Privacy Policy

Last updated: 2026-10-20 (version 2026-10-20-v18)

This policy has two parts: the general text below, which applies everywhere, and an integration for Thailand, which applies to you. Read them together.

Last revised: 2026-10-20 (version 2026-10-20-v18 — the chat with your opponent in a match still to be played is now part of the service: it is how the match gets arranged, so it no longer depends on the chat consent, which now covers only the chat outside your matches. Read receipts: in a one-to-one chat the other participant sees whether you have read the messages and up to which one (sections 2 and 3, and section 2 of the Thailand integration printed below this policy). Notifications on an iPhone now go from our server straight to Apple, without passing through Google (sections 11 and 12). That is why you are asked to accept again. Nothing else about what we collect, why, or for how long has changed.)

This Privacy Policy explains how MeetPlayNow ("we", "us", "the platform") collects, uses, and protects personal data of players, organizers, and visitors. It is written to the standard of the EU General Data Protection Regulation (GDPR), which we apply to everyone wherever they play, and it is completed by a country integration for each market whose own law requires something different — see section 7.

1. Data Controller

The data controller for personal data processed through MeetPlayNow is:

GiBSeS OÜ Juhkentali tn 8, Kesklinna linnaosa 10132 Tallinn, Harju maakond Estonia Registered in the Estonian Business Register (Äriregister) under registry code 17231761 Email for privacy matters: privacy@meetplaynow.com

GiBSeS OÜ is registered in Estonia (EU) and there is one controller for every market: the address and the email above are the ones to write to wherever you play. Where a country's law asks us to name a local point of contact as well, that country's integration says so.

2. Data We Collect

We collect only data needed to operate the platform:

  • Account data: email address (required for account creation), hashed password, locked/disabled status, audit timestamps.
  • Date of birth (required): collected at sign-up, and asked once of accounts created before 2026-08-08. We use it for the age rules and nothing else. There are two: it decides whether an account may be opened at all — MeetPlayNow is not offered to people under the minimum age set out in our Terms, and a date of birth below it means the account is refused rather than created — and it applies the rule that a photo of a person under 18 is never published outside the platform (section 10). It is not shown on your profile, is not used to profile you, and is not passed to anyone. Until it is given, we treat the account's age as unknown, which for the photo rule has the same effect as being under 18 — the photo is not published outside the platform. It does not close an account that already exists: the registration threshold applies when an account is opened.
  • Profile data: the display name you choose, which is the name this service shows other people and publishes in the public ranking; a public handle (slug) derived from it; your sport ratings, computed from your match results. Two further fields are optional and are published only if you ask us to: a profile photo and a short biography. Each has its own consent, each can be withdrawn on its own, and until you give it the field is not shown to anybody but you.
  • Optional contact data: phone number (used only for tournament-related warnings if you opt in).
  • Operational data: IP address and user agent at login, signup, and consent events (for security audit and fraud prevention).
  • Tournament data: registrations, the category you declare when you enter an event (Rookie, Challenger or Elite — the one you would prefer to play in, which you choose yourself and which is not derived from your rating), payment receipts, match results, ranking history.
  • Billing data (only if you choose to provide it): legal name, VAT number, billing address — collected exclusively for invoice issuance under Estonian fiscal law.
  • Prize delivery data (only if you are due a physical prize): the recipient name, delivery address and phone number we need in order to send you a trophy or an object you won. We ask for it when the final of your competition is drawn — which is before it is played, so that a trophy can reach a finalist in time to be handed over on court — and we ask only the people the prize may go to, never every entrant. The phone number is required because couriers in Thailand call before delivering and a parcel with no number on it is returned to us. It is stored on your account, not on a single shipment, so that you type it once and it is already there the next time you win something: you can see it, change it and delete it at any time in /dashboard/prizes, with or without a prize on its way. This is not your billing data above and neither is used for the other: that is a fiscal record kept for invoicing, this is a courier's instructions. When we actually post a parcel we also keep a frozen copy of the address it was sent to — see section 4.
  • Credits wallet data: your credit balance and an append-only ledger of credit movements (grants, purchases, spends, refunds) with amounts, reasons, and timestamps — used to operate the wallet and as accounting records of credit purchases.
  • Chat with your opponent in a match (part of the service): while a match of yours is still to be played or in progress, the messages you exchange with the player or players on the other side of that match, any image you attach to them, and the list of participants in the conversation. This chat is how a match gets arranged — the date, the time, the venue, a change of plan — so it is processed to perform the contract (section 3) and does not depend on the chat consent described in the next point: you can write to your opponent, and your opponent can write to you, even if you have not given that consent or have withdrawn it. Blocking a player in the chat still stops it in both directions. The organizer announcements addressed to you for a competition you entered belong here too. See section 4 for how long they are kept.
  • Other player-to-player chat data (only if you opt in): the messages you exchange with other players outside a match still to be played — for example with an opponent once all your matches against them are over — any image you attach to them, and the list of participants in each conversation. You give this consent when you create your account; you can withdraw it at any time in /dashboard/privacy, and from then on nothing new you send or receive there is processed. Withdrawing it does not stop the chat with your opponent in a match still to be played (previous point). See section 4 for how long they are kept.
  • Read receipts: in a direct chat between two people, the other participant sees whether you have read the messages and up to which one, and you see the same about them. There are none in a competition's announcements, in a dispute thread or in a conversation with our support, and none between two players once either of them has blocked the other. To show this we record, for each conversation, the point up to which each participant has read it; it is used for nothing else.
  • Dispute-channel data (only if the result of one of your matches is contested): the messages you, the other player, and the member of our staff handling the case exchange in the channel opened for that case, and any image attached to them. This is not part of the player-to-player chat consent above: it is how a contested result gets decided, so the channel exists whether or not you have chat enabled, and withdrawing chat consent does not take you out of it. See sections 3 and 4.
  • Match photos (only if you upload one): the image file itself, the people visible in it, the match and tournament it is attached to, who uploaded it and when, and the technical metadata the file carries. See section 10 below.
  • Chatbot data (only if you opt in): conversation transcripts with Khun Somtum and the locale you used. See section 9 below.
  • Mobile app data (only if you use the MeetPlayNow app): an identifier for that installation of the app, a device label and the platform it runs on (`android` or `ios`), the moment each session was last used, the language your phone is set to, and — only if you allow notifications — the push notification token of that installation. Section 11 sets out each one, what it is for, and how long it is kept. The app also reaches for your camera, your photos, your clipboard and your fingerprint sensor in four narrow places, all described in the same section. If you sign in with Apple and hide your email address, the relay address Apple gives us takes the place of your email address above — section 11.
  • Advertising measurement and campaign attribution data (only if you allow marketing cookies on the website, or turn on "Advertising measurement" in the Android app): described in full in section 8 for the website and in section 11 for the app. The iPhone app takes no part in it: nothing is recorded from it for this purpose, and nothing done in it is reported to Meta. When you create your account we record once, on your account, where you came from. On the website that is the Meta click identifier (`fbclid`) and the `utm_` tags carried by the address you landed on, that address itself, the page that referred you, the Meta cookies `_fbp` and `_fbc` if your browser has them, your IP address and browser user agent at that moment, and the time. In the Android app it is a description of the device — platform, the app's identifier, app version and build, operating system version, model, language, time zone, and screen size and density — together with your IP address and the app's user agent at that moment. Our server then reports two events to Meta: an account created, and a payment completed (with the amount, the currency, our internal order number, and the name and identifier of the competition). Each carries your email address and user id as SHA-256 hashes, plus the IP address, user agent and cookies (website) or device description (Android app) of that record. On the website the Meta Pixel in your browser separately reports the pages you view and the start of a checkout (with the amount and the competition). It runs with Meta's automatic event collection switched off, our code gives it no email address and no user id, and it is not loaded at all on the pages where you type personal data (section 8); the creation of your account reaches Meta only from our server. The app reads no advertising identifier — no Google advertising ID, no Apple IDFA — and shows no Apple "allow tracking" prompt. Versions of the app released before 28 September 2026 did read one when the switch was on: if your account was created with one of them, the identifier recorded then is still on your record and still travels with the two events. Section 4 says how to have it erased.

