Ghoulz Competition – Privacy Notice

INTRODUCTION

Last updated: September 2026.

This Privacy Notice ("Notice") describes how Playo Ltd. ("Playo", "we", "us", or "our") collects, uses, and shares personal data about you when you participate in our Ghoulz competition (“Competition”), including when you use our browser-based game – Ghoulz (both as a guest player and as a competition participant), visit our competition landing page, and when we further process personal data about you as a Competition participant (collectively: “Service”).

For more information on the Competition – please see the Ghoulz Competition – Official Competition Rules (“Competition Rules”).

The term personal data refers to any information relating to an identified or identifiable natural person.

By accessing or using the Service, or by registering for the Competition, you acknowledge that you have read this Notice.

The following summary will provide you with a quick and clear view of our practices. Please take the time to read our full privacy notice, and if you do not agree with its terms, please do not access or otherwise use the Service.

SUMMARY OF THIS PRIVACY NOTICE

Personal data that we collect and use – If you choose to enter our Competition after playing our game, we will collect account information through Google Sign-In (your Google account identifier and associated email address), your nickname, your self-declared age, and country of residence, your gameplay and score data, anti-cheat signals, technical and usage information (including approximate country-level location derived from your IP address), and information about how you arrived at our landing page (such as the promotional campaign or source). If you are invited to take part in the Ghoulz 1v1 Feature and you accept, we will also record that session, including your camera video and your voice, for publication by Ghoulz; and if you are under 18, we will collect your parent or guardian's contact details and their consent before recording. If you are selected as a potential winner, we may collect additional information to verify your identity, age, and residence, and if you are the grand prize winner, the information needed to deliver your prize. If you are a grand prize winner, and a minor, we will ask you for the email address of your parent or guardian, to provide relevant information or documents verifying that they are your parent/guardian and the relevant shipping address.
What do we do with personal data related to you? – We use this information to run the Competition, verify eligibility, determine winners, notify and communicate with winners, coordinate prize fulfillment, and understand how the Competition performed.
How do we share personal data related to you? – We do not sell or rent personal data. Other than a Ghoulz 1v1 Feature recording, which Ghoulz publishes on Ghoulz's own social media channels, we do not share it with the promotional partner running our marketing campaign. A public leaderboard may display your nickname, score, and ranking. We use service providers only to the extent necessary, and Google performs sign-in authentication under its own privacy policy. We may also disclose personal data where required by law or legal process, to protect rights and safety, or in connection with a merger, acquisition, or sale of assets. Some privacy regulators may treat our use of service providers as Selling or Sharing.
How long will we retain personal data? – We keep Competition-related information for the duration of the Competition and for an additional period needed to support the purpose of the Competition, including winner verification and prize fulfilment, then delete or anonymize it, unless we are required to keep it longer to comply with applicable law or to resolve a dispute. A published Ghoulz 1v1 Feature recording is retained for as long as it is needed for the purposes described in this notice.
Children's privacy – We ask for a participant's age before registration, and participants must be at least 13 years old (or older if using the Service from your territory requires that you are older under applicable law) to register for the Competition. This applies no matter whose device is used. We do not knowingly collect personal data from anyone under 13, and if we learn that we have, we will delete it. Other than a Ghoulz 1v1 Feature recording published with parental consent, we do not use children's information in connection with advertising or marketing activities.
Your choices and rights – You can stop participating in the Competition at any time and ask us to delete your Service account. You can opt out of appearing on the leaderboards at any time without affecting your eligibility to win a prize. You can ask us to access, correct, or delete personal data by contacting us.
Where do we store personal data? – Information is processed on servers located in the United States, which may be outside your country of residence.
Cookies and tracking technology – We use cookies and similar technologies, including analytics tools, to keep you signed in, maintain session state while you play, record scores reliably, and understand how the Service is used. Non-essential cookies are used only if you accept them through our cookie consent banner. You can see details about which cookies are used by using our cookie consent banner.
Information security – We use reasonable safeguards designed to protect personal data from loss, misuse, and unauthorized access.
Changes to this notice – We may update this notice from time to time. Non-material updates take effect when we publish the new notice; material changes take effect a stated number of days after publication, as set out in our notice of the change.
Contact us – Please contact us at [email protected] with any questions about this notice.

