;

  • Meet legal and regulatory requirements;

  • Provide access to certain functionalities and features of the Services;

  • Enforce the Terms;

  • Contact users for administrative purposes, including, without limitation, notifying you of changes to the Privacy Policy; and

  • Monitor and track total number of users of the Website for statistical purposes.


In all cases of data access and collection, the information you provide will not be disclosed, rented, leased, loaned, sold, or otherwise voluntarily distributed to unaffiliated third parties and will be used and processed solely for one or more of the following Purposes: (i) to allow us to provide you with and improve the Website; (ii) to process any of your requests for information; (iii) to provide member support Website to you; (iv) to notify you about updates to our Services  and/or Website; and (v) to support any of the intended purposes specifically stated at the time at which you provided the information.


Papaya may also make anonymous and/or aggregate personal information for commercial, marketing, and/or business purposes, such as reporting and conducting research and development in order to enhance our existing Services and/or develop new products and Services. Anonymous or aggregated information does not identify you, and we may use or disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information internally and/or with third parties for our or their purposes in an anonymous or aggregated form that is designed to prevent anyone from identifying you.


To Whom Your Information is Disclosed ("Recipients")


Your information may be disclosed for processing to any of the following Recipients: (i) to any entities existing within the same group of companies in which Papaya exists and their employees who have a need to know such information; (ii) to any third parties which provide services to Papaya or their subcontractors in order to allow or enable us to provide you with the Website and/or Services; (iii) to any auditors, contractors or other advisers auditing any of Papaya’s business processes; and (v) to any potential purchasers or investors. Any such third party shall be prohibited from sharing or using your personal information except as necessary to perform the Services or to comply with applicable legal and regulatory requirements. Any processing performed by any Recipients will, where required by law, be governed by a data processing agreement in the form required by law, preserving any and all of your statutory data protection rights and obligating the Recipients to respect the disclosed information and handle it in accordance with the relevant laws.


Other Disclosure of Your Personal Information


We ensure that your information will not be disclosed to government institutions or authorities except if required by law and regulations or in the event of a claim and/or legal process (including but not limited to subpoenas), to protect the property and rights of Papaya or a third party, to protect the safety of the public or any person, or to prevent or stop any activity Papaya may consider to pose a risk of being illegal, unethical, inappropriate or legally actionable.


If you choose to share information with social media services about your activities on the Website by, for example, connecting your social media account (i.e. Facebook account) to the Website, then we may share your personal information and information about your use of the Website with such social media websites. Use of social media service websites is governed by the privacy practices and policies of those websites, including, without limitation, your ability to opt out of certain settings. Please make sure to read the terms and privacy statements of such social media websites prior to connecting to the Website via your social media account.


In the event of a merger, acquisition, reorganization or sale of assets, Papaya may sell, transfer or otherwise share some or all of its assets, and your personal information may be transferred as part of that transaction.




We may send you a permanent cookie when you register with us. A cookie is a small data file that can be placed on your computer's hard disk or your mobile device for record keeping purposes. Cookies can help us recognize you the next time you use the Website, and/or note the advertisements you click on and the other sites you enter via a link from outside the applicable third party Website. This allows us to tailor the Website to your preferences. We may also use the data generated from cookies to compile statistical data on your use of the Website. The Website uses four types of cookies: (i) 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; (ii) 'first party cookies' / 'persistent cookies' which are set and read only by our Website, saved on your computer for a fixed period (usually a year or longer) and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next login (such as user name and/or password); (iii) 'third party cookies' which are set by third party  websites who run content on the page you are viewing, for example by analytics companies who monitor and analyze our web access; and (iv) 'flash cookies' which are saved during game play to allow quicker and better playing experience. You are not obliged to accept a cookie from us or from any other website. You can modify your browser so that it will not accept cookies although you may not be able to access or use features of the Website. However, for legitimate security reasons, we may refuse access to specific website content unless you accept the use of a cookie or similar device.


We check your IP address to determine your current location in order to determine the state you are located within to establish which aspects of the Website you are permitted to use. You may not opt out of the collection of this type of geo-location data.