We do not collect special categories of data (health, biometrics, political opinions, religion, etc.). This includes the fingerprint or face you may use to unlock the app: that check is performed by your phone and its result — yes or no — is all the app ever learns. See section 11.

Forms that need no account, and being named as a partner

Three forms on the website are open to people without an account, and one email reaches an account because another player named it.

  • Waiting list for a city. You choose a city from our list and the formats you would like to play, and give your email address; we also keep the language of the page. We then send one email asking you to confirm, and until you do the request is not counted and nothing else is sent to you. Alongside the address we store a SHA-256 fingerprint of it, which stops the same person being counted twice, and a SHA-256 hash of your network — the first part of your IP address, never the full address — which lets us spot mass voting. No name and no browser user agent are stored. We write to that address only about that city: the confirmation, a notice when its waiting list reaches the threshold we publish, and a notice when it opens. Every one of those emails carries a link that deletes your request at once, without an account. Legal basis: your consent (Art. 6(1)(a)), completed by the confirmation.
  • Waiting list for the shop. Your email address, the language of the page, the time you signed up, and your IP address and browser user agent at that moment, which are our record of your consent. We use the address for one thing: to tell you when the shop opens. Legal basis: your consent (Art. 6(1)(a)).
  • Contact form. Your name, your email address, the subject and your message and, if you are signed in, the email address and id of your account. The message is not stored in our database: it is delivered as an email to our support inbox, and we answer from there. Our security log records that a message was sent, its language and its length — never its content — together with your IP address and browser user agent, as every entry in that log does; your IP address is also used to limit how many messages one connection can send per hour. Legal basis: our legitimate interest in answering you (Art. 6(1)(f)), or the contract, when you write about your account or an entry.
  • Being named as a doubles partner. A player who enters a doubles event names their partner by email address. That address must already belong to a MeetPlayNow account — we never write to an address that is not one — and we send that account one email saying who named it and for which competition, with the page where the invitation can be accepted or declined. It is a service email, sent to perform the contract of the account that receives it (Art. 6(1)(b)).

What is public here, and what is not

MeetPlayNow is a public competition. A ranking nobody can see is not a ranking, and a result that disappears when it is inconvenient is not a result — so taking part means your competitive record is public, and that is not something we ask your permission for: it is what the service is. Concretely, these are visible to anyone, with no account needed:

  • the display name you chose, your position, your rating and your results;
  • the category you declared for an event you have entered — it is shown beside your name in that event's public list of entrants, which anyone can read;
  • the player page that gathers that same record for one sport;
  • the city you play in — not as a field on your page, but because the ranking can be read one city at a time, and appearing in a city's board is what says you play there.

