Solitaire Privacy Notice

Effective date: Nov 30^th 2022

At Solitaire, we recognise that privacy is important. This Privacy Notice (“Notice”) describes how HP Studio Corporation (“we”, “our” or “us”) collects, processes, and protects personal data about you through the Solitaire App (the “App”) and all other HP Studio Corporation websites and applications (collectively, the “Services”) that link to this Notice. This Notice also describes your rights in relation to your personal data. 

Please take the time to read these Terms carefully. If you have any questions about this Notice or how we use your data, our details are provided in the “Contact Us” section below. 

This Notice may be provided in more than one language. In the event of any conflict, where permitted under local law, this English language version of the Notice shall prevail.

1. PERSONAL DATA THAT WE COLLECT

Personal data is information, or a combination of pieces of information that could reasonably allow you to be identified. We collect personal data from a variety of sources, including from you directly (e.g., when you contact us), information we generate about you in the course of our relationship with you, and information we collect about you from other sources, including commercially available sources, such as public databases (where permitted by law), and third-party services (such as third-party social media companies, advertising partners, and analytics providers). 

We may also collect certain personal data about you as required by law, or as a consequence of our contractual relationship. Failure to provide this information may prevent or delay the fulfilment of these obligations. We will inform you at the time when your information is collected whether certain data is compulsory and the consequences of the failure to provide such data. 

We may collect the following categories of personal data from and about you:

1. Personal details (e.g., nickname, image etc.);
2. Contact details (e.g., phone number, email address);
3. Authentication and identification information (e.g., user identification number);
4. Transactional information (e.g., information relating to any of your requests, queries, or complaints);
5. Content uploaded, published, broadcasted or streamed on the Services by you (e.g., videos, music, pictures, files, texts, articles); 
6. certain personal information made available by other users about you via their use of the Services, such as user feedbacks on the content you made available on the Services;
7. Information we collect automatically from you including internet or other electronic network activity information, such as the data we receive when you interact with our app (e.g., your sharing history, log data, download history or actions you take within the app) or information about your device (e.g., your network type, app version, device settings, device ID, Android ID, IMEI and system language and regions), and the information about the other apps you have installed; 
8. subject to requirements under applicable law, coarse geolocation data, such as location information (including your GPS and latitude and longitude information) we receive about you (e.g., based on your Internet Protocol (IP) address, Wi-Fi SSID, etc.); We will only collect your GPS information with your active consent, you can withdraw your consent at any time by turning off location permissions.; and
9. Any information you include in your publicly visible app profile or which you or others make available to us or the public (e.g., should you choose to register your Solitaire account using your third party account details (e.g., Meta, Google), we may receive your username and certain personal information on your public profile from you or the third party platforms).

2. HOW WE USE YOUR PERSONAL DATA

We may use the personal information we collected about you as follows:

a. In accordance with, and to perform, our contract with you, we may use your personal information:

• to communicate with you;
• to set up and manage your Solitaire account; 
• to infer other information about you;
• with your permissions, to deliver location-specific services to you, such as nearby Solitaires; 
• to process your requests, including performing obligations in the course of or in connection with our provision of the Services;
• to enable and facilitate the social interactions on the Services, such as to allow interaction between you and other users through the Services and for you and other users to share, download, and otherwise interact with the content on the Services;
• to protect your safety by reviewing user content and other relevant data for breach of our terms, policies and guidelines;
• to address and resolve technical issues and bugs;
• to respond to, handle and process queries, requests, applications, complaints and feedbacks from you;
• to manage your relationship with us;
• to enforce our terms, policies and guidelines; and
• for any other incidental business purposes related to or in connection with the above.

b. In order to comply with our legal obligations and as necessary to perform tasks in the public interest or to protect the vital interests of our users and other people, we may use your personal information to help us prevent, monitor and respond to abuse, fraud, illegal activity and other potentially harmful content.

c. In accordance with our legitimate interests to provide an effective platform, we may use your personal information:

• to operate, maintain, enhance and improve the Services, such as to carry out data analytics in order to ensure the safety of the Services; 
• to make statistical and other analysis about the use of our Services;
• to share with you any updates, upgrades, promotions and notices concerning the Services;
• to assist with our product and service development;
• to verify your identity, for example, to address your request; and
• to take the appropriate technical and organizational security measures in order to protect your personal information.

d. We may also process your personal information for any other purposes shared with you when we collect your information or in accordance with your consent.

