Privacy policy

28 November 2025

This Privacy Policy (hereinafter referred to as the «Policy») applies to all information, including personal data within the meaning of applicable law (hereinafter referred to as "Personal Information"), which Virplay, TOO and/or its affiliates, including those belonging to the same group with Virplay, TOO (hereinafter referred to as the «Company»), may receive information about Users during the use of the Company's websites, programs, products and/or services (hereinafter collectively referred to as «Services», as well as during the execution of The Company of any agreements and contracts concluded with Users in connection with the use of the Services.

Personal data means any information relating directly or indirectly to a specific or identifiable user of any of the Company's Services, as well as information that identifies, relates to, describes, is associated with or can reasonably be associated, directly or indirectly, with a specific consumer or household.

The representative of the Company in accordance with the General Data Protection Regulation (GDPR) for users located in the European Economic Area (EEA) or Switzerland is Artemia World s.r.o. registered at: Prague 4, Proutěna 405/11, postal code 14900.

1. General provisions

This Policy has been developed in compliance with the requirements of the current legislation on personal data and applies to personal data processed by the Company.

The purpose of the Policy is to ensure the protection of human rights and freedoms when processing his personal data, including the protection of the rights to privacy, personal and family secrets; ensuring proper protection of personal data from unauthorized access and disclosure.

The Policy is a public document and is available for review by anyone on the website https://virplay.me.

Upon registration, each access and/or actual use of any of the Services, the User agrees to the terms of this Policy, as well as to the terms of the agreements of the Services used by him, in the editions that were in effect at the time of actual use of such Services.

2. Personal data processing basic principles

Personal data processing is carried out on the basis of the principles of:

a) legality of the purposes and methods of personal data processing;

b) good faith;

c) compliance of the purposes of personal data processing with the purposes previously defined and declared when collecting personal data, as well as the Company's powers;

d) compliance of the volume and nature of the processed personal data, methods of personal data processing with the purposes of personal data processing;

e) the inadmissibility of combining databases containing personal data created for incompatible purposes.

3. Liability of the Company

The Company is legally obliged to:

- process personal data in accordance with legal requirements;

- use the information received exclusively for the purposes specified in this Policy;

- ensure that confidential information is kept secret;

- not to sell, exchange, publish or disclose in other possible ways the transferred personal data;

- take precautions to protect the confidentiality of personal data;

- provide free of charge to the subject of personal data or his representative the opportunity to get acquainted with personal data related to this subject of personal data;

- respond to requests and requests from personal data subjects and their representatives within the established time limits.

4. General rights of the subject of personal data

The subject of personal data legally has the right to:

- receive information concerning the processing of his personal data in an accessible form;

- to demand clarification of his personal data, their blocking or destruction;

- appeal to the authorized body or to the court against illegal actions or omissions in the processing of his personal data;

- claim damages and (or) compensation in case of violation of his rights in the field of personal data processing.

5. Purposes of personal data processing

а) performance of the End User License Agreement (EULA), including processing refund requests

for details see https://virplay.me/tos

b) implementation of technical and consulting support at the request of the user;

c) addressing advertising to the user;

d) fulfillment of obligations imposed on the Operator by the legislation.

6. The interrelated elements of the processed information.

- Personal data provided by users when using the Services: surname, first name, patronymic, date of birth, email address, phone number;

- Personal data provided by users additionally (phone numbers, addresses);

- Information provided by users at the request of the Company to identify the user, prevent abuse using the Services, prevent violations of the rights of the Company and third parties.

The Company uses automatically collected and aggregated information that does not contain personal information and does not allow identifying the User in order to recognize the preferences of visitors who are particularly popular sections of the Services: location information; type and version of the operating system; browser type and version; device type and screen resolution; source of access to the site; language of the operating system and the browser; actions performed on the site; IP address, statistics and other data.

The Operator has the right to use the "cookies" technology. "Cookies" do not contain confidential information and are not transmitted to third parties. The user can block the function of collecting and analyzing statistics related to the visit at any time by revoking the permission in the browser. Blocking may affect the operation of some functions of the site.

Special personal data

The Operator does not process special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, intimate life.

Biometric personal data

The operator does not process biometric personal data (information that characterizes the physiological and biological characteristics of a person, on the basis of which his identity can be established).