You are not obliged to compete under your legal name. The display name is yours to pick — a nickname is perfectly acceptable — and it is the only name of yours this service publishes. Your legal name is asked only if you need an invoice, and it is never shown to anybody.

Two things are not part of that, and stay off until you switch them on: your profile photo and your biography. A tournament is played without either. That includes the public list of entrants: your name and your declared category are in it because you entered, your photo appears beside them only if you have consented to your photo, and without that consent the entry simply shows no picture.

Search engines. Player pages are served with `noindex` and are not indexed. The public ranking page is a normal indexable page, so the display name you chose can appear in search results next to your position — which is one more reason the choice of name is yours.

Leaving. When an account is deleted, the display name, photo and biography go. Match results do not: they are your opponents' record as much as yours, so they stay with the identity removed. Section 4 sets out the detail.

We rely on the following legal bases:

  • Performance of a contract (Art. 6(1)(b)): account creation, tournament participation, payment processing, match scoring, the chat with your opponent in a match still to be played, and the organizer announcements for a competition you entered (section 2), the publication of your competitive record — display name, position, rating, results, and the category you declared for an event you entered — which is the service you signed up to and is described in "What is public here" above, and the delivery of a prize you won — the address and phone number in section 2 are asked for that delivery and nothing else, and are never used to contact you about anything. On the mobile app this also covers keeping you signed in without retyping your password (the installation identifier in section 11) and sending you the notifications the service is made of — a score entered against you, a match given a date, a decision on a dispute. We send no promotional push notifications, and the app's four notification switches govern service messages only. It also covers the service emails described in "The emails we send you" below.
  • Legitimate interest (Art. 6(1)(f)): security audit logs, fraud prevention, abuse moderation, platform integrity, and the handling of contested match results — including the dispute-management channel described in section 4, which is not consent-based because a contested result has to be decided one way or the other. It also covers the device list in the app: knowing which installations hold a live session is what lets you see where you are signed in and end a session you do not recognise, and it is what lets us detect a session token being replayed by somebody who stole it. It also covers the read receipts in a direct chat between two people (section 2): your opponent needs to know that the message arranging your match has been seen, and you need to know the same about theirs. You can object to it (section 5). There is no switch for it in the app or on the website yet: today you object by blocking that player, which stops the read receipts in both directions together with the chat, or by writing to privacy@meetplaynow.com.
  • Legal obligation (Art. 6(1)(c)): retention of payment and invoicing records under Estonian fiscal law.
  • Consent (Art. 6(1)(a)): non-essential cookies — including advertising measurement with Meta and the campaign attribution that goes with it, governed on the website by the marketing-cookie choice (section 8) and in the Android app by the "Advertising measurement" switch (section 11), which is the same consent given in two places —, promotional emails (see "The emails we send you" below), your profile photo and your biography — two separate consents, each withdrawable on its own, neither of which is a condition of anything (see "What is public here") — optional phone-number contact, player-to-player chat outside your matches (the chat with your opponent in a match still to be played is part of the contract above), chatbot interactions (see section 9), each of the two uses of a match photo — showing it on MeetPlayNow, and publishing it on social media and in promotional material — which are asked and recorded separately (see section 10), and the waiting lists for a city and for the shop (section 2).
  • Legal obligation and the protection of minors: date of birth is processed to apply the age rules in our Terms. Its collection is a condition of using the service, not a consent, and it is used for no other purpose.

You may withdraw consent at any time without affecting the lawfulness of processing carried out before the withdrawal. For photos published outside the platform, please read section 10: withdrawal stops future use and removes the photo from the channels we control, but it cannot recall what third parties have already copied or shared.

What we do not do. We do not profile you: nothing in MeetPlayNow uses your data to build a picture of your preferences or to personalise what you are offered, and we take no automated decision about you (section 5). We send no promotional push notifications and no SMS of any kind. Earlier versions of our sign-up and privacy screens offered switches named "profiling", "marketing push notifications" and "marketing SMS". No processing was ever based on them, and they are no longer offered on the website or in the current version of the app; older versions of the app may still show them, but the choice has no effect; an answer you gave to one of them stays in your consent ledger as a record of what you said, and is used for nothing else.

The emails we send you

We send three kinds of email, and they are governed by three different rules.

  • Promotional emails — new competitions, news about MeetPlayNow, and a reminder of the next steps a few days after you sign up if you have not yet entered a competition. We send them only if you have said yes (the "marketing emails" consent), and no is the default. The consent is recorded in your consent ledger with the date, the version of this policy you had in front of you and your IP address. You can withdraw it at any time, and each of these ways is enough on its own: the "Unsubscribe from these emails" link at the bottom of every one of these emails, the switch in /dashboard/privacy on the website or under Settings → Privacy in the app, or an email to privacy@meetplaynow.com. A withdrawal is recorded in the same way as the consent, and from then on you receive none of them.
  • One help message, if you have not entered a competition. If you created an account but have not entered a competition, we may write to you once, and never more than once, to ask whether something got in the way and to offer help. It contains no promotion. We send it on our legitimate interest (Art. 6(1)(f)) in finding out why somebody who wanted to play has not been able to, and not to anybody who has already used an "Unsubscribe from these emails" link. You can object with the same link, which it carries, or by writing to privacy@meetplaynow.com; that link also withdraws the promotional-email consent above, if you had given it.
  • Service emails — about your account (confirming your address, signing in, resetting your password, deleting your account, a change to these policies), your payments, receipts and refunds, the competitions you have entered, your matches and disputes, a prize being sent to you, and an invitation to play as somebody's doubles partner. They are necessary to perform the contract (Art. 6(1)(b)) and cannot be switched off; unsubscribing from the emails above does not stop them. The only way to stop them is to close your account.