PERSONAL DATA THAT WE COLLECT AND USE

The types of personal data that we process depend on how you use or interact with our Service. Below is a breakdown of the categories of personal data we process, divided based on how you interact with our Service:

Landing Page Visitors

When you visit the Competition’s landing page, we process:

Technical and usage information. We collect basic technical information such as your IP address, your language settings, and browser type and version, along with usage statistics and diagnostic logs, to operate and troubleshoot the Service.
Campaign source information. We collect information about how you arrived at our landing page, such as the promotional campaign or source (for example, the YouTube promotion).
Information collected automatically. We use cookies and browser local storage to keep you signed in, to maintain session state while you play, and to record your scores reliably, as further described under Cookies and Tracking Technology below.
Correspondence Data. If you contact us, either via the landing page (where available) or as provided under Contact Us below, we will collect whatever personal data you choose to include in that communication.

Players

All Players (Guests and Competition Participants)

When you choose to play the game made available on the Competition landing page, you have the option to do so without registering for the Competition as a guest player. In such case, we will process:

Approximate location information. We derive approximate location – country level only – from your IP address, in order to help protect the Service against fraud and abuse. We do not collect precise geolocation data such as GPS coordinates.
Gameplay and score data: Challenge map completions, score, kill counts, cumulative Challenge Week score, score timestamps, attempt/session data, and anti-cheat/abuse signals.
Anti-cheat and abuse signals. We collect and analyze technical and gameplay signals to detect prohibited conduct.
Technical/browser data: Similarly to the landing page, as the game is played in-browser, during gameplay we also process browser type and version, operating system, screen/viewport size, language setting, IP address, session identifiers, page/request timing, and error/performance diagnostics.
Cookies/local storage: Used to keep a player’s sign-in status, maintain session state, and record scores.

Competition Participants

If you choose to participate in the Competition, we will also process:

Registration

Google account information & Email address. To register for the Competition, you must sign in with Google Sign-In, and we will collect your Google account identifier and the email address associated with that account. We do not receive your Google password. We may receive additional information about your Google account, depending on your Google account configuration.
Nickname. The nickname you choose at registration, which is used to identify you on the public leaderboard described below.
Rules Acceptance Record. Records of your acceptance of the Competition rules and your consent to this Notice.
Eligibility to Compete. As part of the registration process, we will review whether you are eligible to participate in our Competition, which will include collecting your:
- Full name;
- Self-declared confirmation that you are over 13 (or older, if the laws of the territory from which you use the Service require that you are older to use it);
- Country-level location (including by asking you and automatically based on your IP Address) to confirm you reside and are currently located in the Eligible Territory (as provided under the Competition Rules);
- Email address for identity verification;
- Confirmation of professional/employment status, e.g., that you are not an employee, contractor, or immediate family member of the Competition Sponsors or their affiliates or agents (as provided under the Competition Rules). Note that you may still participate in the Competition, but you will not be eligible for a prize; and,
- Any other eligibility-specific information, e.g., proof of enrollment, membership, licensure, or geographic residency documentation required under the Competition Rules, as requested of you at registration.

Gameplay

Leaderboard Ranking data: the participant's nickname, score, and ranking, used for displaying competition standings publicly during the Competition period.
Ghoulz 1v1 Feature data. If you are invited to take part in the Ghoulz 1v1 Feature described in the Competition Rules, and you accept that invitation, we process:
- a recording of the 1v1 session, which includes gameplay footage, your camera video and your voice;
- your nickname, which Ghoulz may say aloud during the session;
- the email address to which we send the invitation and your response to it; and,
- where you are under 18, your parent or guardian's email address and a record of the consent they give us by email.

The 1v1 session takes place on a third-party communications platform chosen by Ghoulz, which receives your camera video and audio under its own terms and privacy policy. The recording is published by Ghoulz on Ghoulz's own social media channels. We do not record camera video or voice at any other point in the Competition, and ordinary gameplay outside the 1v1 session is never recorded.

Potential Winners, Winners & the Grand Prize Winner

If you are identified as a potential winner (grand prize and runner up prizes), we will also process:

Legal name. Your full name as it appears on your identity documents, which may differ from the nickname you registered with.
Proof of age. Documentation confirming you meet the minimum age for the Competition.
Proof of country of residence. Documentation confirming you are a legal resident of an eligible territory.
Identity verification. Information confirming you are the person who registered and the holder of the registered Google Account.
Prize acceptance documentation. The forms we ask you to complete and return in order to accept a prize.

If you win our grand prize, we will also process personal data required to deliver your prize to you, including:

Recipient name. The name of the person receiving the prize. This is usually your legal name, but where the winner is under the age of majority it is the parent or legal guardian who accepts delivery.
Delivery address. The full postal address the console is shipped to, including country and postal code.
Delivery contact details. A phone number and email address the carrier can use to arrange delivery.
Parent or guardian identity and authority documentation. Where parental consent is required, and if required under applicable law, we may also request that your parent or guardian provide us with a legal document confirming their authority to act on your behalf.