Use of Cache Data


A cache is a component of your mobile device that transparently stores data for record-keeping purposes. Cache data does not identify users, but does identify your mobile device. Most browsers and applications are initially set up to accept such data. If you prefer, you can program your mobile device so that it does not store this information while utilizing the Website. Certain application features may only be available through the collection of such data. We may use such data to assist in data collection and to track application usage and trends to help us better serve you. We also permit third parties who have entered into confidentiality agreements to access such data to help us monitor use of the Website for fraud or any other activity that does not comply with applicable laws.


Some of our business partners (e.g., analytical tracking software providers) use cookies and tracking technologies on the Website. We have no access to or control over these cookies or tracking technologies. This Privacy Policy covers the use of cookies and cache data on the Website and by us only and does not cover the use of cookies or tracking technologies by any such business partner.


Social Media Applications


When you register to use the Website and/or Services through a social media application ("App") you agree to provide your basic profile information (such as username and email address) and we may obtain the following from your social media profile through the App: (i) your basic information (including your name, profile picture, gender, networks, user ID, list of friends and any other information you made public on Facebook), (ii) your email address, and (iii) your date of birth. The App may publish in your name all of your App-related activities through your social media account, including, without limitation, achievements and winnings you earned, your high scores and more, as well as post in chats and send virtual gifts on your behalf. You shall at all times have the option to modify our permission to do all of the foregoing via your social media profile’s privacy preferences. Papaya does not have any control over information shared through your social media profile.

Third-Party Websites


The Website may contain links to other websites, products, advertisements, or services. The fact that the Website links to a website or presents a banner ad or other type of advertisement does not mean that Papaya endorses or authorizes that third party, nor is it a representation of our affiliation with that third party. This Privacy Policy does not cover any collection or use of information that third party websites may collect from you, or the practices used by third parties to collect such information, and third party websites should have separate and independent privacy policies and terms of use for the purpose of collecting personal information about you. Papaya is in no way responsible for the privacy policies or the content of these other websites to which you chose to access from the Website. Please be sure to read the privacy policies of those websites when exiting the Website. If you decide to use, click on, access, or provide any personal information to a third party website, you acknowledge that you are doing so at your own risk.


Third-Party Payment Processing


When you pay fees through the Website, we may process your payments through a third party website, including, without limitation, third-party payment processors. The third party website may collect certain financial information from you in order to process a payment, including your name, email address, address and other billing information. In order to delete your payment or billing information, you may need to do so with the third party website, as Papaya only has minimal secure access to those records as needed to provide the Services.


Changing or Deleting Your Information


You can modify personal information through your personal settings or by contacting us at You may inquire as to whether Papaya is processing your personal information, request access to your personal information, and ask that we correct, amend or delete your personal information where inaccurate. If you want us to delete your personal information, please contact us at with your request and/or follow the necessary procedures provided through the Website. We’ll take steps to delete your information as soon we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.


Papaya will use best efforts to provide you with access to your personal information. However, there may be circumstances in which we are unable to provide access, including but not limited to: (i) where the information contains legal privilege, (ii) would compromise others’ privacy or legitimate rights, (iii) where the burden or expense of providing access would be disproportionate to the risks to your privacy, or (iv) where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your personal information


In relation to the App, you may review, update, correct or delete any personal information by changing the applicable information provided through your social media profile. If you completely delete all this information, your Papaya account may become deactivated.




We have put in place suitable technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. However, we cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your personal information for improper purposes. Also please note that email and messaging systems are not considered secure, so we discourage you from sending us personal information through these mediums. If you become aware of any security vulnerability or potential data breach, please contact us immediately, and we will take the appropriate measures to address such incident, as deemed necessary. Notwithstanding, Papaya cannot assure or guarantee that any third party with which Papaya shares information will comply with its obligations regarding such information. Furthermore, even though appropriate measures are used to prevent unauthorized disclosures of information, we cannot assure you that any personal identification information collected or received by us will never be disclosed in a manner that is inconsistent with this Privacy Policy, and do not accept liability for any unintentional disclosure.


By using the Website or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Website and/or Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Website or sending you an email at the email provided to us.


