PlayLoop

Privacy Policy

A. Privacy Policy

Last Updated: 21 October 2026

Effective Date: 11 October 2026

This Privacy Policy describes how Clocktone Ltd. (“Company,” “we,” “us,” or “our”) collects, uses, shares, and protects information when you use the Playloop mobile application (the “App”) and related services (collectively, the “Services”).

By using the Services, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our practices, please do not use the Services.

1. Who We Are

Playloop is operated by:

Clocktone Ltd.
Karaiskaki 6, City House, 3032 Limassol, Cyprus

For privacy inquiries, contact us at: legal@clocktone.io

For users in the European Economic Area (EEA), Clocktone Ltd. is the data controller responsible for your personal data.

1.1 Privacy Contact

If you have questions about this Privacy Policy or our data practices, or if you wish to exercise your privacy rights, please contact us at: privacy@clocktone.io. When contacting us, please specify that your inquiry relates to the Playloop app.

2. Overview of Our Data Practices

Playloop is a rewards application where you earn virtual coins by playing games, and completing offers. You can redeem your earnings for gift cards or PayPal payouts.

Key points about our data practices:

3. Information We Collect

3.1 Account and Profile Information

What we collect:

Why we collect it:

3.2 Device Information

What we collect:

Why we collect it:

3.3 Transaction and Earning Data

What we collect:

Why we collect it:

3.4 Location and Device Information

What we collect:

Why we collect it:

When you redeem Rewards, we collect your precise GPS location to detect and prevent fraud (this requires your location permission). Apart from that, we do not collect precise GPS location unless you grant location permission for ad personalization.

3.5 Biometric Information

What we collect:

When we collect it:

Why we collect it:

How we handle it:

For users in Illinois, Texas, and Washington, please review Appendix A: Biometric Information Privacy Notice for additional required disclosures.

3.6 Usage and Behavioral Data

What we collect:

Why we collect it:

4. How We Use Your Information

4.1 Service Provision

We use your information to:

Legal basis (GDPR): Performance of contract

4.2 Fraud Prevention and Security

We use your information to:

Legal basis (GDPR): Legitimate interests (protecting our platform and users)

4.3 Advertising

We use your information to:

Legal basis (GDPR): Consent (where required) or legitimate interests

4.4 Communications

We use your information to:

Legal basis (GDPR): Performance of contract (transactional) or consent (marketing)

Push Notification Categories:

4.5 Automated Decision-Making and Profiling

We use automated systems for fraud detection and prevention. This includes:

How it works:

Your rights:

Legal basis (GDPR): Art. 22 para. 2 lit. a (necessary for contract) and legitimate interests

5. How We Share Your Information

We share your information with the following categories of third parties:

5.1 Advertising Partners

We share device identifiers, advertising IDs, and usage data with advertising networks to display ads and measure their effectiveness.

Partners include:

Data shared: Device information, advertising ID, approximate location, ad interaction data

Your choices: You can reset your advertising ID or opt out of personalized advertising through your device settings. Where required by law, we will obtain your consent before sharing data for advertising purposes.

5.2 Analytics and Attribution Partners

We use Adjust for deep linking and install attribution.

Data shared: Device information, app install/open events

5.3 Offerwall Partners

When you use the Offerwall feature, we share data with Tapjoy.

Data shared: User identifier, completed offer information, reward amounts

5.4 Infrastructure Partners

We use third-party infrastructure to host and operate our Services:

These providers process data on our behalf under data processing agreements.

5.5 Payment and Reward Partners

To fulfill your reward redemptions, we share data with:

Data shared: Reward amount, email and name (only if you provide them); for PayPal payouts, the email address of your PayPal account

5.6 Legal and Safety Disclosures

We may disclose your information when required to:

6. Cookies and Tracking Technologies

The App does not use browser cookies. However, we use the following technologies:

7. Data Retention

We retain your information for the following periods:

Data TypeRetention Period
Account data (Client ID, earnings)Duration of account + 12 months
Transaction/payout records7 years (tax compliance)
Facial geometry data (biometric templates)4 months
Facial photos1 month
Usage data12 months
Ad impression dataUntil earnings are credited
Push notification tokensUntil unregistered or marked invalid
Your Coins and Rewards1 year from credit date (then expire)

After these periods, we delete or anonymize your data unless we have a legal obligation to retain it.

