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PlayCamp Privacy Policy

Effective Date: October 20, 2026
This Policy is provided in Korean and English. The Company keeps both versions consistent and corrects any discrepancy promptly once found.

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Revision History

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Article 1 (General Provisions and Personal Information Controller)

  1. Purpose and Scope. This Privacy Policy (the “Policy”) explains the principles and standards by which SmartPlay Inc. (including its subsidiaries and affiliates, the “Company” or “PlayCamp”) processes users’ personal information. This Policy applies to all services provided by the Company, including our website, creator matchmaking platform, and related services. The Company processes personal information responsibly in accordance with applicable laws, including the Personal Information Protection Act (PIPA) of the Republic of Korea, the EU General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA).
  2. Application. This Policy applies to “Creators” (individuals or businesses registered to offer content creation services), “Game Companies” (representatives of game studios, publishers, or agencies), and “Visitors” (individuals browsing the PlayCamp website without an account).

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Article 2 (Purposes of Processing)

  1. Member Management and Identification. We process personal information to confirm your intent to register, identify and authenticate users, manage accounts, and deliver notices about service or policy changes.
  2. Matchmaking and Platform Services. The core purpose of PlayCamp is to facilitate collaborations between content creators and game companies. We process personal information to operate our 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 bill for platform services, including verifying bank account details to prevent fraud and ensure correct routing. In addition, in accordance with the Income Tax Act, the Value Added Tax Act, and other tax laws, we process unique identification information (such as Korean Resident Registration Numbers or US Social Security Numbers) solely for tax withholding and reporting (e.g., to the National Tax Service of Korea or the US Internal Revenue Service).
  4. Service Improvement and Marketing. We process automatically collected data and usage history to analyze usage patterns, improve website functionality, and ensure IT system stability. With your consent, we may send newsletters, promotional offers, or information about new game campaigns that may interest you. You may withdraw your consent to marketing communications at any time.

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Article 3 (Items of Personal Information and Collection Methods)

We collect the following items to provide the service features you request, depending on how you use the Services.
  1. Creators. When you register as a Creator, we collect the mandatory account information needed to identify you and manage your account: email address, password (stored encrypted), display name or gamertag, and date of birth for age verification. To facilitate campaign participation, we may collect optional profile information such as your introduction, profile images, social media handles, Discord ID, and preferred game genres. To process payouts for completed campaigns, we collect mandatory financial information, including bank account number, bank name, SWIFT/IBAN code, payment service account email address, and wallet address. In addition, solely to fulfill 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.
  2. Game Companies. When you create a Game Company account, we collect business contact information, including the name of your representative, job title, company email address, and phone number. To verify your business entity, we collect your company name, business registration number (or local equivalent), and business address. To process payments for platform fees or creator funding, we collect billing information, including payment history, credit information, and billing address.
  3. Automated Collection via Third-Party APIs. To provide matchmaking and analytics, PlayCamp uses API services from third-party platforms. By using the Platform and linking your third-party accounts, you acknowledge and agree to the following:
    • YouTube: Our Services use YouTube API Services. By using PlayCamp, you agree to be bound by the YouTube Terms of Service and the Google Privacy Policy. You can revoke PlayCamp’s access to your data at any time via the Google Security Settings page. Statistical data collected via the YouTube API (including channel and video metrics such as subscriber counts and view counts) is stored and displayed for a maximum of 30 days from the time of collection, after which it is automatically refreshed (re-fetched) or deleted. This complies with the YouTube API Services Developer Policies (Policy III.E.4.a-g).
    • Twitch: We collect data in accordance with the Twitch Developer Services Agreement. When you connect your account, Channel ID(s), channel metrics (including subscriber counts and view counts), lists of videos, and video metrics (including views, likes, and comments) are automatically collected and stored.
    • TikTok: Our Services use the TikTok for Developers API. By connecting your TikTok account to PlayCamp, you agree to be bound by the TikTok Terms of Service and the TikTok Privacy Policy. You may disconnect your TikTok account and revoke PlayCamp’s access at any time via your TikTok app settings under “Security & Login” > “Manage App Permissions.”
    • SOOP: Our Services integrate with SOOP. By using PlayCamp and linking your SOOP account, you agree to be bound by the SOOP Terms of Service and acknowledge the SOOP Privacy Policy. You authorize PlayCamp to access your public profile information, stream metrics, and content data as permitted by the SOOP Open Platform for campaign reporting and creator matchmaking.
  4. Automatically Collected Information. When you visit our website or use our platform, the following technical information is automatically generated and recorded to ensure service stability, prevent fraud, and improve our website: IP address, browser type and version, operating system (OS), visit history, referral URLs, connection logs, cookies, and device information.
  5. Identity Verification (KYC) Information at Withdrawal. When a Creator requests a withdrawal of earnings, we require identity verification (KYC), and we collect identity verification (KYC) information at withdrawal for that purpose.