​Postings to Public Forums


All postings in Papaya public forums will generally be available to, and freely accessible by, other users of the Papaya public forums as well as the Internet general public. Therefore, users should not expect that any information they post will be kept private or confidential and are encouraged to exercise discretion when using the public forums. Additionally, your username, which you can change, will always be included in conjunction with your postings in the public forums. Papaya is not responsible for events arising from the distribution of any information you choose to publicly post or share through the forums. All information or materials uploaded by you while utilizing the Services is subject to our Terms of Service available at


Policy Regarding Children


The Website is not geared toward children under the age of 18 and we do not knowingly collect personal information from children under the age of 18. If we learn that a child under 18 has provided us with personal information we will delete such information from our files as quickly as possible. If you are a parent or guardian who has discovered that your child has submitted his or her personal information, Papaya will make reasonable efforts to delete the information from its database, at your request. To request the deletion of your child’s information, please send an email to Be sure to include in your message the username, email address and password that your child submitted.


International Transfer


Since we operate globally, it may be necessary to transfer your personal information to Recipients who are located in countries outside the United States. This may happen if our servers or such Recipients or their servers are based outside the United States. If you use our Website and products while visiting countries outside the United States or if we transfer your personal information to Recipients or Recipients that have their servers located outside the United States, you hereby consent to said transfer of your personal information. The data protection and other laws of these countries may not be as comprehensive as those in the United States - in these instances we will take steps to ensure that a similar level of protection is given to your personal information. Notwithstanding the foregoing, this Privacy Policy, and the collection of information hereunder, shall comply with all relevant data protection provisions, including, without limitation, the General Data Protection Regulation (GDPR).


If you are located outside the United States you note that we are processing your personal information in order to provide the Services, or otherwise pursue our legitimate business interests. Our legitimate business interests are balanced against your rights and freedoms and we will not process your personal information if your rights and freedoms outweigh our legitimate business interests.


Additionally, if you are located outside the United States, we may also process your personal information when we are required or permitted to by law; to comply with government inspection, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our Site, or other criminal and tortious activities), defend litigation, and manage complaints or claims.


As required by the GDPR, we require that all processors and sub-processors of the data we collect fully comply with the obligations of the GDPR and do not infringe on your privacy rights in any way. In particular, you have the following rights:


  • Right to Access. You have the right to see any personal information we have collected about you as well as the purpose of our collection and processing of it and whether we plan on sharing such personal information with anyone.


  • Right to Correct. You have the right to complete and/or correct any inaccurate personal information in our possession. In order to complete and/correct personal information, you may contact us at


  • Right to Erase. You have the right to have your personal information erased from our data stores without undue delay. Additionally, we will erase personal information without undue delay if:


  • The personal information is no longer necessary in relation to the purposes for which it was collected;


  • You withdraw consent and there is no other legitimate basis for the processing;


  • You object to the processing and there are no overriding legitimate grounds for the processing;


  • The personal information has been unlawfully processed; or


  • The personal information must be erased for compliance with any of our legal obligations.


  • Right to Restrict. You have the right to restrict processing of your personal information. You may notify us regarding restricting your personal information by contacting us at


  • Right to Port Data. You have the right to request your personal information be ported over to another controller. However, in certain situations, we may not have the technical means to port the information automatically. If this is the case, we will recommend that you delete your personal information instead.


  • Right to Object. You have the right to object to the collection or processing of your personal information at any time if you believe your personal information was collected or processed unlawfully. Our team will work with you to investigate the claim and take appropriate action. While the claims are under investigation, your personal information may be deleted from our Website. You may resubmit your personal information at any time.




Papaya will retain your personal information received as described in this Privacy Policy while you are an active user of the Website and Services, and thereafter so long as needed for purposes that are not prohibited by applicable law. Before we use any of your personal information for any new purpose not originally authorized by you or set forth in this Privacy Policy, we will use best efforts to provide details regarding the new purpose and give you the opportunity to opt-out. Furthermore, where consent is required to process any personal information pursuant to applicable law or contract, we will use best efforts to comply with such law or contract.


Upon termination of your use of the Services, we reserve the right to maintain your personal information as part of our standard back-up procedures in an aggregated format. When personal information is no longer required, we will utilize procedures to destroy, delete, erase or convert it to an anonymous form




You have the right to opt out of certain uses and disclosures of your personal information. Where you have consented to Papaya’s processing of your personal information, you may withdraw that consent at any time and opt-out to further processing by contacting us at If you opt-out, we may still collect and use non-personal information regarding your use of our Services for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.


You may “opt-out” by following the unsubscribe instructions provided through the Website. We do need to send you certain communications regarding the Services and you will not be able to opt-out of those communications – e.g., communications regarding updates to our Terms or this Privacy Policy.