Sensitive information

Excluding potential winner eligibility checks and the Ghoulz 1v1 Feature recording (see below), the Service is not intended to be used to process sensitive personal data. However, the Service may be used by individuals who are underage (however over 13 or older depending on the jurisdiction), as described under Children’s Privacy below.

Under some privacy laws and regulations, personal data relating to an underage individual may itself be considered sensitive personal data.

Regardless of where you are accessing the Service from, and which privacy laws apply to our processing of personal data related to you, we will allow users who are under 16 years of age to request that we limit the use of personal data about them to the following purposes, other than the recording and publication of a Ghoulz 1v1 Feature session to which they and their parent or guardian have consented:

To provide the Service, check it, maintain it, and improve its quality and safety.
To keep the Service, our systems, and personal data safe and secure, and to detect and investigate security problems.
To stop fraud, scams, or other illegal activity and pursue those responsible.
To protect people's physical safety in an emergency.
For quick, one-time uses during your current visit – like showing you a relevant ad without saving anything, creating a profile on you, or tracking you afterward.
Customer support, handling orders and payments (including providing you with your reward if you win), verifying your information, and account maintenance.
To run features (like a search tool) that use your input without trying to figure out anything personal about you.

Additionally, as detailed under Personal Data that We Collect and Use, if you are identified as a potential winner, we may also request copies of official documents proving your identity, age, and – where relevant – the identity and authority of your parent or guardian.

Such documents, and the data contained within them, may be considered sensitive under some privacy laws. Either way, we will only use such documents and data for the purpose of validating your eligibility to receive a prize.

WHAT DO WE DO WITH PERSONAL DATA RELATED TO YOU?

We use the personal data we collect for the following purposes:

to operate the Service, maintain it, improve it, protect it, and run the Competition.
to verify eligibility to participate in the Competition – including age, identity, and territory/residency verification.
where required under law – to obtain, verify, and evidence parental or guardian consent for winners who are under 18, and for participants under 18 who are invited to take part in the Ghoulz 1v1 Feature.
to track scores, determine winners, and publish their nicknames on our Leaderboards.
to detect, investigate, and prevent cheating, fraud, and abuse, and to enforce our terms.
to understand how the Service and the Competition are performing.
to communicate with participants, inviting selected participants to take part in the Ghoulz 1v1 Feature, notifying winners, and coordinating prize fulfillment.
to record a Ghoulz 1v1 Feature session and to enable Ghoulz to publish it, where you and, if you are under 18, your parent or guardian have consented.
to comply with legal obligations applicable to us.
to establish, exercise, or defend legal claims.

We do not sell or rent personal data. However, we engage service providers to help us provide and promote the Service. Some privacy regulators may consider our sharing of data for these purposes as Selling or Sharing of personal data.

Other than a Ghoulz 1v1 Feature recording, we do not share personal data with the promotional partner running our marketing campaign (for example, the YouTuber promoting the Competition). We share personal data only in the following circumstances:

With service providers engaged to help us operate the Service, administer the Competition, verify identity or age, or fulfill prizes, in each case under contract and only to the extent necessary.
With Google, which performs authentication through Google Sign-In. Google processes your sign-in under its own terms and privacy policy, which we do not control.
With the public, through a leaderboard that may display your nickname, score, and ranking during the Competition. The leaderboard does not display your real name, email address, age, or other identifying information.
With Ghoulz, who takes part in the 1v1 session and publishes the recording on Ghoulz's own social media channels. Ghoulz decides independently how the recording is presented and how long it remains available, under Ghoulz's own privacy practices, which we do not control.
With the provider of the third-party communications platform on which the 1v1 session takes place, which is chosen by Ghoulz and receives your camera video and audio under its own terms and privacy policy.
If required to comply with applicable law, legal process, or a valid request from a government authority.
To protect the rights, property, or safety of Playo, our users, or others.
In connection with a merger, acquisition, or sale of company assets, in which case personal data may be transferred as part of that transaction, subject to this Notice.

HOW LONG WILL WE RETAIN PERSONAL DATA?

We keep personal data collected in connection with the Competition only for as long as necessary to run the Competition, verify and announce winners, and complete prize fulfillment. Specifically, we retain Competition-related information (including your Google account information, nickname, age, country of residence, gameplay statistics, and campaign source information) for the duration of the Competition period and for an additional period to support the purpose of the Competition. After we no longer need the data, we will delete or anonymize it – unless we are required to keep it longer to comply with applicable law or to resolve a dispute.