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Article 4 (Processing and Retention Period)

  1. General Principle. The Company destroys personal information without delay once the purpose of collection and use has been achieved. When you withdraw your membership or request account deletion, your personal information is destroyed after a 30-day grace period to prevent accidental deletion and to handle disputes.
  2. Retention Required by Law. Notwithstanding the above, information that must be retained after account deletion under the laws of the Republic of Korea or other jurisdictions is stored separately from other data and is not used for any other purpose.

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Article 5 (Procedure and Method of Destruction)

When the retention period expires or the purpose of processing is achieved, the Company destroys personal information irreversibly using the following methods:
  • Electronic files: Permanently deleted using technical methods (such as low-level formatting) that make the records impossible to reproduce or restore.
  • Printed documents: Shredded or incinerated.

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Article 6 (Provision of Personal Information to Third Parties)

The Company processes your personal information within the purposes in Article 2 and provides it to third parties only in the following cases. The recipients, purposes, items, and retention periods are as set out in Third-Party Provision of Personal Information.
  1. Provision to Game Companies. For campaign operation, when a Creator participates in a campaign, we provide the game company that created the campaign (game developers and publishers) with the Creator’s channel name, email address, content upload/streaming status, and contribution performance. This information is provided solely to identify campaign participants, verify contribution, and provide performance reports. Game companies act as independent controllers of this data once received and must process it in compliance with applicable laws.
  2. Provision to Collaboration Partners. If you participate in specific “Creator Programs” or joint events, we may share your email address and contact details with the collaboration partners of that program to deliver merchandise, rewards, or mission instructions.
  3. Legal and Regulatory Disclosures. Where strictly required by law, we may disclose personal information to the following without your consent:
    • Tax authorities: The National Tax Service (Korea), the IRS (US), or other tax bodies for income reporting and tax withholding.
    • Investigative agencies: The police, prosecutors, or courts for criminal investigations or legal proceedings conducted under valid legal procedures (e.g., warrants or subpoenas).
  4. Business Transfers. In the event of a merger, acquisition, or sale of all or part of our business, personal information may be transferred to the acquiring entity to ensure service continuity. We will notify you in advance and give you the option to withdraw your consent.
  5. Notice to California Residents (CCPA/CPRA): “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 Creators to be matched with and discovered by Game Companies. When you register as a Creator and apply for a campaign or make your profile “Public” or “Discoverable,” you intentionally direct 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.
    • B. “Sharing” for Analytics and Advertising: PlayCamp uses third-party advertising and analytics cookies (e.g., web analytics and ad measurement services) 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 the context of providing the PlayCamp Services.

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Article 7 (Entrustment of Personal Information Processing)

  1. Purpose of Entrustment. To provide the Services smoothly, the Company entrusts certain personal information processing tasks to specialized external service providers. In accordance with the Personal Information Protection Act, we enter into written agreements with these trustees that stipulate data protection obligations, prohibition of use for other purposes, and liability for security incidents, and we supervise them to ensure your personal information is handled safely.
  2. Trustees and Entrusted Tasks.
Information on trustees is available on request at contact@playcamp.io.
  1. Supervision and Changes. We regularly check that trustees process personal information securely. If the entrusted tasks or trustees change, we will disclose the changes through this Policy without delay.

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Article 8 (International Transfer of Personal Information)

  1. Cross-Border Transfers. Due to the global nature of the Service, including cloud computing and international payment networks, your personal information may be transferred to, stored, or processed in countries outside your residence (the United States, Singapore, and Korea).
  2. Transfer Details.
Information and contact details of recipients are available on request at contact@playcamp.io.
  1. Legal Safeguards for EU Users. For users located in the European Economic Area (EEA), any transfer of personal data to countries not recognized by the European Commission as providing an adequate level of protection (such as the United States) is protected by Standard Contractual Clauses (SCCs) approved by the European Commission, or by the EU-U.S. Data Privacy Framework where the recipient is certified.
  2. Right to Refuse Transfer. You have the right to refuse the overseas transfer of your personal information. However, the transfers above are essential to operating the PlayCamp platform; if you refuse the transfer of mandatory items, we may be unable to provide the Services and your account may need to be deactivated. You can notify us of your refusal using the contact details in Article 13.

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Article 9 (Rights and Obligations of Data Subjects and Legal Representatives)

  1. Your Rights. You may at any time request access to, correction, deletion, or suspension of processing of your personal information held by the Company.
  2. Limitations. Deletion requests may be denied for information that other laws require us to collect (e.g., tax records that must be kept for 5 years by law). If you request suspension or deletion of information required to provide the Services (such as your email or bank account for payouts), we may be unable to continue providing the Services, and your account may be terminated.
  3. How to Exercise Your Rights. You may submit a written request by email to the Privacy Officer in Article 13. We will verify that the requester is the data subject or a legitimate representative before processing the request. If you believe your personal information has been infringed, you may also lodge a complaint with the data protection authority in your jurisdiction.