Who delivers them. Every email we send goes out through Resend, Inc., in the United States, which delivers it on our behalf (section 12). Resend receives your email address and the content of each email. It tells us when an email bounces, when a recipient marks it as spam, and when a contact is unsubscribed on its side, and we treat each of those as a reason to stop writing to that address — never as a reason to start.

The contact copy for promotional emails. If — and only while — you have consented to promotional emails, Resend also holds a contact for you, so that a mailing can be prepared and sent from it: your email address, your first name (the first word of your display name), your language, the city or cities you play in, your sports, whether you are in a competition, and your personal unsubscribe link. It is placed in lists by language, by city, and for people not yet in a competition, so that an email about a city reaches the people who play there. Nobody without that consent is copied to Resend. When you withdraw, the contact is marked as unsubscribed and kept that way, so that it cannot be subscribed again by mistake; when your account is deleted, it is deleted.

4. Retention

  • Account data: kept while your account is active. On deletion or purge request, we anonymize personal identifiers and disable login.
  • Payment and invoicing records: retained for 7 years in line with Estonian fiscal obligations.
  • Credit purchase records: the ledger of purchased-credit transactions is retained for 7 years as part of our accounting and invoicing records under Estonian fiscal law.
  • Audit and security logs: retained for 12 months and then aggregated or deleted.
  • Consents ledger: retained as long as required to evidence the lawfulness of processing (typically lifetime of the account plus statutory limitation period).
  • Player-to-player chat messages: message content and any attached image are erased 90 days after the message was sent; the attached files are removed from our storage in the same operation. An empty record of the message (sender, conversation and timestamp, without any content) is retained so that abuse reports filed against that message, and the moderation history attached to it, are not lost. The 90 days run from the date of each individual message, including in conversations that are still active.
  • Dispute-channel messages: when the result of a match is contested, we open a channel dedicated to that case, containing the two players involved and the member of our staff handling it. Message content and any attached image in that channel are erased 365 days after the message was sent — not 90; the attached files are removed from our storage in the same operation, and the same empty record of the message is kept. The longer window is deliberate, and the reason is not a technical one: this channel is not a private conversation between players, it is the written record of a decision we took — one that changes a match result, changes a ranking, and can have money attached to it — and either player is entitled to challenge that decision after it has been made. Erasing the exchange at 90 days would leave the ruling on file with the reasons for it gone, which is why this material is kept on the same kind of clock as our audit and security logs rather than on the chat one. Who can read it: only the two players involved and our staff. It is never shown to other players, to organizers who are not handling the case, or to anyone outside the platform. After the decision: the channel is closed to new messages and stays readable by those same people, so you can always go back to what you were asked and what you answered; it is reopened only if the same case is taken up again, and it is never deleted in order to close a case. The 365 days run from the date of each individual message, exactly as the 90 days do.
  • Chatbot conversation transcripts: we keep no separate archive of them. The only durable copy is the execution record written by the automation platform that runs the chatbot, which that platform deletes automatically once it is more than 14 days old; operational backups of the server it runs on may hold a copy for longer. See section 9.
  • Match photos: kept for as long as the consent that covers them stands. When you withdraw a consent, or delete your account, the photo is removed from the platform and from the social media accounts and channels we control within 30 days. Copies already re-shared, screenshotted, indexed or printed by third parties are outside our reach — see section 10.
  • Prize delivery address: the address and phone number on your account are erased 90 days after the last prize delivery they served was completed, handed over or cancelled — and only once none of your deliveries is still open. The 90 days are not padding: a parcel that comes back, or a delivery you tell us never arrived, has to be re-sendable without asking you for the address again. If you have an address on file and have never had anything to deliver, we keep it as data you chose to store on your account; it is erased with the account, and you can delete it yourself at any moment in /dashboard/prizes. Deleting your account erases it in the same operation.
  • Record of a parcel we posted: when a prize is actually shipped we keep the courier, the tracking number and a frozen copy of the address the parcel was addressed to, for 12 months from dispatch, and then erase all three. This copy does not follow your address: if you change or delete your address afterwards, what a parcel already on its way was addressed to stays as it was. It is kept because it is the record of something we did, and it is what lets us answer you if you tell us a prize never arrived — the same reason, and the same window, as the audit and security logs above.
  • Date of birth: kept for the lifetime of the account, and erased with it.
  • Campaign attribution record: kept for the lifetime of the account and erased with it. It is written once and never updated — a later visit from another advertisement does not replace it. The cookies involved (`_fbp`, `_fbc` and our own `mpn_attrib`) expire on your browser after 90 days; the Cookie Policy lists them. What we have reported to Meta is held by Meta under its own retention rules (section 8).
  • Device description (app), and an advertising identifier recorded by an earlier version of the app: they live on that same record, under the same rule — written once, kept for the lifetime of the account, erased with it. Turning the switch off stops every further use of them and every further report; it does not delete the record — that goes with the account, exactly as the website's does — and it does not recall what Meta already received. You can ask us to erase it sooner at privacy@meetplaynow.com. If an earlier version of the app recorded your phone's advertising identifier (section 2), you can also reset that identifier in the phone's settings, after which what we hold no longer matches your phone.
  • Waiting list for a city: a request you never confirm is deleted after 14 days. A confirmed request is deleted 30 days after the email telling you that the city has opened, and in any case no later than 730 days after you confirmed it. The link in each of our emails deletes it at once.
  • Waiting list for the shop: kept until you ask us to remove it, at privacy@meetplaynow.com. It is not deleted automatically.
  • Contact-form messages: kept in our support inbox for as long as we need them to deal with what you wrote about. The security-log entry, with your IP address and user agent, is kept for 12 months like the rest of that log; the count of messages per connection used to limit abuse expires after one hour.
  • Resend contact (promotional emails): kept while your consent stands; afterwards kept as unsubscribed, without any further mailing, until your account is deleted, when it is deleted too.
  • App sessions (installation identifier, device label, platform, last activity): one record per sign-in of the app, kept while that session can still be used. A session ends when you sign out, when you end it from the device list, or after 60 days without the app being opened. Thirty days after a session has ended its record is erased — long enough to answer "my phone signed itself out last week, what happened", short enough that spent records do not accumulate. One exception, and it is in your favour: while a device still has a live session we keep its oldest record, whatever its age, because that is the date the device list shows you as "first seen", and pruning it would silently rewrite that date to thirty days ago. The security events themselves (a sign-in, a device revoked, a token replayed) live in the audit logs above, under the same 12 months.
  • Push notification token: kept while the installation is registered. It stops being used the moment that installation has no live session — a phone you signed out of, or lost and revoked, receives nothing further even though the token is still on file. It is erased when you turn notifications off in the app, when Google or Apple tells us the token is dead, and when your account is deleted.
  • Installation identifier on the phone itself: it survives signing out, on purpose — that is what keeps the same phone as one entry in your device list rather than a new one every time you sign in — and it is destroyed when you uninstall the app.

