Version 1.0 - SPREE
DATE LAST MODIFIED: 5th October 2026
The Mobile Application is owned and operated by Play Spree LTD. We respect your privacy and understand that you have a right to know why we collect your personal information and what we do with it. This Privacy Policy applies to information we collect through our Mobile Application as well as information we may collect offline. “Mobile Application” means the Spree application for mobile devices. “You,” “your,” and “user” mean a user of the Mobile Application.
This policy describes the type of information we collect from you and/or that you may provide us when you use this mobile application.
By accessing the mobile application, you acknowledge this Privacy Policy and agree to be bound by this Privacy Policy. If there is anything you do not understand, please email any inquiry to [email protected]. If at any time you do not agree to this Privacy Policy, please do not use the application or provide us with any personal information.
We reserve the right to change or update this Privacy Policy by posting such changes or updates in the Mobile Application or emailing you notice of the changes. Amendments to this Privacy Policy will be posted in the Mobile Application and will be effective when posted. You can tell if this Privacy Policy has changed by checking the last modified date that appears at the top of this Privacy Policy. Your continued use of the Mobile Application following the posting of any amendment, modification or change shall constitute your acceptance thereof.
APPLE AND GOOGLE
Neither Apple nor Google are a sponsor of any promotion in the Mobile Application and neither not responsible for the Personal Information we or our third parties collect.
YOUR SECURITY
We strive to keep your Personal Information private and safe. We take commercially reasonable physical, electronic and administrative steps to maintain the security of Personal Information collected, including limiting the number of people who have physical access to database servers, as well as employing electronic security systems and password protections that guard against unauthorized access. Purchases made on iOS are handled by Apple through its In-App Purchase feature. Purchases made outside iOS are handled by our third-party payment processor. We will not have access to your credit card number or other such financial data.
Unfortunately, despite our best efforts, the transmission of data over the Internet cannot be guaranteed to be 100% secure. While we will use reasonable means to ensure the security of information you transmit through the Mobile Application, any transmission of Personal Information is at your own risk. We cannot guarantee that such information will not be intercepted by third parties, and we will not be liable for any breach of the security of your Personal Information resulting from causes or events that are beyond our control, including, without limitation, your own act or omission, corruption of storage media, defects in third-party data security products or services, power failures, natural phenomena, riots, acts of vandalism, hacking, sabotage, or terrorism, and we are not responsible for unauthorized circumvention of any privacy settings or security measures contained on the Mobile Application.
INFORMATION WE COLLECT
We collect various information that identifies you as a person (“Personal Information”) in two ways. First, we collect Personal Information that you provide to us. Second, we collect certain Automated Information that may contain Personal Information when you use our Mobile Application.
Personal Information You Provide to Us The Personal Information you provide to us is generally:
contact details including name, email, telephone number, and address; login and account information, including unique user ID and password; personal details including date of birth and purchase history; identity document details and images where we confirm your identity; and personal preferences including your gameplay preferences.
The Mobile Application is available only to persons who are 21 or older. Where we need to confirm that you meet that age, we collect identity document details and images through Veriff, Veriff may also ask you for a selfie.
We collect Personal Information directly from you when you provide it to us. This typically occurs when you:
Make a purchase in the Mobile Application; Send us an email or other communication; Sign in with Apple or Google; Register for an account with us; Participate in a promotion; Play our social games;
Automated Information. We also collect information, some of which may be Personal Information, through automated means when you use our Mobile Application (“Automated Information”) such as:
the IP address of the device you use to connect to the internet (which may include information about your geographic location); device identifiers, including the advertising identifier on your device; your device characteristics; your operating system; your language preferences; information on actions you take in the Mobile Application; and the dates and times you use the Mobile Application. We collect Automated Information automatically as you use the Mobile Application, as explained further below.
