Privacy Policy

Welcome to KeepPlay Engine (the “App”, “Platform”, “we”, “us”, or “our”). The App is operated by RAVADO TECH LTD, a company registered in England & Wales with its registered office at 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.

This Privacy Policy describes how we collect, use, store, share, and protect personal data when you download, install, access, or use the KeepPlay Engine mobile application, website, and any related services (collectively, the “Services”).

By using our Services you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described herein, please do not use our Services.

For the purposes of applicable data-protection legislation (including the UK GDPR, EU GDPR, and the Data Protection Act 2018), the data controller is:

We process your personal data for the following purposes:

• Providing & Improving the Services — operating the App, delivering game content, tracking loyalty rewards, processing payouts, and developing new features.
• Account Management — creating and managing your account, authenticating you, and providing customer support.
• Personalisation — tailoring content, game recommendations, and reward offers to your preferences and usage.
• Analytics & Research — understanding how users interact with the App, measuring performance, conducting aggregated research, and optimising user experience.
• Security & Fraud Prevention — detecting, investigating, and preventing fraudulent, unauthorised, or illegal activity, including multi-account abuse.
• Communications — sending service-related messages (e.g. payout confirmations, security alerts) and, where you have opted in, promotional communications.
• Advertising — displaying contextual or interest-based ads within the App via third-party ad networks, where permitted.
• Legal Compliance — fulfilling legal and regulatory obligations, responding to lawful requests, and enforcing our Terms of Service.

Where applicable law requires a legal basis, we rely on one or more of the following:

• Performance of a contract — processing necessary to provide the Services you requested (e.g. account creation, reward payouts).
• Consent — where you have given clear, affirmative consent (e.g. push notifications, marketing emails, optional analytics). You may withdraw consent at any time.
• Legitimate interests — processing necessary for our legitimate business interests (e.g. fraud prevention, App improvement, direct marketing to existing users) provided those interests are not overridden by your rights.
• Legal obligation — where processing is necessary to comply with a legal or regulatory requirement.

Our website and App may use cookies, local storage, SDKs, and similar technologies for the following purposes:

• Strictly Necessary — essential for the technical operation of our Services (e.g. session management, authentication tokens).
• Analytics & Performance — help us understand usage patterns and improve the Services.
• Advertising — used by third-party ad networks to deliver interest-based ads and measure ad effectiveness.

You can manage cookie preferences in your browser or device settings at any time. Note that disabling certain cookies may affect the functionality of the Services.

We do not sell your personal data. We may share information in the following limited circumstances:

• Service Providers — trusted vendors that help us operate the Services (hosting, analytics, payment processing, email delivery, customer support). These providers are contractually bound to process data only on our instructions.
• Game & Advertising Partners — game publishers, ad networks, and attribution providers that participate in our loyalty ecosystem to deliver content and measure campaign performance, in compliance with applicable law.
• Legal & Safety — law enforcement, regulators, or other parties when disclosure is required by law, legal process, or is necessary to protect the rights, property, or safety of RAVADO TECH LTD, our users, or the public.
• Business Transfers — in connection with a merger, acquisition, restructuring, or sale of assets, your data may be transferred as part of that transaction. We will notify you of any such change.
• With Your Consent — when you have given explicit permission for a specific disclosure.

RAVADO TECH LTD is based in the United Kingdom. Your personal data may be transferred to, and processed in, countries outside the UK and the European Economic Area (EEA) that may not provide the same level of data-protection.

Where such transfers occur, we implement appropriate safeguards, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission or the UK's International Data Transfer Agreement (IDTA).
• Adequacy decisions where the destination country has been recognised as providing adequate protection.
• Additional technical and organisational measures as needed.

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting requirements. When determining retention periods we consider:

• The nature and sensitivity of the data and the potential risk of harm from unauthorised use or disclosure.
• The purposes for which we process the data and whether we can achieve those purposes through other means.
• Applicable legal, regulatory, tax, accounting, or other requirements.

When you delete your account, we will delete or anonymise your personal data within a reasonable period, unless retention is required by law.

We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, alteration, disclosure, or destruction. These measures include, but are not limited to:

• Encryption of data in transit (TLS/HTTPS) and at rest.
• Access controls limited to authorised personnel on a need-to-know basis.
• Regular security assessments of our infrastructure and third-party providers.
• Secure coding practices and vulnerability management.

