Privacy Policy

Last updated: September 1, 2024

Introduction

This privacy policy for Playmaker Software Ltd ("we", "us", or "our"), doing business as Playmaker, describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

- Visit our website at https://www.playmaker.so, or any website of ours that links to this privacy policy

- Use our web or API-based applications, downloaded desktop software, or any other software of ours that links to this privacy policy

- Download and use our mobile application (Playmaker), or any other application of ours that links to this privacy policy

- Engage with us in other related ways, including any sales, marketing, or events

Summary of Key Points

What personal information do we process?

When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

- **Do we process any sensitive personal information?** We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.

- **Do we receive any information from third parties?** We do not receive any information from third parties.

- **How do we process your information?** We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

- **In what situations and with which parties do we share personal information?** We may share information in specific situations and with specific third parties.

- **How do we keep your information safe?** We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.

- **What are your rights?** Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

## 3. What Information Do We Collect?

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

### Personal Information Provided by You

The personal information we collect may include the following:

- names

- email addresses

- job titles

- usernames

- passwords

- contact preferences

- billing addresses

- debit/credit card numbers

- phone numbers

- mailing addresses

- contact or authentication data

### Sensitive Information

When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

- financial data

- customer data

### Application Data

If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

- Mobile Device Access

- Push Notifications

## 4. How Do We Process Your Information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

- To facilitate account creation and authentication and otherwise manage user accounts

- To request feedback

- To protect our Services

- To identify usage trends

- To save or protect an individual's vital interest

## 5. When and With Whom Do We Share Your Personal Information?

We may share information in specific situations described in this section and/or with the following third parties.

### Third-Party Service Providers

We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. The categories of third parties we may share personal information with are listed in Annex 2.

## 6. Do We Use Cookies and Other Tracking Technologies?

We may use cookies and other tracking technologies to collect and store your information. We use both session-based and persistent cookies.

## 7. How Long Do We Keep Your Information?

We keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law. No purpose in this policy will require us to keep your personal information for longer than the period of time in which users have an account with us.

## 8. How Do We Keep Your Information Safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure.

## 9. Do We Collect Information From Minors?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services.

## 10. What Are Your Privacy Rights?

Depending on your location, you may have certain rights regarding your personal information, such as the right to request access, correction, or deletion of your data.

## 11. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized.

## 12. Data Residency and Processing

### Data Storage and Processing Locations

All our data is stored and processed exclusively within the European Union (EU) and United States (US). Our servers are located in EU data centers, and we do not transfer data outside the EU zone except when using Large Language Model (LLM) providers for processing.

### AI and Data Usage

We only use LLM providers (currently OpenAI, Anthropic, and Google) that specifically mention that they do not train their models with the data received from APIs. For our own models, we follow the same procedure. We do not train our models with customer data.

### Reinforcement Learning Process

Playmaker strips out extracted data from the actual documents and keeps only the format for learning purposes. We use multiple layers of AI models to ensure accuracy without retaining sensitive information.

## 13. Changes to This Privacy Policy

We may update this privacy policy from time to time. We will notify you of any changes by posting the new privacy policy on this page and updating the "Last updated" date at the top of this privacy policy.

## 14. Contact Us

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Efecan Erdur, by email at efecan.erdur@playmaker.so, or contact us by post at:

Playmaker Software Ltd

272 Bath Street, Glasgow, Scotland, G2 4JR

## Annex 1: Categories of Data Subjects and Personal Data

### Categories of Data Subjects

- Customers

- Employees

- Prospective Customers

- Suppliers and Service Providers

- Website Users

- End Users

- Partners

- Applicants

- Subscribers

- Event Participants

### Categories of Personal Data Processed

- Identification data

- Employment data

- Technical data

- Usage data

- Marketing data

- Location data

- Educational data

- General financial data

### Sensitive Categories of Personal Data Processed (if applicable)

- Sensitive financial data

- Racial or ethnic origin

- Political opinions

- Religious or philosophical beliefs

- Trade union membership

- Genetic data

- Biometric data

- Data concerning health

- Data concerning a person's sex life

- Data concerning a person's sexual orientation

## Annex 2: List of Subprocessors

| Name | Purpose | Region |

|------|---------|--------|

| Amazon Web Services (AWS) | Cloud infrastructure | European Economic Area |

| DigitalOcean | Cloud infrastructure | European Economic Area |

| CloudFlare | Cloud infrastructure | European Economic Area |

| Hetzner | Cloud infrastructure | European Economic Area |

| OpenAI | AI services | United States |

| Anthropic | AI services | United States |

| Google | AI services | United States |

By using our Services, you acknowledge that you have read and understood this privacy policy.