PRIVACY POLICY

This Privacy Policy explains how BUFFO Club (“we”, “us”, “our”) collects, uses, stores, shares, transfers and protects personal data when you visit our website, create user accounts, use our games, social‑network applications, software products, APIs and all related digital services (collectively the “Services”).

This Privacy Policy forms an integral part of our Terms of Use. By accessing or using our Services, you consent to the data practices described in this document. If you do not agree with any part of this Privacy Policy, you must stop using our Services.

1. Information We Collect

We may collect the following categories of information when you interact with our Services.

1.1 Information you voluntarily provide to us

• Account registration data: username, email address, phone number, password, display name, avatar, interests, gender, profile settings you submit when creating an account.
• User‑generated content (UGC): text messages, comments, images, videos, avatars, profile descriptions, chat messages and other content you post inside games and social‑app communities.
• Support / legal inquiries: name, email and any personal details you provide when contacting our support or legal team for help, complaints or legal requests.
• Purchase information: when you make in‑app purchases, we may receive transaction‑related information such as order identifier, purchase timestamp; we do NOT store full credit‑card or payment card details. Payment information is processed securely by third‑party payment service providers.
• Newsletter / subscription data: your email address if you sign‑up for our mailing list.

1.2 Automatically collected information

When you use our website, games or apps, we automatically gather technical and usage information:

• Device information: device model, operating‑system version, screen resolution, unique device identifier, application version, network type.
• Log data: IP address, access timestamp, pages / game features you visited or used, crash logs, error reports, interaction events within the Services.
• Cookie and similar tracking technologies: cookies, local storage, web beacons. We use these for session maintenance, preference remembering, analytics and service security.

1.3 Information we do NOT intentionally collect

• We do not intentionally collect sensitive special‑category personal data (racial origin, religious beliefs, health data, biometric data) unless you actively choose to submit such content in UGC or support tickets.
• We do not intentionally collect personal information from children under 13 years of age, in compliance with US COPPA requirements. If we become aware we have received personal data of children under 13 without verifiable parental consent, we will delete that data without delay.

2. How We Use Your Information

We process your personal data for the below lawful purposes, consistent with applicable law (for GDPR users: legitimate interest, performance of contract, your consent, legal obligation):

• To provide, operate and maintain our Services: create and manage your user account, enable game and social‑app features, process in‑app purchases, host UGC, ensure normal game server operation.
• To improve and develop our products: analyse usage patterns, fix bugs, diagnose crashes, test new features, optimise user experience for games and social applications.
• For safety, moderation and security: detect abuse, fraud, cheating, harmful content; moderate chat and community UGC; prevent unauthorised account access; enforce our Terms of Use.
• To communicate with you: respond to support questions, send service‑related system notifications, inform you of critical service updates, respond to your data‑subject requests.
• To send optional marketing communications: newsletters, product announcements, new‑game updates — you may opt‑out of marketing emails at any time.
• To comply with legal obligations: respond to valid legal orders, court requests, regulatory requirements, protect our legal rights and defend against legal claims.

We will not repurpose your personal data for purposes incompatible with those set‑out above without obtaining your new consent.

3. Cookies and Similar Technologies

Our website and applications use cookies, local storage and web beacons.

• Necessary cookies: required for login session persistence, account security, basic website function; cannot be disabled.
• Functional cookies: remember your preferences, language settings.
• Analytics cookies: collect aggregated usage statistics to help us improve Services.

You can manage or disable cookies via your browser or device operating‑system settings. Disabling cookies may cause some parts of our Services to stop working correctly.

4. Who We Share Your Information With

We do not sell your personal data to third‑parties for commercial purposes. We may share information only in limited circumstances described below:

4.1 Authorised service providers (data processors)

We share data with trusted third‑party vendors who act only on our instructions to deliver our Services:

• Payment processors for handling in‑app purchases;
• Cloud hosting and server providers to host games, apps and user content;
• Analytics and crash‑reporting service providers;
• Customer‑support ticketing system providers.

All processors are bound by data‑protection contractual obligations and may not use your personal data for their own independent purposes.

4.2 Within your public community features

Information and UGC you publish in public game chat, social‑app feeds, public profiles will be visible to other users of our Services. Please exercise caution before disclosing sensitive personal information in public areas.

