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Playcamp Personal Information Processing Policy Last Updated: Jan 29, 2026

Article 1: General Provisions and Identity of Controller
  1. Purpose and Scope This Privacy Policy (hereinafter referred to as the “Policy”) outlines the principles and guidelines governing how Smartplay Inc. (including its subsidiaries or affiliates, hereinafter referred to as “Playcamp,” “we,” “us,” or “the Company”) processes the personal information of its users. This Policy applies to all services provided by Playcamp, including our website, creator matchmaking platform, and related services. We are committed to protecting your personal integrity and ensuring that all data processing is performed responsibly and in accordance with applicable laws, including the General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA), including the Personal Information Protection Act (PIPA) of the Republic of Korea.
  2. Application of Policy This Policy applies to “Creators” (individuals or companies registered to offer content creation services), “Companies” (representatives of game studios, publishers, or agencies), and “Visitors” (individuals browsing the Playcamp website without an account).
Article 2: Items of Personal Information Collected and Collection Methods We collect different types of data, to provide the functionality of the Services you have requested, depending on how you interact with our Services. The specific items of personal information collected are detailed below.
  1. Information Collected from Content Creators When you register as a Creator, we collect mandatory account information necessary to identify you and manage your account. This includes your email address, password (stored in encrypted format), display name or gamertag, and date of birth for age verification purposes. To facilitate your participation in campaigns, we may also collect optional profile data, such as your introduction, profile images, social media handles, Discord ID, and preferred game genres.
For the purpose of processing payouts for completed campaigns, we collect mandatory financial information, including your bank account number, bank name, SWIFT/IBAN code, PayPal email address, wallet address. Additionally, solely for the fulfillment of tax obligations under applicable laws such as the Korean Income Tax Act or US IRS regulations, we may collect your Tax Identification Number (TIN), Social Security Number (SSN) or equivalent.
  1. Information Collected from Game Companies When you create a Company account, we collect business contact information, including the name of your representative, job title, company email address, and phone number. We also collect organization details such as your Company Name, Business Registration Number (or local equivalent), and physical address to verify your business entity. To process payments for platform fees or creator funding, we collect billing information, including payment history, credit information, and billing address.
  2. Information Collected via Third-Party APIs (Automated Collection) To provide matchmaking services and analytics, Playcamp utilizes API services from third-party platforms. By using our Platform and linking your third-party accounts, you acknowledge and agree that:
  • YouTube: Our Services use YouTube API Services. By using Playcamp, you are agreeing to be bound by the YouTube Terms of Service (https://www.youtube.com/t/terms) and the Google Privacy Policy (http://www.google.com/policies/privacy). You can revoke Playcamp’s access to your data at any time via the Google Security Settings page (https://security.google.com/settings/security/permissions).
  • Twitch: We collect data in accordance with the Twitch Developer Services Agreement.
    * Collected Data: By connecting these accounts, the following data is automatically collected and stored: Channel ID(s), channel metrics (including subscriber counts and view counts), lists of videos, and video metrics (including views, likes, and comments)   
  • TikTok: Our Services use the TikTok for Developers API. By connecting your TikTok account to Playcamp, you acknowledge and agree to be bound by the TikTok Terms of Service (https://www.tiktok.com/legal/terms-of-service) and the TikTok Privacy Policy (https://www.tiktok.com/legal/privacy-policy).
    * Revocation: You may disconnect your TikTok account and revoke Playcamp’s access to your data at any time via your TikTok app settings under “Security & Login” > “Manage App Permissions.”
  • SOOP: Our Services integrate with SOOP services. By using Playcamp and linking your SOOP account, you agree to be bound by the SOOP Terms of Service (https://www.sooplive.co.kr/policy/lang/policy1_en.html) and acknowledge the SOOP Privacy Policy (https://www.sooplive.co.kr/policy/lang/policy2_en.html).
    * Data Usage: You authorize Playcamp to access your public profile information, stream metrics, and content data as permitted by the SOOP Open Platform to facilitate campaign reporting and creator matchmaking.
  1. Information Collected Automatically When you visit our website or use our platform, our servers automatically generate and record certain technical information to ensure service stability, prevent fraud, and improve our website. This includes your IP address, browser type and version, operating system (OS), visit history, referral URLs, connection logs, cookies, and device information.

