Privacy Policy隐私政策

Last Modified: 25 February 2026

1. INTRODUCTION

1.1 GRAILVERSE PTE. LTD. ("GRAILVERSE", "we", "us", or "our"), a company incorporated in Singapore, takes its responsibilities under the Personal Data Protection Act 2012 ("PDPA") and its subsidiary legislation seriously. We are committed to protecting the privacy of all users ("Users", "you", or "your") of our games, mobile applications, and related services (collectively, the "Services").

1.2 This Privacy Policy ("Policy") describes how we collect, use, disclose, and process your personal data. By accessing the Services, you acknowledge that you have been notified of and understand the terms of this Policy and consent to our processing of your personal data as described herein.

2. CHILDREN AND MINORS

2.1 Age Restrictions: Our Services are not intended for children under the age of 13. We do not knowingly collect personal data from children under 13. If we discover such data has been collected without verifiable parental consent, we will take immediate steps to delete it.

2.2 Minor Consent: In accordance with the PDPA and the Advisory Guidelines on the PDPA for Children, if you are under the age of 18, you must obtain the consent of your parent or legal guardian to use our Services. By allowing a minor to use the Services, parents and guardians acknowledge they are bound by this Policy and are responsible for the minor's data and actions.

3. THE DATA WE COLLECT

We collect personal data to provide a seamless and secure gaming experience. This includes:

• Technical & Device Data:
• From our Mobile Apps: Subject to your device settings and permissions (such as Apple’s App Tracking Transparency), we may collect unique device identifiers (e.g., IDFA, AAID) for the purposes of attribution, fraud detection, and performance analytics. Where you have opted out of tracking via your device settings, we will respect those settings and will not collect these identifiers for advertising purposes.
• From our Website: We use Google Analytics and similar web tools to collect IP addresses, browser types, and page interaction data.
• Cookies and Tracking: Our website uses cookies and web beacons to improve user experience and analyze traffic. You can manage cookie preferences through your browser settings.

4. PURPOSES OF COLLECTION, USE, AND DISCLOSURE

4.1 We process your personal data for the following purposes:

• Service Provision: Managing your account and providing technical support.
• Compliance with Gaming Laws: Ensuring that "loot boxes" or randomised rewards remain compliant with the Gambling Control Act 2022 by verifying that virtual items cannot be "cashed out" or exchanged for real-world currency.
• Security: Preventing fraud, hacking, and cheating to maintain a fair environment.
• Communication: Sending updates, security alerts, and administrative messages.

4.2 Deemed Consent & Legitimate Interests: Pursuant to the 2020 amendments to the PDPA, we may process your personal data without express consent where it is in our Legitimate Interests (e.g., for network security, fraud detection, or business improvement) or by Deemed Consent by Notification, provided we have conducted the required assessments to ensure that any adverse effect on you is outweighed by the public or business interest.

5. DISCLOSURE OF PERSONAL DATA

We may disclose your personal data to:

• Data Intermediaries: Third-party service providers who process data on our behalf.
• Corporate Affiliates: Related corporations (as defined in the Companies Act 1967).
• Legal Authorities: Where required by Singapore law, including the Singapore Police Force, the Gambling Regulatory Authority (GRA), or the Infocomm Media Development Authority (IMDA).

6. DATA TRANSFERS OUTSIDE SINGAPORE

If your personal data is transferred to a country outside of Singapore, GRAILVERSE will ensure that the recipient is bound by legally enforceable obligations to provide a standard of protection that is comparable to the PDPA.

7. DATA SECURITY

We implement comprehensive administrative, physical, and technical measures to protect your data from unauthorised access. While we employ industry-standard encryption, no method of transmission over the internet is entirely secure; users are responsible for keeping their account credentials confidential.

8. RETENTION OF PERSONAL DATA

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required for legal and business purposes (such as tax and audit compliance).

9. ACCESS AND CORRECTION RIGHTS

9.1 You have the right to request access to your personal data or request the correction of inaccuracies.

9.2 Administrative Fees: In accordance with the PDPA, we reserve the right to charge a reasonable administrative fee for processing your data access requests. We will provide you with a written estimate of the fee before processing the request.

10. CONTENT MODERATION AND SOCIAL HARMONY

10.1 In accordance with the IMDA’s Content Code for Games and Singapore’s commitment to racial and religious harmony, GRAILVERSE reserves the right to monitor and moderate User-Generated Content (UGC).

10.2 We may process and disclose personal data to relevant authorities (including the Ministry of Home Affairs) if content is deemed to promote ill-will, hostility, or hatred between different groups, or if it contravenes the Maintenance of Religious Harmony Act.

11. DATA PROTECTION OFFICER (DPO)

If you have any questions, concerns, or complaints regarding this Policy, please contact our DPO at: