Last Updated: 2 July 2025
1. Scope and Application of the Policy
1.1. We will collect and process your personal data only when necessary or relevant to our interactions with you. This Privacy Policy (the "Policy") outlines our privacy practices regarding the collection, processing, use, disclosure, transfer, retention, storage, and disposal of your Personal Data when we provide you with our services ("Our Services").
1.2. By accepting this Policy, you consent to the collection, processing, use, disclosure, transfer, retention, storage, and disposal of your Personal Data as described below.
1.3. "Personal Data" refers to your individual personal information (whether accurate or not) that can identify you, either alone or in combination with other information we have or may obtain. The Personal Data we collect and process may include:
(a) Your first and last name;
(b) Email address;
(c) Mobile number;
(d) Merchant affiliation and/or IP address;
(e) Cookies and/or statistical/analytical data (such as browsing behavior, to the extent it can identify you);
(f) Documentation to verify the accuracy of provided information (e.g., proof of identity);
(g) Your social media links or public profiles, and any personal information visible thereon, provided during customer support interactions;
(h) Account passwords you create;
(i) Any other personal information provided while using Our Services.
1.4. This Policy applies only to Personal Data in our possession or under our control.
1.5. We collect and process your Personal Data to enable you to make purchases from us, your mobile network operator, relevant third-party payment channel operators ("Payment Channels"), or merchants/suppliers of digital products ("Partners") via mobile platforms, server/database applications, or websites operated by us ("the Platform").
1.6. We reserve the right to amend this Policy from time to time without prior notice. Amendments will be published on the Platform and take effect on the date specified below. You can check the "Last Updated" date below to see if revisions have occurred. We recommend reviewing this Policy periodically. Continued use of Our Services after an amendment constitutes your acknowledgment and acceptance of the changes.
2. Collection of Personal Data
2.1. We collect your Personal Data when you use Our Services or communicate with us. In such cases, you may provide Personal Data directly, or it may be shared with us by our affiliates, subsidiaries, Payment Channels, or Partners based on your consent to those third parties.
2.2. You may also submit Personal Data via other methods, including:
(a) Responding to our communications;
(b) Through social media or online forums;
(c) Participating in our offers, programs, or promotions;
(d) Signing up for our newsletter;
(e) Logging into Our Services with a social media account or credentials from a third-party platform (e.g., Facebook, Gmail), where we collect the Personal Data you agree to share via that platform.
2.3. We also collect transaction information (such as purchase amount, date, and details of digital content, goods, or services purchased, referred to as "Transaction Data") to pursue our legitimate interests and fulfill contractual obligations to provide you access to Our Services and/or the Platform. In most cases, Transaction Data is not considered Personal Data as it does not reveal your identity. However, to the extent your identity can be determined from Transaction Data, it will be treated as Personal Data under this Policy. By using Our Services and/or the Platform, you consent to our collection of such Transaction Data.
2.4. You must provide accurate and non-misleading information. We reserve the right to request documentation to verify the information you provide.
3. Use and Disclosure of Personal Data
3.1. Your data will be processed for the following purposes:
(a) Transaction processing and content delivery;
(b) Marketing and promotional campaigns;
(c) Other permitted uses and disclosures.
3.2. Transaction Processing and Content Delivery
3.2.1. As an online distributor of digital content and provider of related services, we use and share your Personal Data with third parties (including affiliates, subsidiaries, Payment Channels, and Partners) to provide Our Services or as necessary for doing business with you.
3.2.2. Specifically, your Personal Data may be processed for:
(a) Facilitating your use of Our Services;
(b) Processing and verifying online transactions and payments on the Platform;
(c) Resolving transaction-related disputes;
(d) Mitigating fraud;
(e) Protecting our legitimate interests;
(f) Enforcing contractual rights;
(g) Providing information you have requested.
3.2.3. Your Personal Data may also be shared for the above purposes with:
(a) The Partner from whom you purchase content;
(b) The Payment Channel you select for payment.
3.3. Marketing and Promotional Campaigns
3.3.1. We occasionally run marketing and promotional campaigns to reward top spenders on the Platform in specific countries, for specific Partners, or in other categories. To this end, we may analyze your Transaction Data and use your Personal Data to contact you and award prizes (typically free Partner or Payment Channel credits or other gifts). These campaigns are conducted by us, and your Personal Data will not be shared with third parties for such purposes. To opt out of receiving gifts, please contact us.