When you use the Mobile Application, we may collect information, which may include Personal Information such as your IP address. We collect it through the app and through tools provided by us and by the third parties listed in this Privacy Policy. This may include your (a) IP address; (b) device identifiers, including the advertising ID; (c) device type; (d) operating system and system settings; (e) country and time zone; (f) information about your interaction with the Mobile Application, such as actions you take, purchases, and indicated preferences; and (g) access times.
The iOS and Android settings in “Your Choices About How We Use Your Information and Opting Out” are how you limit advertising and measurement. Those settings do not stop the Mobile Application from keeping you signed in. Cookies apply only where a web page opens inside the Mobile Application, or where you click a link in an email.
In some of our email messages we use a “click-through URL” linked to the Mobile Application or to a web page. When you click one of these URLs, you pass through our web server before arriving at the destination. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our emails. If you prefer not to be tracked in this way, do not click text or graphic links in the email.
HOW WE USE THE INFORMATION WE COLLECT
Most commonly we will use your Personal Information in the following circumstances:
Where you have asked us to do so, or consented to us doing so; Where we need to do so in order to perform a contract we have entered into with you; Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and Where we need to comply with a legal or regulatory obligation.
SHARING PERSONAL INFORMATION WITH THIRD PARTIES
We are committed to maintaining your trust and we want you to understand when and with whom we may share Personal Information and information collected about you. We do not share your Personal Information with any third parties except as set forth herein.
We may disclose your Personal Information to outside individuals and/or companies that help us bring you the products and services we offer and to create, operate, and maintain our Mobile Application. For example, we may work with third parties to: (a) manage a database of customer information; (b) assist us in distributing e-mails; (c) assist us with direct marketing and data collection; (d) provide data storage and analysis; (e) provide fraud prevention; (f) provide customer service; (g) provide other services designed to assist us in developing and running our Mobile Application and maximizing our business potential. We require that these outside companies agree to keep all information shared with them confidential and to use the information only to perform their obligations to us. Any third party with whom we share user data, including analytics tools, advertising networks, third-party SDKs, and any parent, subsidiary, or related entity with access to that data, must protect it to at least the same standard as this Privacy Policy.
If we seek investors or go through a business transition, including but not limited to, a merger, acquisition by another company, or a sale of all or a portion of our assets, your Personal Information may be shared as part of the negotiation of the transaction and will likely be among the assets transferred in the event of a sale or partial sale of our assets.
We may disclose your Personal Information when legally required to do so, to cooperate with law enforcement investigations or other legal proceedings, to protect against misuse or unauthorized use of the Mobile Application, to limit our legal liability and protect our rights or to protect the rights, property or safety of Users of the Mobile Application or the public.
YOUR CHOICES ABOUT HOW WE USE YOUR INFORMATION AND OPTING OUT
You can limit how we and our partners use information from the app for advertising and measurement.
On iOS, the first time it is needed, the Mobile Application will show Apple’s App Tracking Transparency prompt asking for your permission to track your activity across other companies’ apps and websites. If you choose “Ask App Not to Track”, we and our partners will not access your device’s advertising identifier or use information from the app to track you across other companies’ apps and websites. You can change your choice at any time in Settings → Privacy & Security → Tracking, by switching off Spree. You can also switch off “Allow Apps to Request to Track” to decline tracking for all apps.
On Android, go to Settings → Security & privacy → Privacy → Ads and delete your advertising ID or opt out of ad personalization. The menu name can differ by device.
These choices do not delete your account or stop the app from keeping you signed in. To remove information stored on the device, log out or delete the app. If you use more than one device, change the settings on each device.
ACCOUNT DELETION
You can delete your Customer Account in the app under Menu → My Account → Delete Account. Deletion removes the Personal Information linked to your Customer Account, except information we must keep for a legal obligation or to prevent fraud, and you may also request deletion by emailing [email protected].
DATA RETENTION
We keep Personal Information for as long as your Customer Account is open, and afterwards for as long as we need it to provide the Mobile Application, meet a legal or accounting obligation, prevent fraud, or resolve a dispute. When you delete your Customer Account, we delete or de-identify the Personal Information linked to that account, except information we are required to keep for those purposes. Information stored only on your device is removed when you log out or delete the app.