While we strive to protect your data, please note that no method of transmission over the internet or electronic storage is 100% secure. We encourage you to help keep your account safe by using a strong password and not sharing your credentials.

Depending on your jurisdiction, you may have some or all of the following rights regarding your personal data:

• Access — request confirmation of whether we process your personal data and obtain a copy of it.
• Rectification — request correction of inaccurate or incomplete personal data.
• Erasure (“Right to be Forgotten”) — request deletion of your personal data, subject to lawful exceptions.
• Restriction of Processing — request that we limit the processing of your data under certain circumstances.
• Data Portability — receive the personal data you provided to us in a structured, commonly used, machine-readable format.
• Object — object to processing based on legitimate interests or for direct-marketing purposes.
• Withdraw Consent — withdraw consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before it.
• Lodge a Complaint— file a complaint with your local data-protection authority (in the UK, the Information Commissioner's Office — ico.org.uk).

To exercise any of these rights, email us at privacy@keepplayengine.com. We will respond within the time frame required by applicable law.

The Services are not intended for children under the age of 16 (or the applicable minimum age in your jurisdiction). We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without verifiable parental consent, we will take steps to delete that information promptly. If you believe a child has provided us with personal data, please contact us at privacy@keepplayengine.com.

With your permission, we may send push notifications to inform you about:

• Changes to your earnings or reward status.
• Reminders related to your account activity.
• New features, games, or App updates.
• Promotional offers and special events.

You can opt in or out of push notifications at any time through your device settings. Disabling notifications will not affect core functionality of the App.

When you redeem coins or loyalty rewards, additional personal data may be required to process your payout (e.g. full name, email address, or postal address). This data is shared with our third-party payment partners solely for the purpose of fulfilling your redemption.

We do not directly process or store sensitive payment information such as bank account or credit-card numbers. All transactions are handled by our authorised payment providers under their own privacy policies.

Your payout history is retained so that you can track your earnings. This is based on our legitimate interest in providing a transparent and convenient experience.

For fraud detection and prevention purposes, certain criteria — such as IP address, device fingerprint, and usage patterns — may be evaluated automatically. If multiple indicators suggest fraudulent behaviour, your account may be restricted or suspended.

Such processing is necessary for the performance of our contract with you and our legitimate interest in maintaining Platform integrity. You have the right to request human review of any automated decision that significantly affects you.

If you are a California resident, the California Consumer Privacy Act and the California Privacy Rights Act grant you additional rights:

Residents of US states with comprehensive privacy laws (e.g. Colorado, Connecticut, Virginia, Utah, Oregon, Texas, Delaware, Montana, Iowa, and others as they come into effect) may have additional rights, including:

• Right to Confirm & Access — confirm whether we are processing your personal data and obtain a copy.
• Right to Delete — request deletion of your personal data.
• Right to Correct — request correction of inaccuracies.
• Right to Opt-Out — opt out of the sale of personal data and targeted advertising.
• Right to Appeal — appeal our response to your request.

To exercise these rights, email privacy@keepplayengine.com. We will verify your identity and respond within the legally required time frame. You will not be discriminated against for exercising your rights.

If you are located in the United Kingdom or the European Economic Area, the General Data Protection Regulation (GDPR) and the UK GDPR apply to our processing of your data. In addition to the rights described in Section 11 above, you have the right to:

• Lodge a complaint with the Information Commissioner's Office (ICO) in the UK or your local supervisory authority in the EEA.
• Request details of the safeguards we apply when transferring data outside the UK/EEA (see Section 8).
• Object to processing of your data where we rely on legitimate interests as the legal basis.

The data controller address and contact email are listed in Section 2. We aim to resolve any concerns directly, but you always retain the right to approach your supervisory authority.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• Update the “Last updated” date at the top of this page.
• Notify you via in-app notification, email, or a prominent notice on our website, as appropriate.

We encourage you to review this Privacy Policy periodically. Your continued use of the Services after the effective date of any changes constitutes acceptance of the updated policy.

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

We will endeavour to respond to all legitimate enquiries within one month. Occasionally it may take longer if your request is particularly complex or you have made multiple requests, in which case we will notify you of the extension.