5. Your Rights (GDPR Art. 15-22)

You have the right to:

  • Access the personal data we hold about you (Art. 15).
  • Rectification of inaccurate or incomplete data (Art. 16).
  • Erasure ("right to be forgotten") subject to legal retention obligations (Art. 17).
  • Restriction of processing in specific cases (Art. 18).
  • Data portability in a structured, machine-readable format (Art. 20). When you download your data, IP addresses in the audit history are masked to /24 (IPv4) or /64 (IPv6) for data minimization — only the network prefix is retained, not the full host address. The download also includes your campaign attribution record (section 2), if you have one, with every field it holds — including the IP address recorded with it, in full, because it is the one we use.
  • Objection to processing based on legitimate interest (Art. 21).
  • Not to be subject to automated decisions with legal or similarly significant effect (Art. 22). We do not perform such automated decisions on the platform.

6. How to Exercise Your Rights

You can exercise any of the rights above by:

  • Sending an email to privacy@meetplaynow.com, or
  • Using the privacy controls available in /dashboard/privacy when logged in.

We will reply within 30 days. If we cannot honor a request (e.g. erasure conflicts with fiscal retention), we will explain the reason in writing.

You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or with your local supervisory authority.

7. Local Law, and the Country Integrations

Everything in this document applies to you wherever you play. But data protection law is not the same everywhere, and a policy that pretends otherwise ends up saying a number that is right in one country and wrong in the next. So we do not rewrite this text per market: what a local law changes is published as a country integration — a short document, one per market that needs one, printed directly under this one on /privacy, saying only what is different. Read the integration for the country your account belongs to together with everything above. Where the two differ, the integration governs, and only for the players it names.

Age. You may hold an account once you have reached the age of majority of the country your account belongs to. That is 18 by default and higher where local law puts it higher; the integration for that country states its number, and section 2 of the Terms states the rule itself. We operate no parental-consent route anywhere. We have no way to reach a parent, to verify that they are one, or to record what they agreed to, and a half-built version of that would be worse than not admitting the minor — so an account whose date of birth is below the threshold is refused at registration, not created and then restricted.

This is a different line from the one in section 10, and the two are kept apart on purpose. Section 10 stops a photo of a person under 18 from being published outside the platform, and that number is 18 in every country, including the ones whose age of majority is higher: it asks whether someone is a child, which is not the same question as whether they can enter into a contract.

8. Cookies

We use cookies and similar technologies. Details are in our Cookie Policy. Strictly necessary cookies are always active, and so are the few functional ones that only remember a choice you made on the site — the sport, country and city you picked, and a referral code you followed (7 days) — which the Cookie Policy lists in section 2.5; analytics and marketing cookies, and the chatbot, are loaded only with your consent.

Marketing cookies mean Meta. If you allow them, two things happen, and neither happens otherwise:

  • the website loads the Meta Pixel — a script served from `connect.facebook.net` by Meta Platforms Ireland Ltd — which sets the cookies `_fbp` and `_fbc` on your browser and tells Meta which pages of MeetPlayNow you view and when you start a checkout (with the amount, the currency and the competition). It runs with Meta's automatic event collection switched off, and our code gives it no email address, no user id and no other identifying data. It is not loaded on the pages where you type personal data — sign-up and sign-in (with email verification and sign-in callbacks), password reset, consents, onboarding and the choice of city, policy updates, your whole dashboard, account deletion, unsubscribing, the chat, the organizer area, the contact form, the city waiting list and the shop pages — so it cannot read what you type there. On the pages where it stays loaded, it is paused while you type in a field that takes personal data — the email field in the footer, a partner's email address at payment, a city request, the chat with Khun Somtum — and resumes when the field is empty again or the form is closed;
  • our own server reports two events to Meta through its Conversions API: that an account was created, and that a payment was completed — the latter with the amount, the currency, our internal order number, and the name and identifier of the competition. Each event carries your email address and your user id as SHA-256 hashes, together with the IP address, the browser user agent and the two Meta cookies recorded when you created your account. A hash is a pseudonym, not anonymity: if Meta holds an account under the same email address it can link the event to that account, and so learn that its holder signed up or paid on MeetPlayNow; if it holds none, it still receives the hash. The creation of your account reaches Meta only this way, from our server.