7. Provisions and procedure of the processing of personal data

The processing of User Information is carried out by the Company in accordance with the following principles:

1) legality of the purposes and methods of information processing;

2) the integrity of the Company;

3) compliance of the purposes of information processing with the purposes previously defined and declared during its collection, as well as with the Company's powers;

4) compliance of the volume and nature of the processed information, methods of its processing with the purposes of information processing;

5) the inadmissibility of combining databases containing User Information created for incompatible purposes.

Collecting Information

The User's personal data is collected during use, any interaction, as well as access to the Company's Services (for example, when launching an application).

Data transmission

User Data is not transferred to any third parties, except as expressly provided for in this Policy, other applicable rules, as well as applicable legislation.

The Company may transfer User data to third parties, in compliance with the purposes and if there are grounds specified in this Policy. Such third parties may include:

- persons who participate in the provision of services related to the placement and display of information to users (including offers relevant to the interests of Users) about the Company's services and services in programs, products or services that belong to or are controlled by such persons (for example, owners of websites and applications, advertising networks and other persons, etc.);

- third parties in respect of whom the assignment of rights or obligations has been made, or an innovation under the relevant Agreement with the user;

- any authority to which the Company is obliged to provide information in accordance with applicable law upon request.

The Company has the right to provide the User with the opportunity to transfer Credentials to third parties through special technologies (Open ID, etc.), subject to the User's consent to such transfer. At the same time, the Company does not guarantee the completeness and correctness of the transfer of Credentials to the User and is not responsible for the safety of data during the transfer.

In cases provided for by the privacy policies of the relevant Services, the Company may carry out cross-border transfer of Information to the minimum extent necessary for the purposes specified in this Policy to third parties.

It is not allowed to extract and use User data, including for commercial purposes, without the Company's permission.

Storage of Information

The Company stores data in accordance with the requirements of the legislation on personal data on servers that provide reliable data protection.

User data is stored exclusively on electronic media and processed using automated systems, except in cases where non-automated processing of personal data is necessary in connection with compliance with legal requirements.

Information retention periods

The data is stored until the purposes of their processing are achieved, unless otherwise specified in the privacy policy.

The data is stored by the Company during the term of the agreement between the User and the Company on the use of the Service (link to the agreement), and after the termination of such agreement – for the period necessary and established by applicable law.

Termination of Information processing

Upon achieving the purposes of information processing, the Company terminates data processing in one of the ways provided for by the current legislation.

8. Reject to process data

The User can prevent and/or manage the collection and processing of data related to the use of the Services by following the instructions given below.

Google Analytics. To opt out of tracking Google Analytics data, the User can install and activate the Google Analytics Blocker. The User can also manage and/or delete cookies previously set by Google Analytics through the browser settings. Additional information about the practical methods of data processing and the corresponding instructions of Google Analytics can be found at the link https://support.google.com/analytics/answer/6004245 (section “Information for visitors to websites and applications where Google Analytics is used").

Blocking cookies

Browsers that allow you to refuse to accept cookies:

- Internet Explorer: https://support.microsoft.com/kb/278835

- Chrome: https://support.google.com/chrome/answer/95647.

Blocking all cookies can negatively affect the usability of many Services and Websites.

9. Feedback

Users have the right to send requests, including requests regarding the use of their personal data provided for in Section 5 of the Policy, in writing to the address: the legal address of the company, or in the form of an electronic document signed with a qualified electronic signature in accordance with applicable law, to the email address: support@virplay.me.

In order to exercise the stated right, the Company may request: (1) to provide sufficient information to ensure that the user is the person about whom the Company has collected Personal Data, and (2) to describe the request in sufficient detail so that the Company can understand, evaluate and respond to it. The Company may not respond to requests that do not meet these criteria. The Company will use the Personal Data provided in the request only for verification and execution of the request. The Company will respond to the request within 30 days of its receipt.

10. Processing of User's personal data in order to refund funds

When you request a refund through the App Store services, we share information about your use of the app with Apple Inc.:

- the age of the User’s account;

- a value that indicates the extent to which the User consumed the in-app purchase;

- a value that indicates the total amount, in USD, of in-app purchases the User has made in our app, across all platforms;

- a value that indicates the total amount, in USD, of refunds the User has received, in our app, across all platforms;

- a value that indicates the platform on which the User consumed the in-app purchase;

- the status of the User’s account.

Apple Inc. analyzes the User's interaction with the application and, based on the transmitted data, makes a final decision on the refund of funds to the user.

We transfer data only if we have a legal basis for this:

a) processing is necessary for the performance of a contract to which the User is a party (EULA)

b) processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party, except in cases where your interests or fundamental rights and freedoms that require the protection of personal data prevail over our interests.