We may occasionally send you push notifications through your device with updates and other notices that may be of interest to you. You may opt-out from receiving these types of communications by changing the settings on your device.


California Privacy Rights


California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you wish to opt-out of disclosing personal information to third parties, such requests may be made to Under California law (and as a result of your ability to opt-out as set forth in this Privacy Policy), we are not required to maintain or disclose a list of third parties that receive your personal information for marketing purposes.


Under the California Consumer Privacy Act (“CCPA”), California consumers have the following rights, which can be exercised directly or in certain cases, through an authorized agent:


  • Right to Know. California customers have the right to request information about the categories and sources of personal information we collect, our purposes for collecting the information, and the types of third parties that receive that information. Details about our data collection, use and third-party disclosures can be found in this Privacy Policy. In addition, you have the right to request a copy of your personal information. You may exercise this right once per 12-month period by submitting a request to us at


  • Right to Delete. California customers have the right to request that we delete some or all of the personal information that we have about you, subject to certain exceptions (i.e. to complete transactions, honor opt-outs, prevent fraud, spam, and other abuse, comply with our legal obligations, cooperate with law enforcement, and to exercise and defend our rights). You may exercise your right to delete by contacting us at


  • Right to Opt-Out of Sale of Personal Information. California customers have the right to opt-out of the sale of your personal information, and to request information about whether we have sold your personal information in the past 12 months. We do not sell personal information, and we do not plan to do so. Should such change, we will notify you and provide an ability to opt-out as required.


  • Non-Discrimination. We won’t discriminate against you because you exercise any rights herein.


To exercise the foregoing rights, we must be able to verify your identity as the owner of the personal information. In general, we verify identity by confirming that you are the owner of the email address associated with the personal information. An authorized agent submitting a request on your behalf must also have access to the email address associated with the personal information, along with sufficient evidence that you have authorized that person to submit the request on your behalf.


Governing Law


This Privacy Policy shall be construed and enforced in accordance with the laws of the State of Spain without regard to any conflict of law provisions. Notwithstanding the foregoing, this Privacy Policy, and the collection of information hereunder, shall comply with all relevant data protection provisions, including, without limitation, the Data Protection Act and General Data Protection Regulation.


Contacting Us


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


Effective Date; Policy Changes


Each time you use the Website, the current version of the Privacy Policy will apply. Accordingly, when you use the Website, you should check the date of this Privacy Policy (which appears at the top of the Privacy Policy) and review any changes since the last version. This Privacy Policy is subject to change from time to time. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you. The continued use of the Website and/or Services following the posting of any amendments will be deemed as acceptance of those amendments.


General Provisions


This Privacy Policy sets forth the entire understanding between you and Papaya regarding your use of the Website and Services. In the event that any one or more of the terms and conditions contained in this Privacy Policy is held to be invalid, illegal or unenforceable, the remaining provisions will not in any way be affected or impaired thereby. Papaya's failure to insist upon strict adherence to any term contained in this Privacy Policy shall not constitute a waiver of such term and shall not be considered a waiver or limit of any right thereafter to insist upon strict adherence to that term or any other term contained in this Privacy Policy. The Parties shall make a good faith effort to resolve any actual or threatened breach of this Privacy Policy, or any other dispute arising under or in connection with this Privacy Policy, by binding arbitration under the administration and rules of the European Arbitration Association. The arbitration shall be held in in the county in which you reside, or another mutually agreeable location. The prevailing party in any action or proceeding shall be entitled to reasonable costs and attorneys' fees.


Notwithstanding the foregoing arbitration provisions, in no event shall Papaya be precluded or delayed from seeking and obtaining temporary, preliminary and/or permanent injunctive relief, without the posting of any bond or proving of actual damages, against infringement (or threatened infringement) or other violation (or threatened violation) of its claimed intellectual property rights, or other relief that it deems reasonably necessary to defend or enforce its rights or this Privacy Policy, in any court(s) of competent jurisdiction, and through your use of the Website, you hereby consent to, and hereby waive any objection regarding, such  jurisdiction and venue. This is without prejudice to your right to launch a claim with the data protection supervisory authority in the country in which you live where you think we have infringed data protection laws.


Survival of the Privacy Policy


Regardless of your request to delete your account, the provisions contained in this Privacy Policy shall survive any termination of your account and/or use of the Website and/or Services.