Article 3: Purpose of Collection and Use
  1. Member Management and Identification We process personal information to handle membership registration, identify and authenticate users, and maintain the integrity of our platform. This includes verifying your intent to join, managing user accounts, and delivering notices regarding service changes or policy updates.
  2. Provision of Matchmaking and Platform Services The core purpose of Playcamp is to facilitate collaborations between Content Creators and Game Companies. We process your data to operate the matchmaking(including discoverability) algorithm, which analyzes Creator metrics (such as viewer engagement and subscriber counts) to suggest relevant campaigns to Game Companies. For Creators, this includes displaying your profile, portfolio, and social media analytics to prospective partners. For Game Companies, we use your business information to manage campaign briefs, distribute game keys, and generate performance reports.
  3. Payment Settlement and Tax Compliance We process financial and identification data to execute payouts for completed campaigns and to handle billing for platform services. This includes verifying bank account details to prevent fraud and ensuring that payments are routed correctly. Furthermore, we are legally obligated to process sensitive identification numbers (such as Korean Resident Registration Numbers or US Social Security Numbers) solely for the purpose of tax withholding and reporting to relevant tax authorities (e.g., the National Tax Service of Korea or the US Internal Revenue Service) in compliance with the Income Tax Act, Value Added Tax Act, and other applicable global tax regulations.
  4. Service Improvement and Marketing We process automatically collected data and usage history to analyze service usage patterns, improve website functionality, and ensure the stability of our IT systems. We  may also use your contact information to send you newsletters, promotional offers, or information about new game campaigns that may be of interest to you. You may withdraw your consent for marketing communications at any time.

Article 4: Provision of Personal Information to Third Parties
  1. Provision to Game Companies To fulfill the purpose of our matchmaking and discoverability service, Playcamp provides the personal information of Content Creators to “Game Companies” (including game developers, publishers, and agencies) that a Creator has elected to share information with, that utilize our platform. When a Creator applies for a campaign or is matched by our system, we provide the Game Company with the Creator’s profile data, including display name, social media metrics (e.g. YouTube/Twitch APIs), introduction, and past campaign performance data. This information is provided solely to enable the Game Company to evaluate the Creator for potential collaboration, manage active campaigns, and distribute rewards or game keys. Game Companies act as independent controllers of this data once received and are obligated to process it in compliance with applicable laws.
  2. Provision to Collaboration Partners In the event that you participate in specific “Creator Programs” or joint events, we may share your email address and contact details with collaboration partners involved in that specific program. This is done to facilitate the delivery of merchandise, rewards, or specific mission instructions relevant to that program.
  3. Legal and Regulatory Disclosures We may disclose your personal information to third parties without your consent where strictly required by law. This includes providing data to:
  • Tax Authorities: The National Tax Service (Korea), IRS (US), or other local tax bodies for the purpose of reporting income and withholding taxes.
  • Investigative Agencies: The police, prosecutors, or courts for the purpose of criminal investigations or legal proceedings, provided that such requests follow valid legal procedures (e.g., warrants or subpoenas).
  1. Business Transfers In the event of a merger, acquisition, or sale of all or part of our business, your personal information may be transferred to the acquiring entity to ensure the continuity of service. We will notify you in advance of any such transfer and provide you with the option to withdraw your consent if you do not wish for your data to be transferred.
  2. Notice to California Residents (CCPA/CPRA): “Sale” and “Sharing” of Personal Information Under the California Consumer Privacy Act, as amended by the CPRA, Playcamp provides the following disclosures regarding the “Sale” and “Sharing” of personal information:
  • A. Directed Disclosures to Game Companies (Not a “Sale”): The core purpose of the Playcamp Service is to enable Content Creators to be matched and discovered by Game Companies. When you register as a Creator and apply for a campaign or make your profile “Public” or “Discoverable,” you are intentionally directing Playcamp to disclose your profile information (including display name, audience metrics, and portfolio) to these third-party Game Companies. Under California law (Civ. Code § 1798.140(ad)(2)(A)), this intentional interaction does not constitute a “Sale” or “Sharing” of personal information, as you have directed us to disclose this data to perform the Service.
  • B. “Sharing” for Analytics and Advertising: Playcamp utilizes third-party advertising and analytics cookies (e.g., Google Analytics, Meta Pixel) to improve our Service and deliver relevant advertisements. Under the broad definition of the CPRA, allowing these third parties to collect data from your device may technically constitute “Sharing” for cross-context behavioral advertising.
    • Categories Shared: Internet or other electronic network activity information (e.g., browsing history, IP address).
  • C. No Sale of Data to Brokers: We do not sell your personal information to data brokers or third parties for their independent use outside of the context of providing the Playcamp Services.

