Privacy Policy – Socialplayza

This Privacy Policy explains how Mobistar Limited collects, uses, shares, stores and protects personal information when you visit the SocialPlay website, subscribe to the service, access its games or other digital content, or contact customer support. This Policy is intended to comply with South Africa’s Protection of Personal Information Act, 2013 (POPIA) and other applicable requirements.

1. Who is responsible for your personal information?

Responsible party: Mobistar Limited Address: BLK 2, FLAT 4, Games Village, Surulere, Lagos, Nigeria Service: SocialPlay Website: www.socialplayza.com Privacy and support email: info@socialplayza.com Support number: 087 940 7333 SocialPlay is available in South Africa to eligible Vodacom, MTN and Cell C customers. Your mobile network operator also processes certain personal information under its own privacy notice and subscriber terms.

2. What personal information do we process?

Depending on how you use SocialPlay, we may process: your mobile number and network operator; your subscription status, activation date, renewal history and cancellation details; billing references, dates, amounts and transaction status received through the mobile-billing process; records showing how and when the subscription was requested or confirmed; access credentials or technical identifiers assigned to your subscription; technical information, including your IP address, device type, browser, operating system, language settings and connection logs; information about your use of the website and available content, such as pages, games or other resources accessed; information contained in customer-support requests and related correspondence; and cookie identifiers and advertising or analytics information where the relevant tools are used and lawfully enabled. We obtain this information directly from you, from your use of SocialPlay, and from Vodacom, MTN, Cell C or the technical and billing providers involved in activating, charging, renewing and cancelling your subscription. Mobile-billed subscriptions do not require you to provide SocialPlay with payment-card details.

3. Why do we use your information?

We process personal information to: activate and administer your SocialPlay subscription; authenticate your access and provide games and other available digital content; process recurring subscription charges through your mobile network operator; send necessary service communications, including activation, renewal, support and cancellation messages; respond to enquiries and investigate subscription, access or billing issues; maintain and improve the operation, security and performance of the service; prevent fraud, abuse, unauthorised access and technical interference; analyse service usage and campaign performance where permitted; and meet legal, regulatory and contractual requirements and manage disputes. Depending on the purpose, processing may be necessary to perform the subscription agreement, comply with a legal obligation, pursue a legitimate interest that does not unjustifiably affect your rights, or act with your consent. Your mobile number and subscription information are necessary to activate, bill and manage the service. If this information cannot be processed, we may be unable to provide the subscription.

4. Service messages and marketing

We may send messages that are necessary to operate your subscription, such as activation, billing, service-change and cancellation notices. These are service communications and are not optional while the relevant subscription remains active. Promotional messages will only be sent where permitted by applicable law. Where consent is required, subscribing to SocialPlay will not by itself be treated as unlimited consent to receive unrelated marketing. You may opt out of promotional communications using the instructions contained in the message or by contacting info@socialplayza.com Opting out of marketing does not automatically cancel your paid subscription. To cancel the subscription itself, dial *135*997# or contact customer support.

5. Who may receive your information?

We may disclose necessary personal information to: Vodacom, MTN or Cell C, depending on your network, to activate, bill, renew and cancel the subscription; mobile-billing and messaging providers involved in delivering the service; hosting, maintenance, security, analytics and customer-support providers acting on our behalf; WASPA, where information is reasonably required to investigate or resolve a complaint under its procedures; professional advisers, regulators, courts or law-enforcement authorities, where disclosure is required or permitted by law; and a successor or purchaser in connection with a lawful reorganisation or transfer of the service, subject to appropriate safeguards. Providers acting on our behalf may only use personal information for the agreed services and must apply appropriate confidentiality and security measures. We do not sell your personal information to third parties for their own advertising purposes.