The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

3. HOW AND WHEN WE SHARE YOUR PERSONAL DATA

a. Service Providers. We may share your personal information with our service providers that support our business, such as cloud services providers, analytics vendors or telecommunication services providers.

b. Our Corporate Group. We may share your personal information with other members, subsidiaries or affiliates of our corporate group where it is necessary to make available the Services in accordance with our terms, policies and guidelines.

c. Law Enforcement/Legal Obligation. We may share your personal information with law enforcement agencies, public authorities or other third parties if we consider that we are legally required to do so or if such use is reasonably necessary to:

• comply with a legal process or request;
• enforce our terms, policies and guidelines, including investigation of any potential violation;
• detect, prevent or otherwise address abuse, fraud, illegal activity or security or technical issues; or
• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).

d. Sale or Merger. We disclose your information to third parties:

• in the event that we sell or buy any business or assets (for example, as a result of liquidation, bankruptcy or otherwise). In such transactions, we will disclose your information to the prospective seller or buyer of such business or assets; or
• if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

4. INTERNATIONAL DATA PROCESSING & TRANSFER

We will store your personal information in Singapore.

Where permitted under applicable laws, your personal data may be transferred to and processed outside of your jurisdiction, including, if you are an EU or UK-based user of the Services, in a country that is not regarded as ensuring an adequate level of protection for personal data under European Union law / by the European Commission or under UK law / by the UK Government.

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protection for your personal data. For more information on the appropriate safeguards in place, and to obtain a copy of such safeguards, please contact us at the contact information below.

5. DATA SECURITY AND RETENTION 

We implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal data we process. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal data. We evaluate these measures on a regular basis to ensure the security of the processing.

We retain your personal data for as long as we have a relationship with you. After our relationship has ended, we will delete or anonymize your personal information within a reasonable period of time, unless otherwise required or permitted by law. We may also retain records to investigate or defend against potential legal claims, deal with any complaints or official enquiries or investigations regarding the Services, or maintain business records for analysis and/or audit purposes.

6. YOUR RIGHTS OVER YOUR PERSONAL DATA

You have certain rights regarding the personal data we hold about you, subject to local law. These may include the following rights:

1. access – confirm with whether your personal data is processed by us, and if it is, to request a copy of your personal data and information relating to how it is processed;
2. rectify – request any inaccuracies in the personal data we hold about you be corrected or any incomplete personal data we hold about you to be completed;
3. erase – in certain circumstances, request that we erase your personal data from our records;
4. restrict – in certain circumstances, request that your personal data is no longer processed by us;
5. object – where we process your personal data on the basis of our legitimate interests, you have the right to object to this. However, we may continue to process your personal data if you have objected where we have compelling legitimate grounds to continue such processing or for the establishment, exercise or defence of legal claims;
6. portability / transfer – in certain circumstances, request to receive personal data concerning you or transmit that data to you or another third party you have chosen;
7. withdraw your consent – where we are relying on your consent to process your data, then you can withdraw your consent at any time; and 
8. lodge a complaint – you have the right to lodge a complaint with your local data protection authority. 

We also encourage you to contact us to update or correct your information if it changes or if the personal data we hold about you is inaccurate. Please note that we may require additional information from you in order to honour your requests. 

If you would like to discuss or exercise any rights you may have under law, please contact us at the contact details below. 

7. CHILDREN’S INFORMATION

The Services are not directed to children, and we do not knowingly collect any personal data from children under the age of 13 (or such legally required age of consent as defined under applicable laws) or knowingly allow such person to register on our Services. In the event that we are notified that we have collect personal data from a child of or under the age of 13 (or such legally required age of consent as defined under applicable laws) without parental consent, we will suspend the account and delete relevant information as quickly as possible. If you believe that we might have any information from a child of or under 13 (or such legally required age of consent as defined under applicable laws), please contact us at the contact details provided below

8. CONTACT US

If you have questions or concerns regarding the way in which your personal data has been used or would like to exercise any right, please contact us at [solitaire.HPstudio@gmail.com]. 

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the data protection authority of your country of residence.

9. CHANGES TO THE NOTICE

You may request a copy of this Notice from us using the contact details set out above. We may modify or update this Notice from time to time. 

If we change this Notice, we will notify you of the changes. Where changes to this Notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. to object to the processing) or to terminate your use of the Services.

10. Indonesia-Specific Terms

If you are using our Services in Indonesia, the following additional terms shall apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Notice, the following terms shall prevail.

• Minimum age. The Services are only intended for users of more than 14 years old (including) in Indonesia. 
• Age, Parental and Guardian Consent. By using the Services, you represent that you are at least 21 years of age or married or not under guardianship. If you are below 21 years old and you are not married, or under guardianship, you represent and warrant that you have obtained consent from your parent or legal guardian to use the Services. If you do not obtain consent from your parent or legal guardian, or your parent or guardian is not willing to give their consent, you must cease using the Services.