8. Your Rights and Choices

8.1 Your Rights Under GDPR (EEA Users)

If you are located in the European Economic Area, you have the following rights:

To exercise these rights: Contact us at legal@clocktone.io. We will respond within 30 days.

Complaints: You have the right to lodge a complaint with a supervisory authority in your country of residence.

8.2 Your Rights Under Other US State Laws

If you reside in a US state with comprehensive privacy laws, you may have additional rights. These states currently include:

StateLawKey Rights
VirginiaVCDPAAccess, delete, correct, opt-out of targeted ads
ColoradoCPAAccess, delete, correct, opt-out, universal opt-out signals
ConnecticutCTDPAAccess, delete, correct, opt-out, universal opt-out signals
OregonOCPAAccess, delete, correct, opt-out, list of third parties
TexasTDPSAAccess, delete, correct, opt-out of targeted ads
MontanaMCDPAAccess, delete, correct, opt-out
DelawareDPDPAAccess, delete, correct, opt-out, list of third-party categories
IowaICDPAAccess, delete, opt-out
TennesseeTIPAAccess, delete, correct, opt-out
IndianaICDPAAccess, delete, correct, opt-out
New JerseyNJDPAAccess, delete, correct, opt-out
New HampshireNHDPAAccess, delete, correct, opt-out
NebraskaNDPAAccess, delete, correct, opt-out
MarylandMODPAAccess, delete, correct, opt-out
MinnesotaMCDPAAccess, delete, correct, opt-out

To exercise your rights: Contact us at legal@clocktone.io. We will respond within the timeframe required by your state’s law.

Right to Appeal: If we deny your request, you have the right to appeal our decision by emailing us at legal@clocktone.io with “Privacy Appeal” in the subject line.

Authorized Agents: You may designate an authorized agent to make requests on your behalf. We may require verification that you authorized the agent.

9. Security Measures

We implement appropriate technical and organizational measures to protect your information, including:

While we strive to protect your information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

10. International Data Transfers

Your information may be transferred to and processed in countries outside your country of residence, including:

For transfers from the EEA to countries without adequate data protection, we rely on:

11. Children’s Privacy

The Services are not intended for minors under the age of 18.

We do not knowingly collect personal information from minors under the age of 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at legal@clocktone.io. We will take steps to delete such information.

12. Direct Marketing

Current Practice: We do not currently send marketing communications to users.

We will not send marketing emails unless you have given us an explicite consent. Push notifications within our App are limited to account-related updates.

Future Marketing (If Implemented): If we begin sending marketing communications in the future:

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

Your continued use of the Services after changes become effective constitutes acceptance of the revised Privacy Policy.

14. Contact Us

If you have questions about this Privacy Policy or our data practices, contact us at:

Clocktone Ltd.
Email: legal@clocktone.io
Website: https://clocktone.io\ Playloop website: https://getplayloop.com

B. Additional Provisions for California Users

This Part B for California consumers supplements the remaining provisions of our Privacy Policy and applies exclusively to individuals who reside in California. It explains how we collect, use and share your data and how we comply with the California Consumer Privacy Act and its implementing regulations (“CCPA”).

1. Personal Information We Collect

We may obtain from California residents through our apps the personal information described in Section 3 of this Privacy Policy. Further details are set out in the table below.

Under the CCPA, some of our disclosures of personal information qualify as “sales” or “sharing”. We disclose the following categories of personal information for purposes of cross-context behavioral advertising or otherwise sell them:

Personal information that is sold or shared for cross-context behavioral advertising may be received by third-party advertisers and analytics providers. We disclose this personal information to show you relevant ads, for marketing, advertising and certain types of analytics, to optimize our services, to personalize content or serve ads that may be more relevant to your interests, and to perform other advertising-related services such as reporting, attribution, analytics and market research, or for similar purposes. We have no actual knowledge that we sell or share the personal information of consumers under 16 years of age.