4.3 Legal and safety requirements

We may disclose personal data if required by law, valid governmental request, court order; or to protect the rights, property and safety of BUFFO Club, our users or the public; to enforce our Terms of Use.

4.4 Business‑transfer scenarios

In connection with merger, acquisition, asset sale, corporate restructuring: your user data may transfer as part of business assets. We will notify you via website notice before personal data transfers to a new entity.

We will never share your personal information with unaffiliated third‑parties for their own marketing purposes without your explicit separate consent.

5. International Data Transfers

Our Services may be operated using cloud infrastructure located outside your country of residence. Your personal data may be stored and processed in other jurisdictions which may have different data‑protection legal rules.

When transferring personal data across borders, we implement appropriate safeguards (such as standard contractual clauses, where applicable) to protect your personal information in compliance with GDPR and other applicable privacy laws. By using our Services, you acknowledge this international data transfer.

6. Your Privacy Rights

Depending on your country or region of residence, you may have the following data‑subject rights:

For European Economic Area / UK users (GDPR rights)

• Right to access: request a copy of the personal data we hold about you.
• Right to rectification: correct inaccurate or incomplete personal information.
• Right to erasure (“right to be forgotten”): request deletion of your personal data, subject to our legitimate legal retention obligations.
• Right to restriction of processing: request limitation on how we process your data under certain conditions.
• Right to data portability: receive your account data in machine‑readable format.
• Right to object: object to processing based on legitimate interests or direct marketing.
• Right to withdraw consent: you may withdraw consent where processing relies on your consent; withdrawal does not affect lawfully‑performed processing prior to withdrawal.
• Right to lodge a complaint with your local data‑protection authority.

For California residents (CCPA / CPRA)

If you are a California resident you have rights including: right to know what personal data we collect/use/disclose; right to request deletion of your personal information; right to opt‑out of sale of personal data (we do NOT sell your personal data). We will not discriminate against you for exercising your CCPA rights.

General for all users

Account deletion: You may request full deletion of your user account. After account deletion:

• We will erase most of your personal account data.
• Public UGC you have posted (chat messages, comments) may not always be fully removed from live community view (for technical reasons of replicated caches; where feasible we will anonymise such content).
• Some limited data may be retained to fulfil legal, tax, fraud‑prevention and archival obligations for the period required by applicable law.

How to submit your privacy‑rights request:
Send your request to support@buffo.club. Please provide sufficient information so we can verify your identity before fulfilling your request. We will respond within legally required timelines.

7. Data Retention Periods

We only keep personal data for as long as necessary to fulfil the purposes for which it was collected:

• Active account: retain your account‑related data for the lifetime of your account.
• After you delete your account: Most personal identifiers are deleted. Mandatory legal retention: we may retain limited transaction, log and fraud‑prevention records for the period required by applicable statute of limitations / local law.
• Marketing email records: retain until you opt‑out.
• UGC: public content may persist with anonymisation after account deletion; private chat data will be removed subject to system capabilities.

8. Children’s Privacy (COPPA)

Our Services are not intended for children under the age of 13.

We do not knowingly collect personal information from children under 13 without verifiable parental consent. If you are a parent or guardian and you believe your child under 13 has provided personal data to us without proper consent, please contact us at support@buffo.club. We will take steps to delete that information.

Users must meet the minimum‑age requirements defined in our Terms of Use to register for our Services.

9. Third‑Party Links and Services

Our website, games and social‑apps may contain links or integrations to third‑party services: payment providers, social platforms, app stores, SDK partners.

We have no control over the data‑handling practices of these third‑parties. Your interaction with third‑party services is governed solely by their own privacy policies. Please review their privacy statements before providing personal data.

10. Data Security

We apply reasonable organisational and technical security safeguards to protect your personal data against loss, unauthorised access, alteration or disclosure.

However, no method of internet transmission or electronic storage is 100% secure. We cannot guarantee absolute security of your information. If we detect a personal‑data breach which poses risk to your rights, we will notify you and relevant authorities as required by applicable law.

11. Changes to this Privacy Policy

We may revise this Privacy Policy from time‑to‑time.

Material changes will be published on our official website with an updated “Last Updated” date, and where practicable via in‑service notice or email notification. Your continued use of Services after the effective date of revised Privacy Policy constitutes acceptance of the updated provisions. If you reject revised terms you must discontinue using our Services.

12. Contact Information for Privacy‑Related Inquiries