The purpose is to measure whether our advertising works — which campaign brought the people who actually signed up and paid — and to show our advertisements to people who have visited us (remarketing). For that we also keep the campaign you arrived from, described in section 2: it is recorded when you create your account and stays with it. Who is responsible for what. For collecting this data on our website and in our app and transmitting it to Meta, GiBSeS OÜ and Meta Platforms Ireland Ltd are joint controllers (GDPR Art. 26), under the terms Meta sets for these tools — the Meta Controller Addendum. In essence: we are responsible for informing you (this section) and for the legal basis (your consent, below); Meta is responsible for giving effect to your rights over the data once it holds it. You can exercise those rights with Meta directly, through its privacy policy, or write to us at privacy@meetplaynow.com: we act on our side and pass on to Meta what concerns Meta. What Meta then does with the data — matching it to accounts, delivering and measuring advertising, its own products — it decides alone, as an independent controller under that same privacy policy.

The marketing-cookie switch governs both the browser and our server: if you do not allow marketing cookies, the Pixel is not loaded, no event is reported, and no attribution is kept. You can withdraw the consent at any time in /dashboard/privacy; withdrawal stops all further reporting. The cookies already on your browser expire on their own after 90 days, and you can delete them sooner in your browser's settings.

The app has no cookies and no Pixel. What the Android app has instead is the same measurement done from our server — the two events above, with a description of the device in place of the cookies — behind its own switch, "Advertising measurement", which is off until you turn it on. It is the same consent as the marketing-cookie choice, recorded under the same name in your consent ledger; you turn it off in the app under Settings → Privacy, and the entry also appears in /dashboard/privacy on the website. Section 11 sets out what the app reads and sends, and when. The iPhone app has none of this: nothing done in it is reported to Meta.

9. Chatbot Service (Khun Somtum)

MeetPlayNow offers an optional AI chatbot named Khun Somtum to help you navigate the platform, answer questions about tournaments, sports, rules, and onboarding. You can use it in any language (with first-class support for English and Thai).

Activation. The chatbot is opt-in. It is loaded only after you grant the "Khun Somtum chatbot" consent in our cookie banner or in your /dashboard/privacy settings; in the app, the assistant screen asks for the same consent before the first message. If consent is withheld or revoked, the widget is not loaded and no conversation data is sent to our chatbot infrastructure.

Data we process for the chatbot.

  • The text of messages you send and receive.
  • The locale you use during the conversation.
  • A non-persistent session identifier (random UUID) for anonymous visitors, or your account user ID if you are logged in. We use it to keep the messages of one conversation together, and to find that conversation again if you ask us about it.

Where the chatbot runs. Conversations are processed by our self-hosted automation pipeline (n8n) running on EU infrastructure. To produce a reply, the pipeline sends the conversation to Anthropic, PBC, in the United States, which provides the large language model (Claude). Each message is sent to it twice: once to a check that keeps the conversation on topic and screens out abuse, and once to write the reply. What Anthropic receives is the text of your message, the recent messages of the same conversation and the instructions we give the chatbot. Message content is sent to Anthropic for the sole purpose of generating a reply. Under Anthropic's commercial terms it does not train its models on what it receives, and it keeps it only for a limited period, to provide the service and detect misuse, before deleting it. The transfer to the United States is covered as section 12 says.

Retention. We keep no separate archive of chatbot conversations. The chatbot's working memory holds only the last few messages of an exchange and is lost when the conversation ends. The one durable copy is the execution record that our automation platform (n8n) writes each time the chatbot answers: it contains the messages of that exchange, it lives on the server that runs the platform, our administrators can read it, and the platform deletes it automatically once it is more than 14 days old. Operational backups of that server may hold a copy for longer; we use them only to restore the service. Because a conversation is filed under a session identifier and not under your name, we can delete one earlier only if we can identify it: write to privacy@meetplaynow.com telling us when you spoke to the chatbot and, for an anonymous session, roughly what you asked.

Rate limits. The chatbot widget stops an anonymous conversation after 5 messages and invites you to sign in. This is a limit applied in your browser, to hold down cost and casual abuse in ordinary use. It is not a security control: it is not enforced on our server, and starting a fresh browser session resets it. We state it this way rather than describe it as a protection it is not. It counts nothing about you on our side, and it is not a profiling mechanism.

No automated decisions. The chatbot does not take any decision that has legal or similarly significant effects on you (no account suspensions, no payments, no eligibility decisions). If a chatbot suggestion conflicts with the official tournament rules or the platform terms, the official rules and terms prevail.

Withdrawal of consent. You can revoke chatbot consent at any time from the cookie banner or /dashboard/privacy. Revocation hides the widget on next page load and stops new data collection. The execution records of past conversations are deleted on the 14-day cycle described above, or earlier on request where we can identify them.

Legal basis. Your consent (GDPR Art. 6(1)(a)). Where a local law names the equivalent basis differently, its integration says which one — see section 7.