Category of Personal Information: Identifiers, for example name, telephone number, email address, mailing address, third-party accounts, unique personal identifier, online identifier and IP address.

Customer Records, including any personal information described in subdivision (e) of Section 1798.80 of the California Civil Code, for example your name, signature, address, employment-related information and financial information.

Purposes for Collection, Use, and Disclosure:

Category of Personal Information: Internet or other electronic network activity information, for example browsing history, search history, operating system and information about your interactions with our applications or advertisements.

Purposes for Collection, Use, and Disclosure:

Category of Personal Information: Geolocation data, including your approximate location as derived from your IP address or your mobile device.

Purposes for Collection, Use, and Disclosure:

Category of Personal Information: Inferences drawn from collected personal information, for example a consumer profile reflecting preferences, characteristics and interests.

Purposes for Collection, Use, and Disclosure:

Category of Personal Information: Sensitive personal information

For details, please refer to our Facial Mapping Notice and Consent Policy below.

Purposes for Collection, Use, and Disclosure:

2. California Privacy Rights

The CCPA grants you the following rights with respect to your personal information:

2.1 Right to Know

You may request information about the personal information we have collected about you, in particular:

2.2 Right to Delete

You may ask us to delete the personal information we have collected from you. Certain exceptions apply.

2.3 Right to Correct

You may ask us to correct personal information we hold about you if you believe it is inaccurate.

2.4 Right to Opt-Out of Sales and Sharing

You may opt out of the sale of your personal information and ask us not to share it for cross-context behavioral advertising. To do so, please use the “Do not Sell or Share my Personal Information” link in the Settings section of our apps.

2.5 Right to Non-Discrimination

Exercising your rights will not lead to any discrimination against you by us.

2.6 Exercising Your Rights

Please send your request to exercise your rights by email to privacy@clocktone.io using the subject line “CCPA and Covered State Rights Request.” Before we process your request, we may need to verify your identity. As a rule, we do this by matching sufficient information provided by you with the information we hold about you in our systems. In certain circumstances, we may decline a request if we are unable to verify your identity.

Questions or concerns may also be sent by email to privacy@clocktone.io. In certain circumstances, an authorized agent may submit requests on your behalf, provided that (i) you provide sufficient evidence that the requestor is an authorized agent with your written permission to act on your behalf and (ii) you successfully verify your own identity with us.

We will respond to your request within the time period permitted under applicable law. If we need more time, we will inform you in writing of the reason and the extension period.

2.7 California “Shine the Light” Law

Under California’s “Shine the Light” law, California residents may request certain information about our disclosure of certain personal information to third parties for those third parties’ own direct marketing purposes. If you are a California resident, you can request information about our compliance with the Shine the Light law by contacting us at privacy@clocktone.io. Please include “California Shine the Light Request” in the subject line, together with your name, street address, city, state and ZIP code. We are only required to respond to one request per customer per calendar year.

C. Additional Provisions for Individuals Who Reside in Covered States

This Part C supplements the remaining provisions of our Privacy Policy and applies exclusively to individuals who reside in US states with comprehensive privacy laws that apply to us (“Covered States”). Residents of California should refer to the California-specific disclosures in Part B above.

1. Privacy Rights

Depending on the Covered State in which you reside, you may have certain rights regarding your personal data, as described below. To exercise any of these rights, please send your request by email to privacy@clocktone.io. Before we can process your request, we may need to authenticate your identity. For this purpose, you will be asked to verify your identity in accordance with applicable law.

1.1 Right to Know

You may confirm whether we process your personal data, access your personal data and obtain a copy of the personal data you provided to us in a portable format.

Residents of Oregon may also request a list of the third parties to which we disclose personal data.

Residents of Delaware may request a list of the categories of third parties to which we disclose your personal data.

1.2 Right to Delete

You may ask us to delete your personal data. We may, however, retain certain personal data where applicable law permits this.

1.3 Right to Correct

You may ask us to correct inaccuracies in your personal data.