With respect specifically to Ghoulz 1v1 Feature recordings that have been published – we retain such recording, and personal data included in it, for as long as necessary for the purposes described in this notice, our legitimate business needs, and applicable legal requirements.

To determine the appropriate retention period, we consider applicable legal requirements; the amount, nature, and sensitivity of the personal data; the purposes for which it is processed; the risks associated with its continued retention; and whether those purposes can be achieved through other means.

We will also retain personal data after you stop using the Service, where reasonably necessary to comply with law, resolve disputes, prevent fraud or abuse, or enforce this notice and our terms.

We will retain aggregated, non-identifiable information without limitation and will delete or de-identify personal data when it is no longer needed in identifiable form.

CHILDREN’S PRIVACY

Age screening. Before a participant may register for the Competition, we ask for their age. Participants who say they are 13 years of age or older (depending on jurisdictional requirements) may register directly, subject to the rest of this Notice.
Participants under 13. The Competition is not open to anyone under 13 years of age or older (depending on jurisdictional requirements). We do not knowingly collect personal data about such individuals, and if we learn that we have collected personal data about such individuals we will delete it promptly and will not permit that person to participate in the Competition. If you are a parent or guardian and believe we hold personal data about your child without your consent, please contact us.
Use of parents’ devices. We recognize that, in practice, children may access the Service on a parent’s or guardian’s device or account. This Notice, and the age screening described above, apply no matter whose device is used, and we encourage parents and guardians to supervise their children’s use of shared devices.
Leaderboard and win publication for underage participants. If you are under 18 – you are excluded by default from the public leaderboard and from any winners list or win publication. You will only appear on the leaderboard if you affirmatively opt in. This exclusion does not apply to the Ghoulz 1v1 Feature. If you are under 18 and you and your parent or guardian accept an invitation to the Ghoulz 1v1 Feature, the recording of that session will be published even if you have opted out of the public leaderboard.
Ghoulz 1v1 Feature and parental consent. If you are under 18 and are invited to take part in the Ghoulz 1v1 Feature, we will ask for your parent or guardian's email address. We will not record or publish the session unless your parent or guardian has consented by email to the recording, to its publication by Ghoulz on Ghoulz's own social media channels, and to the use of the third-party communications platform on which the session takes place. We take the steps we consider reasonable in the circumstances to satisfy ourselves that the consent comes from a parent or guardian. Your parent or guardian may withdraw that consent as described under Your choices and rights below.

YOUR CHOICES AND RIGHTS

You have the following choices and rights regarding personal data related to you:

You can stop participating in the Competition at any time, and we will stop collecting further personal data from you through the Service. You can also request that we delete your Service account.
You can request access to the personal data we hold about you, subject to certain legal limitations. We will ask you to verify your identity before responding.
You can opt out of appearing on the leaderboards at any time without affecting your eligibility to win a prize.
If personal data we hold about you is inaccurate, incomplete, or out of date, you can ask us to correct or delete it. If we decline your request, we will let you know why.
You can decline or withdraw consent to the Ghoulz 1v1 Feature. You, or your parent or guardian, may decline an invitation to the Ghoulz 1v1 Feature, or withdraw consent at any time, without affecting your participation in the Competition, your position in the Competition Ranking, or your eligibility to win a prize. If the recording has already been published, we will remove it from channels within our control and request its removal from channels that are not.

You can exercise any of these rights by contacting us.

WHERE DO WE STORE PERSONAL DATA?

We store and process data using cloud-based service providers located in the United States.

If you are a resident in a jurisdiction where transfer of personal data related to you to another country requires your consent, then hereby you consent to such transfer.

COOKIES AND TRACKING TECHNOLOGY

Almost every website uses tracking technology of some kind, and ours is no exception. We use cookies, browser local storage, and similar technologies – some of which are operated by third parties – to run the Service, keep it secure, keep you signed in, maintain session state during play, record scores reliably, analyse how the Service is used, and improve the user experience. In this Notice we refer to all of these technologies collectively as “cookies”.

Except for cookies that are strictly necessary to operate the Service, we do not set or activate cookies until you have made a choice through our cookie consent banner, presented when you first visit the Service. If you accept, we begin using the additional cookies detailed as non-essential in our Cookie Consent Banner, including for analytics and advertising. If you decline, only strictly necessary cookies are used.

You can change your choice at any time, as described under How can I manage the use of cookies? below

How do cookies work?

When you first visit a website, it may place cookies on the device or browser you are using. Cookies are small files that allow a website to recognize your browser or device, remember your preferences and settings, understand how the Service is used, and improve the user experience.