YOUR RIGHTS
You may ask us for a copy of the Personal Information we hold about you, or ask us to correct it, by emailing [email protected].
You may withdraw consent for marketing emails by using the unsubscribe link in those emails or by emailing [email protected]. You may withdraw consent for advertising and measurement through the iOS or Android settings described above. Withdrawing consent does not affect processing we do to provide the Mobile Application, to prevent fraud, or to meet a legal obligation.
To request deletion of your Personal Information, delete your Customer Account as described under Account Deletion, or email [email protected].
PROMOTIONAL OFFERS
If you do not wish to receive our email promotional offers, you can opt out by emailing [email protected], or by clicking on the “unsubscribe” link found in emails we send to you. Opting out of receiving our communications will not affect your receipt of service-related communications, such as payment confirmations, if we have a data breach, or other such communications for which we have a legal obligation to inform you and/or to prevent fraud or harm to our Mobile Application, our business, and/or third parties.
Our products and services use Google Analytics and its associated tracking technologies to help display our ads you see on other mobile applications, and to help us manage and optimize our advertising. To limit this, use the iOS or Android settings described above.
In addition, we use the following third party providers for the purposes listed in the table below:
| Provider | Purpose |
|---|---|
| Google Analytics | Marketing analytics |
| SEON | Fraud prevention |
| Veriff | ID Documentation Confirmation |
| Zendesk | Live Chat customer support |
DISCLOSURE FOR LEGAL PURPOSES
You hereby authorize us to disclose any of your Personal Information pursuant to judicial and administrative proceedings and to law enforcement or government agencies if we are legally required to do so. You also authorize us to disclose Personal Information if we believe the disclosure is necessary or appropriate in the event of an investigation of improper or illegal conduct in connection with the Mobile Application, such as fraud, misrepresentation, intellectual property infringement, or other activity that may put us at risk for liability.
DISPUTES
This Privacy Policy will be interpreted in accordance with the laws of the State of Delaware and the United States of America, without regard to its conflict-of-law provisions. By using the Mobile Application, you agree that, except as otherwise specified herein, the laws of the State of Delaware without regard to principles of conflict of laws, will govern any dispute of any sort that might arise between us or any of our affiliates regarding your use of the Mobile Application.
We and you agree that in the event of any dispute, the party wishing to address the dispute must contact the other party in writing, including by e-mail, and advise the other party of the dispute in reasonable detail as well as informing the other party of the remedy being sought. We may send you notices via the email address you provide to us, and all notices to us shall be sent to the following email address: [email protected] and include the words “DISPUTE NOTICE” in the subject. The parties shall then make a good faith effort to resolve the dispute before resorting to more formal means of resolution. In the event that the dispute is not resolved through this procedure, the party raising the dispute may proceed to mandatory arbitration as set forth in the Terms of Service.
CHILDREN
We do not knowingly permit persons under 21 years of age to use the Mobile Application, and we do not knowingly collect, use or disclose Personal Information from anyone under 21 years of age. If we become aware that we have unknowingly collected Personal Information from a person under the age of 21, we will make reasonable efforts to delete such information from our records.
CONFIDENTIAL INFORMATION
We do not want you to send to us any confidential or proprietary information through email or otherwise. Any information, materials, suggestions, ideas or comments sent to us will be considered non-confidential, and by submitting the same to us, you are giving us the absolute right to use, modify, reproduce, transmit, display and distribute the information for any purpose whatsoever, with no payment or other compensation to you. However, we will not use your name unless we are required by law to identify the source of the materials, information, suggestions, ideas or comments, or unless we first obtain your permission.
ASSIGNMENT
We may freely assign this Privacy Policy or any of our rights and/or obligations hereunder to any successor.
CONTACT
If you have any questions about your privacy or security at the Mobile Application, or wish to update your Personal Information, please send an email to [email protected].