Article 5: Entrustment of Personal Information Processing
  1. Purpose of Entrustment To ensure the smooth and efficient provision of our Services, Playcamp entrusts certain personal information processing tasks to specialized external service providers. We select these trustees based on their ability to protect your data and comply with relevant privacy laws. In accordance with the Personal Information Protection Act, we enter into written agreements with these providers that stipulate data protection obligations, prohibitions on using data for other purposes, and liability for security incidents. We strictly supervise these providers to ensure they handle your personal information safely.
  2. List of Trustees and Tasks We entrust the processing of personal information to the following entities for specific tasks:
  • Infrastructure and Data Storage: We use Amazon Web Services (AWS) and/or Google Cloud Platform to host our website, store user data, and manage our database infrastructure. These providers ensure the physical security and availability of the servers where your data resides.
  • Payment and Settlement Processing: For processing payouts to Content Creators and billing Game Companies, we entrust payment information to global payment processors (e.g. Stripe, Payoneer, Tipalti, Toss, PayPal). These providers handle the verification of bank accounts and the execution of monetary transfers.
  • Identity and Age Verification: To comply with age restrictions and anti-money laundering (AML) laws, we entrust identity verification tasks to specialized providers such as K-ID (or similar global verification services). These providers verify government-issued IDs and confirm age eligibility, especially for minors.
  • Customer Support and Communication: We entrust customer service tools (such as Zendesk) and email delivery services (such as Mailchimp or SendGrid) with your contact information to manage support tickets, send service notifications, and deliver newsletters to which you have opted in.
  1. Supervision and Changes We conduct regular checks to ensure these trustees process personal information securely. If the contents of the entrusted work or the trustees change, we will disclose such changes through this Privacy Policy without delay.

Article 6: International Transfer of Personal Information
  1. Cross-Border Data Transfers Due to the global nature of our Service, including the use of cloud computing and international payment networks, your personal information may be transferred to, stored, or processed in countries outside of your residence, specifically the United States, Singapore, and Korea.
  2. Details of International Transfers The specific details regarding the overseas transfer of personal information are as follows:
  • Cloud Infrastructure (Storage): Your account information, profile data, and usage logs are transferred to Amazon Web Services (AWS) located in the US, Singapore, and Korea. This transfer occurs via encrypted network transmission at the time of your signup and during your use of the service.
  • Payment Processing: To facilitate global payouts, financial data (bank account, tax ID, wallet address and chain information) of Creators is transferred to global payment processors(e.g. Tipalti, Payoneer, Toss, Stripe) located in the United States.
  • Third-Party API Integration: To provide analytics, data regarding your social media channels (e.g. YouTube, Twitch, Soop) is exchanged with relevant companies(e.g. Google, Twitch, Soop) located in the United States and Korea. This data transfer is continuous while your account is linked.
  1. Legal Safeguards for EU Users For users located in the European Economic Area (EEA), any transfer of your personal data to countries that have not been recognized by the European Commission as providing an adequate level of data protection (such as the United States) is protected by Standard Contractual Clauses (SCCs) approved by the European Commission, or through reliance on the EU-U.S. Data Privacy Framework where the recipient is certified.
  2. Right to Refuse Transfer Users have the right to refuse the overseas transfer of their personal information. However, please be advised that the transfers listed above are essential for the operation of the Playcamp platform. Therefore, if you refuse the transfer of mandatory items, we may be unable to provide you with our Services, and your account may need to be deactivated.