The information collected through cookies varies by cookie type and may include, among other things, the pages you visited, the actions you took on the Service, site performance, content you showed interest in, how you arrived at the Service, your account sign-in, and your usage preferences.

When you return to the Service, cookies stored on your device allow it to recognize the browser or device you are using and to provide a more tailored and efficient experience. Cookies may be set by us (“first-party cookies”) or by service providers and business partners acting on our behalf (“third-party cookies”).

We use the information collected through cookies for the following purposes, among others:

to operate and maintain the Service;
to keep you signed in and maintain session state while you play;
to record your scores and gameplay reliably;

We may combine information collected through cookies with other information we process about you, in accordance with the purposes described in this Notice.

Cookies are used in numerous ways. For example, when analyzing trafﬁc to a website or tracking users’ browsing behavior.

Cookies are widely used as they allow a website to recognize a user’s device. Cookies and other similar technologies help the Service to remember the visitors and their activities, for example, the user’s login details, the pages they visited, and how they interacted with the website.

“Session Cookies” are removed from your device once you close your browser session.

“Persistent Cookies” last for longer periods on your device – after you close your browser session.

A user can delete previously set Persistent Cookies manually or conﬁgure the browser settings to delete cookies, as further described below.

First-party cookies are set directly by the website that the user is visiting. For the purpose of this Notice, these are cookies that are set directly by the Website.

Third-party cookies are set by a domain other than the one visited by the user. For the purpose of this Notice, these are cookies that are set by service providers of the Website.

What Are “Similar Technologies”?

Functions usually performed by a cookie can be achieved by other means. This could include, for example, using certain characteristics to identify devices so that visits to a website can be analyzed.

Any technology that stores or accesses information on the user’s device is relevant for this purpose, and therefore it includes, for example, HTML5 local storage, Local Shared Objects and ﬁngerprinting techniques.

Additionally, technologies like scripts, tracking pixels and plugins, wherever these are used – are also considered as Similar Technologies.

Do We Use Tracking Technologies?

We use Tracking Technologies for the following purposes:

Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the Service.
Functionality. To enhance the performance and functionality of our Service.
Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails.
Advertising. To help our third-party advertising partners collect information about how you use the Service and other online services over time, which they use to show you ads on other online services they believe will interest you and measure how the ads perform.

There are various ways in which you can manage and control your cookie settings. If you do not want Cookies to be placed on your device when using the Service – you can do this through our website’s Cookie consent banner, by adjusting your browser settings to manage such Cookies or to notify you when a Cookie is being placed, or by deleting Cookies already stored on your device at any time.

However, if you refuse or delete our cookies, some parts of the Service may not work properly – in particular, you may not be able to stay signed in, your session may not be maintained while you play, and your scores may not be recorded.

Web browsers

You can block, delete, or restrict cookies through the settings of the browser you are using. If you block all cookies, however, some parts of the Service may not work properly, as described above.

Some browsers offer a “Do Not Track” (DNT) signal. There is currently no uniform, agreed standard for interpreting these signals consistently, and the Service therefore does not respond to DNT signals at this time. You can still control the use of cookies through the other means described in this section.

You can also set your browser to notify you when cookies are sent to your device, so that you can choose whether to accept them.

Mobile devices

The Service is a browser-based game and we do not operate a mobile application, so we do not use mobile advertising identifiers. If you play on a mobile device, iOS and Android include advertising identifiers and similar technologies that serve measurement, advertising, and personalization purposes in a manner comparable to cookies on websites. Both operating systems provide controls that let you limit the use of those identifiers, reset them, or manage your advertising preferences.

Email pixels and web beacons

We may use pixels, web beacons, or similar technologies in emails we send you – for example, a winner notification – to confirm that the message was delivered and opened and to improve our communications with you. You can limit these technologies through the settings of the email software or service you use, typically by disabling automatic loading of remote images.

Additional Information

You can also turn off certain third party targeting/advertising cookies by visiting the following link: Network Advertising Initiative.

You can also use this tool to opt-out of Google's tracking cookies.

INFORMATION SECURITY

We use reasonable administrative, technical, and organizational measures designed to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

If you become aware of a potential security issue, please contact us.

CHANGES TO THIS NOTICE

We may update this Notice from time to time. Non-material updates will take effect on the day we publish the new notice. Material changes will take effect a certain number of days after we publish the new notice, as will be provided under our notice updating you of the change.

CONTACT US

If you have questions about this Notice, please contact us at:

Legal Name: Playo Ltd.
Email: [email protected]