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Article 10 (Restriction on Users Under 18)

  1. Age Limitation. PlayCamp Services are available only to users aged 18 or older.
  2. No Collection from Minors. We do not knowingly collect, use, or process personal information from persons under 18 (including children under 14), and we do not accept registrations through parental or guardian consent. Persons under 18 may not register for or use the Services.
  3. Deletion. If we learn that we have collected personal information from a person under 18, we will immediately delete that information and terminate the associated account.
  4. Reporting. If you are a parent or guardian and believe your child has provided us with personal information, please contact our Privacy Officer immediately at contact@playcamp.io so that we can remove the data.

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Article 11 (Measures to Ensure the Safety of Personal Information)

  1. Administrative Measures. The Company has established and implemented an internal management plan to protect personal information systematically and provides regular training to all employees who handle personal information. Access to personal information is limited to the minimum number of personnel necessary.
  2. Technical Measures. We implement high-standard technical measures to prevent the loss, theft, leakage, forgery, or damage of personal information. Personal information is transmitted over encrypted protocols (TLS), and important data such as passwords, unique identification numbers (including Social Security Numbers), and financial account numbers are stored encrypted using industry-standard algorithms (such as AES-256). We strictly control access to systems processing personal information, grant access rights under the principle of least privilege, and keep access records for a minimum period to prevent misuse. We also use security programs such as firewalls and antivirus software to monitor and block hacking attempts, computer viruses, and other unauthorized intrusions.
  3. Physical Measures. Our servers and data storage systems are housed in external data centers (the infrastructure trustees in Article 7) with strict physical security controls. These facilities restrict physical access to authorized personnel and use surveillance systems, access control readers, and environmental controls to protect hardware from physical threats such as disasters or intrusion.

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Article 12 (Installation, Operation, and Refusal of 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 use of the Service. A cookie is a small text file sent by the server operating a website to your computer or mobile browser and stored on your device. We use cookies to maintain your login session, remember your preferences (such as language), analyze traffic and usage patterns to improve the Service, and provide optimized information, including targeted advertisements.
  2. Installation, Operation, and Refusal. You can choose whether to accept cookies by adjusting your web browser settings. You may allow all cookies, confirm each time a cookie is saved, or refuse all cookies.
    • Google Chrome: Settings > Privacy and Security > Cookies and other site data
    • Microsoft Edge: Settings > Cookies and site permissions
    • Safari: Preferences > Privacy
    If you refuse cookies, you may have difficulty using parts of the Service that require login or authentication.
  3. Third-Party Analytics. We may use third-party analytics tools, such as web analytics services, to understand how users interact with our website. These tools may collect information such as your IP address, browser type, and pages visited, and the information generated by cookies is transmitted to and stored on these providers’ servers in the United States or other locations. You can opt out by installing an opt-out tool offered by the analytics provider or by changing your browser cookie settings.

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Article 13 (Privacy Officer and Regional Representatives)

  1. Privacy Officer. To protect your personal information and handle complaints or disputes related to its processing, the Company has designated a Privacy Officer in accordance with Article 31 of the Personal Information Protection Act (Korea). For questions about how your personal information is processed or to exercise your rights, please contact:
  1. Regional Representatives. We value your privacy and your rights as a data subject and have 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). To contact us via our representative Prighter or to exercise your data subject rights under the GDPR, please visit: https://app.prighter.com/portal/11579825222

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Article 14 (Remedies for Infringement of Rights)

  1. Internal Dispute Resolution. If you are dissatisfied with the Company’s handling of a privacy complaint or the result of a damage relief request, please first contact our Privacy Officer. We are committed to resolving valid disputes amicably within a reasonable timeframe.
  2. Global Remedies (EU, UK, and US). Users residing outside Korea may lodge a complaint with their local supervisory authority:
    • EU residents: The Data Protection Authority (DPA) in your country of residence.
    • UK residents: The Information Commissioner’s Office (ICO) at ico.org.uk.
    • 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.
  3. Domestic Remedies (Republic of Korea). If you do not receive adequate relief from us, or wish to report a privacy infringement or seek consultation from an external authority, you may contact:
    • 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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Article 15 (Changes to This Policy)

  1. When we add, delete, or modify this Policy, we will announce the changes and the effective date on the service screen at least 7 days before the effective date.
  2. For significant changes affecting your rights, such as changes to collected items, purposes of use, or third-party provision, we will announce them at least 30 days before the effective date and notify you individually by email or similar means.
  3. The revision history of this Policy is shown in the table at the top.

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Addendum

  1. This Policy takes effect on October 20, 2026.
  2. Personal information is provided to third parties only within the items and purposes you consented to.