3.3.2. If you opt in to receive marketing communications, we may use your Personal Data to notify you about campaigns related to Our Services or those conducted jointly with Partners, Payment Channels, or third parties, and may share your name, email, and/or mobile number with them for this purpose. To opt out of marketing communications or prevent such disclosure, please contact us. You may also unsubscribe from marketing emails by clicking the unsubscribe button provided.
3.4. Other Permitted Uses and Disclosures
3.4.1. You agree we may use your Personal Data for:
(a) Maintaining and securing your user accounts with us;
(b) Notifying you of account or transaction matters requiring your attention;
(c) Processing service requests, resolving issues, and responding to queries/feedback;
(d) Managing internal security or risk management mechanisms;
(e) Conducting statistical analysis, market, or customer research (including surveys), and may share your Personal Data with third-party service providers for such purposes;
(f) Improving your customer care experience;
(g) Notifying you of material changes to this Policy or our Terms and Conditions.
3.4.2. You understand we may disclose your Personal Data to affiliates, subsidiaries, Partners, Payment Channels, or other parties as permitted/required by law (e.g., government authorities), for:
(a) Negotiating mergers, sales of stock/assets, financing, acquisitions, divestitures, or dissolution of all/part of our business;
(b) If we believe disclosure is reasonably necessary to: (i) comply with laws/regulations/legal processes; (ii) assist in investigations/proceedings; (iii) protect the security of Our Services, us, users, or the public from harm/illegal activities.
4. Your Choices, Rights, and Exceptions
4.1. Where we process your Personal Data solely based on your consent, you have the right to request its removal or withdraw consent. To remove your Personal Data or object to its use/processing for the above purposes, please contact us. Note that depending on the request, removing data or withdrawing consent may prevent us from continuing to provide Our Services or process/complete your Platform transactions.
4.2. You have the right to access, update, or request correction of your provided Personal Data at any time. To access, update, or correct your Personal Data, contact us. We may charge a reasonable administration fee, which we will inform you of promptly based on the request nature.
5. Retention and Disposal of Data
Your Personal Data will be retained for as long as necessary to fulfill the purpose of collection and until no longer required for legal or business purposes. Thereafter, we will dispose of it by preventing further access/processing, including deletion or irreversible anonymization.
6. Security
We take reasonable measures to safeguard your Personal Data against loss, misuse, modification, unauthorized access/disclosure, alteration, or destruction. While no internet transmission/storage is fully secure, we have implemented administrative, organizational, technical, and physical security measures, including:
(a) Limiting access to authorized/necessary personnel;
(b) Implementing technical solutions for information security;
(c) Continuously monitoring and reviewing protection measures;
(d) Other measures required by laws in your jurisdiction.
7. International Transfer of Data
7.1.1. We operate internationally. You acknowledge that we may store your data in different countries per applicable data localization regulations or share your Personal Data with recipients (e.g., Partners, Payment Channels, affiliates/subsidiaries) located outside the collection country to provide Our Services, process transactions, or fulfill other purposes under this Policy.
7.1.2. In such cases, we ensure overseas recipients provide a protection standard comparable to the EU General Data Protection Regulations and local data protection laws in your jurisdiction.
8. Collection of Statistical Data
8.1. We collect, and allow third parties (including AWS, Facebook, Google) to collect, statistical information about your website use and online activities on the Platform using "cookies" and similar technologies. This information is anonymous (not identifying you) and includes page visits, access times/dates, and browser types, collected for analysis to improve the Platform and Our Services.
8.2. "Cookies" are browser features storing small data on your device when visiting a website, enabling us to recognize devices/browsers to personalize content. Cookies do not identify you unless you provide personally identifiable information. You can manage/delete cookies via browser settings.
8.3. Your statistical data may be shared with third-party partners: (i) for advertising; (ii) to deliver/optimize services; (iii) to market goods/services of interest; (iv) to improve their offerings to you.
9. Use by Minors
9.1. Our Services are not directed at minors (persons under the age of majority in your country). If you are a minor, you may use Our Services/Platform only with the consent, permission, and supervision of a parent/guardian, subject to your country's age restrictions on digital content.
9.2. If you are a parent/guardian supervising a minor using Our Services and accept this Policy on their behalf, you consent to processing their Personal Data as per this Policy.
10. Links to Other Websites
The Platform may contain links to third-party websites not maintained by us. When visiting these sites, please read their privacy policies, as we are not responsible for their content, use, or privacy practices.
11. Contact Us
11.1. To contact us regarding this Policy or your Personal Data (including withdrawing consent, opting out of gifts/marketing, requesting access/updates to data, or exercising rights under this Policy or data protection laws), please email our Data Protection Officer.