Privacy Policy — Play Smart

Last updated: May 20, 2026

Big Ape SAS ("Big Ape", "we", "our", or "us") is a company incorporated in France (RCS Paris 911 849 735), with its registered office at 1 Rue de Stockholm, 75008 Paris, France.

This Privacy Policy applies to your use of the Play Smart mobile application (the "App"), our website https://dolly.gg (the "Website"), and the related services made available through them (together, the "Services").

It explains how we collect, use, store, and protect your personal data, and your rights under applicable US privacy laws, including the California Consumer Privacy Act ("CCPA").

For any questions, please contact us at [email protected].

1. Minimum Age Requirement

You must be 18 years or older to use the Services and withdraw earnings.

Please do not use the Services or provide us with any personal information if you are under 18 years old.

2. Information We Collect

We collect and process the following types of data:

A. Information You Provide Directly

• Contact Information: name, email address, phone number.
• Account Details: username, profile photo, password or authentication data.
• KYC & Identity Data: government-issued ID, selfie/liveness check — collected via our KYC provider (Veriff) for withdrawal eligibility verification.
• Payment Data: withdrawal request details processed via MassPay.
• Communications: support requests, survey responses, complaints, or marketing consents.

B. Information Collected Automatically

• Technical Data: IP address, device ID, operating system, app version, time zone, and language.
• Usage Data: screens viewed, clicks, session duration, in-game actions, crash logs, and analytics.
• Location Data: approximate (country/city level) based on IP address or device settings. We do not collect precise GPS data.

C. In-App Activity Data

• Coin & Earnings Data: coin balance, earning history, conversion history, and withdrawal requests.
• Game Session Data: session duration, actions taken within child games, and performance metrics.
• Anti-Fraud Data: behavioral signals used to detect and prevent abuse of the reward system.
• Third-Party Login Data (optional): if you sign in using Google, we may receive data such as your name and email, as permitted by your account settings.

Note: Play Smart does not collect or process any health or motion data.

3. How We Use Your Information

We use your personal data for the following purposes:

• To create, maintain, and manage your Play Smart account.
• To enable earning of coins through gameplay.
• To process coin-to-USD conversions and withdrawals.
• To verify your identity for KYC compliance before withdrawal.
• To send service messages (e.g., account updates, T&C changes).
• To provide customer support and handle your requests.
• To prevent fraud, misuse, and unauthorized activity.
• To analyze performance and improve the App.
• To send marketing communications (where you have opted in).
• To comply with legal obligations or respond to lawful requests.

We do not sell your personal data.

4. Who We Share Your Information With

We may share your data with:

• KYC Provider (Veriff): to verify your identity before enabling withdrawals. Veriff processes identity documents and biometric data under their own privacy policy.
• Payment Processor (MassPay): to process your withdrawal requests.
• Service Providers: who assist us in hosting, analytics, support, email delivery, or security (under strict confidentiality agreements).
• Legal and Regulatory Authorities: if required by law or to protect our rights or users.
• Business Successors: in the event of a merger, acquisition, or sale of assets.

We do not share your personal data with third parties for their independent marketing without your explicit consent.

5. Data Storage

Your data is stored on servers located in the United States and may be processed by service providers operating in the US or other countries.

We ensure all third-party service providers are contractually bound to protect your data and use it only for the purposes we specify.

You can request details about our data storage practices by contacting [email protected].

6. Data Retention

We keep your data only as long as necessary for the purposes described in this Policy or as required by law.

When no longer needed, we securely delete or anonymize your data.

If you delete your Play Smart account, most of your data will be erased within 30 days, unless retention is legally required (e.g., for fraud prevention, KYC compliance, or accounting).

KYC records may be retained for longer periods as required by applicable regulations.

7. Data Security

We use industry-standard technical and organizational measures to safeguard your data against unauthorized access, alteration, disclosure, or destruction.

However, no system is entirely secure; you use the Services at your own risk.

8. Cookies and Tracking

We use cookies and similar technologies on the Website and App for analytics, personalization, and advertising.

You can manage cookie preferences in your browser or device settings.

For full details, see Annex 2 – Cookies below.

9. Your Privacy Rights

Depending on your state of residence, you may have the following rights:

• Right to Know: request information about the personal data we collect, use, and share about you.
• Right to Delete: request that we delete your personal data, subject to certain exceptions.
• Right to Correct: request that we correct inaccurate personal data we hold about you.
• Right to Opt Out of Sale: we do not sell your personal data. If this changes, you will have the right to opt out.
• Right to Non-Discrimination: we will not discriminate against you for exercising any of your privacy rights.

California residents may exercise rights under the California Consumer Privacy Act (CCPA). Residents of other states (Virginia, Colorado, Connecticut, Texas, and others) may have similar rights under their applicable state privacy laws.

To exercise any of these rights, contact [email protected] or use the in-app help section:

Profile → Settings → Help → Contact Us → Delete Account.

We may request verification of your identity before processing certain requests. We will respond within 45 days as required by applicable law.

10. Complaints

If you believe we have misused your data, please contact us at [email protected] and we'll respond promptly.

You also have the right to file a complaint with your state's Attorney General or the Federal Trade Commission (FTC) at www.ftc.gov.

11. Links to Third-Party Services

The App or Website may link to third-party websites or services (including Veriff and MassPay).

We are not responsible for their content, data handling, or privacy practices.

Please review their privacy policies before sharing your data with them.

12. Changes to This Policy

We may update this Privacy Policy periodically.

Any changes will be posted on https://dolly.gg and within the App.

Please check this page regularly for updates.

13. Contact

Questions, comments, or requests regarding this Policy should be sent to:

Annex 1 – Summary of Data Uses

Category	Example Data	Purpose
Account & Profile Data	Name, username, photo	To create and manage your Play Smart account
Contact Data	Email, phone	To send notifications, support replies
KYC & Identity Data	Government ID, selfie	To verify identity before withdrawal
Earnings & Withdrawal Data	Coin balance, USD withdrawals	To process rewards and track user activity
Technical & Usage Data	Device, IP, analytics	To improve App and detect fraud
Marketing Preferences	Consent records	To send updates and offers
Legal Records	Logs, access data	To comply with legal obligations

Annex 2 – Cookies

What are cookies?

Cookies are small text files stored on your device when you visit our Website or use our App. They help us recognize your device and improve your experience.

Types of cookies we use:

• Essential Cookies: required for site functionality and security.
• Analytics Cookies: to understand how users interact with our Services (e.g., Google Analytics).
• Advertising Cookies: to deliver relevant offers or content.

You can manage or disable cookies via your browser settings. Note that disabling cookies may limit some features.