6. Cookies and similar technologies

SocialPlay may use essential cookies and similar technologies to maintain sessions, authenticate users, remember necessary settings and protect the website. Additional tools may be used for audience measurement, service improvement or advertising attribution. Where consent is required, optional cookies or tracking technologies will only be activated after you have made the relevant choice. You may also control cookies through your browser, although blocking essential cookies may prevent parts of the service from working correctly. Before publication, insert or link to the actual cookie list, including each provider, purpose, cookie or identifier name, duration and the mechanism for accepting, rejecting and changing optional preferences.

7. Cross-border processing

Mobistar Limited is based in Nigeria, while SocialPlay is offered to users in South Africa. Personal information may therefore be processed outside South Africa, including in Nigeria and in countries where approved technical providers operate. Where personal information is transferred outside South Africa, we will take reasonable steps to ensure that the recipient is subject to a law, agreement or binding arrangement that provides an appropriate level of protection as required by POPIA. Before publication, confirm the actual hosting, backup and remote-access locations, the providers involved and the safeguards used for each cross-border transfer.

8. How long do we keep personal information?

Personal information collected for SocialPlay will be retained for no longer than necessary for the purposes described in this Policy and, in any event, for a maximum of 24 months from the date of collection, unless a longer period is required or permitted by law, reasonably necessary for a lawful purpose, or required to establish, exercise or defend a legal claim. When the applicable retention period ends, the information will be securely deleted, destroyed or de-identified so that it cannot reasonably be reconstructed. Cancelling the subscription does not necessarily result in the immediate deletion of every record. Certain activation, billing, consent, security or complaint records may need to be retained for the remainder of the applicable lawful period.

9. How do we protect personal information?

We implement reasonable technical and organisational safeguards designed to protect personal information against loss, damage, unauthorised access, unlawful processing, alteration and disclosure. Access is limited to authorised personnel and service providers who require the information for legitimate operational purposes. No online service can guarantee absolute security. Do not disclose your password, access code or one-time verification code to anyone. If you believe your information or subscription has been misused, contact info@socialplayza.com or call 087 940 7333.

10. Your rights

Subject to POPIA and any lawful limitations, you may have the right to: ask whether we hold personal information about you and request access to it; request correction or deletion of information that is inaccurate, irrelevant, excessive, outdated, incomplete, misleading or unlawfully obtained; object to certain processing on reasonable grounds; withdraw consent where processing depends on consent; object to direct marketing; request information about the identity of third parties that have had access to your information where applicable; and lodge a complaint with South Africa’s Information Regulator. To exercise a right, email info@socialplayza.com and identify the mobile number concerned and the nature of your request. We may ask for proportionate proof of identity to protect your information. Never send us a password or one-time verification code. You may contact the Information Regulator South Africa through its official website: https://inforegulator.org.za/.

11. Users under 18

The subscription is intended for users aged 18 or older or users who have the bill payer’s valid permission. SocialPlay does not knowingly seek to collect children’s personal information without the authorisation required by law. If you believe that a child’s personal information has been processed without proper authorisation, contact us so that we can investigate and take appropriate action.

12. Cancellation, privacy requests and complaints

You may cancel your paid SocialPlay subscription by dialing *135*997#. You may also request assistance by emailing info@socialplayza.com or calling 087 940 7333. Cancelling a subscription, opting out of marketing and exercising a privacy right are separate actions. If you want us to deal with more than one of these, clearly state each request. Mobistar Limited is a WASPA member. You may lodge a service complaint through https://www.waspa.org.za/ in accordance with the WASPA complaints procedure. A privacy complaint may also be submitted to the Information Regulator.

13. Changes to this Policy

We may update this Privacy Policy when our service, data practices or legal obligations change. The latest version and revision date will be published on the SocialPlay website. Where a change requires fresh consent, we will request it before carrying out the relevant processing.

14. Contact details

Mobistar Limited — SocialPlay BLK 2, FLAT 4, Games Village, Surulere, Lagos, Nigeria Email: info@socialplayza.com Support: 087 940 7333