10. Match Photos

After a match you can upload photos of it. What we may do with them is set out in full in section 10 of our Terms of Service; this section describes the data protection side of the same thing.

What we process. The image file, the faces and other identifiable features it contains, the match and tournament it is attached to, the account that uploaded it, the timestamp, and the technical metadata carried by the file. Where the file carries a GPS location, we strip it before the photo is stored.

Two consents, recorded separately. Uploading is not consenting. We ask you two questions and we record the answers as two distinct entries in our consent ledger, each with the text you accepted, its version, the date, your IP address and your browser's user agent:

  • `photo_use_platform` — display of the photo on MeetPlayNow.
  • `photo_use_marketing` — publication on our social media accounts and use in advertising and promotional material, online and printed.

They are separate because withdrawing them does not have the same effect, and because you must be free to allow one without the other. Refusing either has no consequence for your account, your matches or your ranking.

Other people in the photo. When you upload, you declare to us that every identifiable person in the photo has agreed with you to the uses you are authorising. That declaration is our basis for processing their image, and it is recorded with the consent. If someone shown in a photo tells us they did not agree, we take the photo down — write to privacy@meetplaynow.com. You do not need an account with us to make that request, and we will not ask you to justify it.

People under 18. A photo of a person under 18 is never published outside the platform, whatever consent is on record. This is why date of birth is collected (section 2). An account whose date of birth we do not hold is treated as being under 18 for this purpose.

Withdrawal, and its limits. You can withdraw either consent at any time in /dashboard/privacy or at privacy@meetplaynow.com. We then stop all new use, and remove the photo from the platform and from the social channels we control, within 30 days. We cannot retrieve copies that third parties have already downloaded, re-shared, screenshotted or indexed, nor printed material already distributed. This limit is inherent to publication outside our own systems; we state it plainly so that the second consent is an informed one.

Recipients. Photos published under `photo_use_marketing` are, by definition, transmitted to the social media platforms we post them on, each of which acts as an independent controller for what happens on its own service, under its own terms, including any transfer outside the EU/EEA. Photos under `photo_use_platform` alone are not sent to them.

Legal basis. Your consent (GDPR Art. 6(1)(a)), asked and recorded once for each of the two uses.

11. The MeetPlayNow Mobile App

MeetPlayNow is also an app, for Android and for iPhone. Everything above applies to it exactly as it applies to the website — same account, same data, same rights. This section covers only what is different because the app runs on a phone.

Your installation identifier. When you first sign in from the app we mint a random identifier for that installation and the app keeps it in the phone's encrypted keystore. It travels with every sign-in. It exists so that your phone is one thing to us rather than a stranger every time: it is what makes the device list show one entry per phone, what lets you end the session on a lost phone without ending the others, and what makes a stolen session token detectable when someone tries to reuse it. It is not an advertising identifier — the app reads none —, we do not read your phone's hardware identifiers (no Android ID, no IMEI, no serial number), and it means nothing to any app but ours. It survives signing out — that is the point of it — and it is destroyed when you uninstall.

What we store next to it. A device label, the platform (`android` or `ios`), and when the session was last used. The label is a fixed string, "MeetPlayNow Android" or "MeetPlayNow iOS": the session record never carries your phone's model or the name you gave it. The one place the app reads the model is the device description for advertising measurement below, and only once you have switched that on.

Push notifications. If you allow the app to send you notifications, your phone's push service issues a registration token — an address for that one installation — and the app hands it to us so we know where to deliver. On Android the token comes from Google's Firebase Cloud Messaging, and our server sends each notification through Google. On an iPhone the token comes from Apple, and our server sends each notification directly to Apple's push service, without passing through Google. The token is not a name and not an account; it is a destination, and Google or Apple may replace it on their own schedule, so the app reports the new one and it overwrites the old on the same record.

  • What a push actually contains. The title and the text are fixed sentences we wrote in advance — "A score was entered", "You have a new message". No message text, no player names, no scores, no tournament names ever travel inside a notification. What travels beside it is a handful of identifiers so that tapping the notification opens the right screen. A lock screen is a public surface, and this is why yours stays uninformative to whoever is looking at it.
  • What we never push. Anything promotional. The four notification switches in the app govern service messages only, and there is no switch for promotional notifications because we do not send any.
  • Turning it off. Your phone asks you before the first notification and you can refuse; you can also switch categories off inside the app, or withdraw the permission in your phone's settings at any time. Refusing costs you nothing in the service — everything a push announces is in the app anyway.
  • Where it goes. Delivery is performed by Google (Firebase Cloud Messaging) for Android phones and by Apple (Apple Push Notification service) for iPhones, both in the United States — see section 12.

Camera and photos. The app asks for the camera only at the moment you tap "Take a photo", never when a screen opens, and it keeps working if you refuse. Choosing an existing photo asks for nothing at all: it goes through your phone's own photo picker, which hands the app the single image you selected — we never request access to your photo library, because asking for the whole library in order to read one file is not a trade we are willing to offer you. What happens to a match photo after that is section 10.

Your clipboard. There is exactly one clipboard read in the app, and it is on the screen where you join a tournament with an invite code. When that screen opens, the app looks at the clipboard once to see whether what you copied is shaped like an invite code; if it is, the field is filled in for you and the screen says so. If it is not, nothing is kept and nothing leaves the phone. We never read your clipboard anywhere else, never in the background, and the contents are never sent to us.