Article 7: Period of Retention and Destruction
  1. General Retention Principle In principle, Playcamp destroys personal information without delay once the purpose of its collection and use has been achieved. This typically means that when you withdraw your membership or request the deletion of your account, your personal information will be destroyed immediately, subject to a grace period of 30 days to prevent accidental deletion or to handle disputes.
  2. Retention Required by Relevant Laws Notwithstanding the above, we are required by specific laws in the Republic of Korea and other jurisdictions to retain certain information for a fixed period, even after you have deleted your account. We will store this data separately from other user data and will not use it for any other purpose. The specific retention grounds are as follows:
  • Records on Contracts and Withdrawal of Subscription: Retained for 5 years in accordance with the Act on the Consumer Protection in Electronic Commerce.
  • Records on Payment and Supply of Goods: Retained for 5 years in accordance with the Act on the Consumer Protection in Electronic Commerce.
  • Records on Consumer Complaints or Dispute Resolution: Retained for 3 years in accordance with the Act on the Consumer Protection in Electronic Commerce.
  • Website Visit Records (Login Logs): Retained for 3 months in accordance with the Protection of Communications Secrets Act.
  • Tax and Financial Records: Information related to payouts, withholding taxes, and tax identification numbers is retained for the minimum number of years as required in Korea, US, EU and other jurisdictions.
  1. Procedure and Method of Destruction When the retention period expires or the purpose of processing is achieved, Playcamp destroys personal information irreversibly using the following methods:
  • Electronic Files: Files stored in digital format are permanently deleted using technical methods (such as low-level formatting) that make the records impossible to reproduce or restore.
  • Printed Documents: Personal information printed on paper is destroyed by shredding or incineration.

Article 8: Rights of Users and Legal Representatives
  1. Rights of Users You have the right to exercise control over your personal information at any time. Specifically, you may request to view (access), correct, delete, or suspend the processing of your personal information held by Us. You may exercise these rights directly through contacting our Privacy Officer via email.
  2. Limitations on Rights Please note that your request to delete personal information may be denied if the collection of that information is mandatory under other laws (e.g., we cannot delete tax records upon request if the law requires us to keep them for 5 years). Additionally, if you request the suspension or deletion of mandatory information required to provide our Services (such as your email or bank account for payouts), we may be unable to continue providing the Service to you, resulting in the termination of your account.
  3. Exercise of Rights You may exercise your rights by submitting a request in writing via email to our Chief Privacy Officer. We will verify that the person making the request is the data subject or a legitimate legal representative before processing the request. If you believe that your personal information has been infringed, you also have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.

Article 9: Protection of Minors (Age Restrictions)
  1. Strict Age Limitation Playcamp Services are strictly intended for users who are at least 18 years of age or older, if required by the laws of your country of residence to use the Services without parental approval.
  2. No Collection from Minors We do not knowingly collect, use, or process personal information from children under these age thresholds. If you are under the required age, do not use or register for the Services.
  3. Automatic Deletion If we discover that we have inadvertently collected personal information from a child under the applicable age threshold (14 in Korea, 13 in the US/Global) without valid parental consent (which Playcamp does not currently support), we will take immediate steps to delete that information and terminate the associated account.
  4. Reporting If you are a parent or guardian and believe that your child under the age of 13 (or 14 in Korea) has provided us with personal information, please contact our Chief Privacy Officer immediately at legal@playcamp.io so that we can remove the data.
Article 10: Measures to Ensure Safety of Personal Information
  1. Administrative Measures To ensure the systematic protection of personal information, Playcamp has established and implemented an internal management plan. We operate a privacy protection process and conduct regular training for all employees handling personal information to ensure they understand their obligations and compliance requirements. We limit access to personal information to the minimum number of personnel necessary to perform their duties.
  2. Technical Measures We implement high-standard technical measures to prevent the loss, theft, leakage, forgery, or damage of personal information. First, personal information is transmitted safely over the network using encrypted communication protocols (TLS). Important data, such as passwords, unique identification numbers (including Social Security Numbers), and financial account numbers, are stored in encrypted formats using industry-standard algorithms (such as AES-256) that cannot be easily decrypted. We strictly control access to the database systems that process personal information, grant access rights based on the principle of least privilege, and maintain records of system access for a minimum period to prevent misuse. Furthermore, we use security programs such as firewalls and antivirus software to monitor for and block hacking attempts, computer viruses, and other unauthorized intrusions.
  3. Physical Measures Our servers and data storage systems are housed in secure third-party data centers (e.g., Amazon Web Services and Google Cloud Platform) that maintain strict physical security controls. These facilities restrict physical access to authorized personnel only and employ surveillance systems, access control readers, and environmental controls to protect the hardware from physical threats such as disasters or intrusion.