1.4 Right to Opt-Out

You may opt out of the sale of your personal data and of the use of your personal data for targeted advertising. To do so, please use the “Do not Sell or Share my Personal Information” link in the Settings section of our apps.

1.5 Right to Appeal

You may appeal our decision by email to privacy@clocktone.io.

1.6 Authorized Agents

Depending on your state of residence, you may be entitled to designate an authorized agent to submit certain privacy rights requests on your behalf.

1.7 Overview of main US states privacy rights

StateLawKey Rights
VirginiaVCDPAAccess, delete, correct, opt-out of targeted ads
ColoradoCPAAccess, delete, correct, opt-out, universal opt-out signals
ConnecticutCTDPAAccess, delete, correct, opt-out, universal opt-out signals
OregonOCPAAccess, delete, correct, opt-out, list of third parties
TexasTDPSAAccess, delete, correct, opt-out of targeted ads
MontanaMCDPAAccess, delete, correct, opt-out
DelawareDPDPAAccess, delete, correct, opt-out, list of third-party categories
IowaICDPAAccess, delete, opt-out
TennesseeTIPAAccess, delete, correct, opt-out
IndianaICDPAAccess, delete, correct, opt-out
New JerseyNJDPAAccess, delete, correct, opt-out
New HampshireNHDPAAccess, delete, correct, opt-out
NebraskaNDPAAccess, delete, correct, opt-out
MarylandMODPAAccess, delete, correct, opt-out
MinnesotaMCDPAAccess, delete, correct, opt-out

2. Miscellaneous

If you submit a privacy rights request, we will retain the personal data provided in connection with that request for recordkeeping purposes.

Exercising these rights will not lead to any discrimination against you. We will not deny you any services or charge you different prices in retaliation for exercising your privacy rights.

Effective Date: 11 October 2026

1. Introduction

This Facial Mapping Notice and Consent Policy ("Policy") explains how Clocktone Ltd. ("Company", "we", "our" or "us") collects, uses, stores, and protects facial mapping data obtained through the FaceTec software ("FaceTec") when you use our App (the “App”). To the extent there is any inconsistency between this Policy and the above Privacy Policy, this Policy controls with respect to facial mapping data and photos collected through the FaceTec software. This Policy is intended to comply with any federal, state, or local laws that may apply to the facial mapping data. By proceeding to use the FaceTec software, you confirm that you are not doing so from within a jurisdiction where such use is prohibited.

2. Collection of Facial Mapping Data and Photos

In order to use the redeeming feature within the App for the first time, you will need to use your device’s camera and software provided by FaceTec that is embedded within the App to scan your face and provide us with facial mapping data that is unique to you, as well as a photo of your face. We use the facial mapping data and photo for the following purposes:

3. Storage and Protection of Facial Mapping Data and Photos

Your facial mapping data and photo is stored in our rented server space on the servers of Google Cloud Services provided by Google Cloud EMEA Ltd. (70 Sir John Rogerson's Quay, Dublin 2, Ireland) (please see our general privacy policy in this regard). We implement robust security measures, including encryption and secure storage, to protect your information from unauthorized access, disclosure, or misuse.

Your facial mapping data is stored for up to 4 months and then is securely deleted. Your photo is stored for up to 1 month and then is securely deleted.

4. Sharing of Facial Mapping Data and Photos

Other than as described in this Policy, we do not sell, lease, trade, or otherwise profit from your facial mapping data or photos. The FaceTec software runs within our own environment, and we do not share your facial mapping data or photos with FaceTec. As noted above, the facial mapping data and photos are stored on Google Cloud Services. We may disclose your facial mapping data and photos when required by law, regulation, or legal process, such as a court order or subpoena.

5. Your Rights

Depending on the jurisdiction in which you reside, you may have the following rights regarding your Facial Mapping Data:

6. How to Exercise Your Rights

To exercise any of your rights or if you have any questions about this Policy, please contact us at:

Questions?

For any inquiries and additional questions about processing personal data please contact privacy@clocktone.io. Our contact details may also be found above or in the imprint under the App’s settings menu.