Article 11: Matters Concerning Automatic Collection Tools
  1. Definition and Purpose of Cookies Playcamp uses “cookies” and similar automatic data collection technologies to store and retrieve information about your usage of our Service. A cookie is a small text file sent by the server used to operate a website to your computer or mobile device browser and stored on your hard drive. We use these tools to maintain your login session, remember your preferences (such as language settings), analyze traffic and usage patterns to improve our Service, and provide optimized and customized information, including targeted advertisements.
  2. Installation, Operation, and Rejection of Cookies You have the right to choose whether to install cookies. You can exercise this option by adjusting the settings in your web browser. You may allow all cookies, confirm each time a cookie is saved, or refuse the storage of all cookies.
  • For Google Chrome: Go to Settings > Privacy and Security > Cookies and other site data.
  • For Microsoft Edge: Go to Settings > Cookies and site permissions.
  • For Safari: Go to Preferences > Privacy.
Please be advised that if you refuse the storage of cookies, you may experience difficulties in using certain parts of our Service that require login or authentication.
  1. Use of Third-Party Analytics We may use third-party analytics tools, such as Google Analytics, to better understand how users interact with our website. These tools may collect information such as your IP address, browser type, and pages visited. The information generated by the cookie about your use of the website will be transmitted to and stored by these third-party providers on servers in the United States or other locations. You can opt-out of Google Analytics specifically by installing the “Google Analytics Opt-out Browser Add-on” provided by Google.

Article 12: Chief Privacy Officer and Regional Representatives
  1. Designation of Chief Privacy Officer (CPO) To protect your personal information and handle complaints or disputes arising from the processing of personal data, Playcamp has designated a Chief Privacy Officer (CPO) in accordance with Article 31 of the Personal Information Protection Act (Korea). The CPO is responsible for the oversight of all internal data protection practices. If you have any questions about how your Personal Data is processed, or if you wish to exercise your rights, you may contact us using the details below:
  • Company Name: Smartplay Inc.
  • Representative: Won Il Sue
  • Address: Bundanggu Pangyoro, Pangyo Innovalley, 402-B, B-dong, Gyeongido, Korea
  • Business Registration Number: 501-88-03298
  • Privacy Contact Email: legal@playcamp.io
  You may contact our CPO regarding matters pertaining to the processing of your personal data.
  1. Representative
We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:
  • United Kingdom (UK)
  • European Union (EU)
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website:https://app.prighter.com/portal/11579825222 Exercise your data subject rights under GDPR We provide you with an easy way to submit us privacy related request like a request to access or erase your personal data. If you want to make use of your data subject rights, please visit our Trust Center: https://app.prighter.com/portal/11579825222   Article 13: Remedies for Infringement on Rights
  1. Internal Dispute Resolution If you are dissatisfied with Playcamp’s handling of a privacy complaint or the results of a damage relief request, you may first contact our Chief Privacy Officer. We are committed to resolving all valid disputes amicably and internally within a reasonable timeframe.
  2. Global Remedies (EU, UK, and US) Users residing outside of Korea also have the right to lodge a complaint with their local supervisory authority:
  • For EU Residents: You have the right to lodge a complaint with the Data Protection Authority (DPA) in the country where you reside.
  • For UK Residents: You may contact the Information Commissioner’s Office (ICO) at ico.org.uk.
  • For California Residents: If you believe we have violated the CCPA, you may file a consumer complaint with the Office of the Attorney General of California.
  1. Domestic Remedies (Republic of Korea) If you fail to receive adequate relief from us, or if you wish to report a privacy infringement or seek consultation from an external authority, you may contact the following agencies in the Republic of Korea:
  • Personal Information Infringement Report Center (operated by KISA): 118 (without area code) | privacy.kisa.or.kr
  • Personal Information Dispute Mediation Committee: 1833-6972 | www.kopico.go.kr
  • Supreme Prosecutors’ Office (Cybercrime Investigation Division): 1301 | www.spo.go.kr
  • Korean National Police Agency (Cyber Bureau): 182 | cyberbureau.police.go.kr
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