Unlocking the app with a fingerprint or your face. You can ask the app to require your fingerprint, your face or your device PIN before it opens. If you do, the only thing stored is your preference that this is on — kept on the phone, not on our servers. The check itself is performed entirely by Android or iOS against data held in your phone's secure hardware: no fingerprint, no face, no biometric template of any kind is ever sent to us, and we could not read one if we tried. This is a lock on the app for whoever is holding your phone; it is not a second password on your account, and it is not a condition of anything.

Signing in with Google. If you use "Sign in with Google", the sign-in happens on Google's own pages and Google is told that you are signing in to MeetPlayNow. What comes back to us is a signed assertion containing your email address, which we use to find or create your account. We never see your Google password. You can use an email address and a password instead, and nothing in the service depends on the choice.

Signing in with Apple. "Sign in with Apple" is offered in the iPhone app and on the website (meetplaynow.com); it is not offered in the Android app. If you use it, the sign-in happens through Apple and Apple is told that you are signing in to MeetPlayNow. What comes back to us is a signed token containing an identifier for you and an email address — and, only the first time you sign in and only if you choose to share it, your name. On the website the sign-in happens on Apple's own page, which sends the result back to our server (`api.meetplaynow.com`); we load no Apple script on our pages for it. Apple lets you hide your real address: when you do, Apple gives us a private relay address (`…@privaterelay.appleid.com`) instead. Unlike the Google assertion, which passes once at sign-in, the relay is a permanent mail channel: every service e-mail we send you — including a password reset — is routed to you through Apple's relay servers in the United States for as long as you keep the relay in place (see section 12). If Apple issues you a new relay address, we bring ours up to date the next time you sign in with Apple. We never see your Apple password. You can use an email address and a password instead, and nothing in the service depends on the choice.

Advertising measurement in the app. The Android app can take part in the advertising measurement described in section 8, and it does so only behind a switch of its own — "Advertising measurement", off until you turn it on, shown when you create your account and afterwards under Settings → Privacy. It is not a condition of anything: the app works identically with it off. On an iPhone there is no advertising measurement with Meta. The iPhone app does not offer the switch when you create your account, it reads and sends nothing for this purpose, and our server reports nothing to Meta about an account created or a payment made in it. If you had already given this consent, the switch still appears under Settings → Privacy on the iPhone, only so that you can turn it off. In the Android app, with it on, and at no other time:

  • What the Android app reads. A description of the device: platform, the app's identifier, app version and build, operating system version, model, language, time zone, and screen size and density. No advertising identifier — not Google's advertising ID, not Apple's IDFA — and therefore no Apple "allow tracking" prompt. Nothing else either — not your location, not your contacts, not the other apps on your phone, not your mobile carrier, processor or storage.
  • When it is read. Once: when you create your account from the app, or — if you signed in with Google or Apple and turned the switch on in the days that followed — the first time you do. It is recorded on your account next to the campaign record of section 2 and is never updated afterwards (section 4).
  • What leaves, and from where. Our server reports the same two events to Meta as on the website — an account created, a payment completed with the amount, the currency, our internal order number, and the name and identifier of the competition — with your email address and user id as SHA-256 hashes, the IP address and app user agent recorded with your account, and the device description, in the form Meta requires for events from an app (which reports the phone's own tracking permission as not given). There is no Meta SDK in the app, and nothing in the app talks to Meta: what Meta receives leaves from our server, after the fact, and only these two events. There is no Pixel, no page-view reporting and no cookie in the app.
  • Why. The purpose is the one in section 8 — to know which advertisement brought the people who actually signed up and paid, and to show our advertisements to people who already know us. For collecting and transmitting this data, we and Meta are joint controllers, and what Meta does with it afterwards it decides alone, as section 8 explains.
  • Turning it off. In the app under Settings → Privacy, or on the website in /dashboard/privacy, at any time. Off means no further use of what was recorded and no further report; what was recorded stays on the account until the account goes, as section 4 says, and what Meta already received is Meta's to keep under its own rules.
  • Legal basis. Your consent (GDPR Art. 6(1)(a)) — the same consent as the marketing-cookie choice, recorded under the same name.

Paying in the app. Card payments in the app are handled by Stripe's own component, exactly as on the website: your card details are entered into Stripe and never pass through our systems. See section 12.

Where you are signed in. The app shows you every installation with a live session — its label, when it first signed in and when it was last used — under Settings → Security, and lets you end any of them, including the one you are holding. Ending a session there also stops that phone receiving notifications.

What the app does not do. There is no analytics SDK, no crash-reporting SDK, no advertising SDK and no third-party tracker in the app: nothing in it reports to anyone but us. The only thing that ever reaches an advertiser is what the "Advertising measurement" switch above describes; it leaves from our server and not from your phone, and it does not happen with the switch off, nor ever from the iPhone app. It does not ask for your location, your contacts, your microphone, your calendar, your files or your call history, and it does not read them.

Legal basis. Contract performance (GDPR Art. 6(1)(b)) for the session, the installation identifier and service notifications; legitimate interest (Art. 6(1)(f)) for the device list and the detection of a reused session token; your consent (Art. 6(1)(a)) for advertising measurement. The camera, the photo you pick, the clipboard read and the biometric lock are each an action you take, and your phone asks for its own permission where one is required.

12. International Data Transfers

Personal data is hosted in the European Union. Our hosting provider is Contabo GmbH (Munich, Germany), and the servers holding the database, the uploaded files and the application itself are located in the European Union; the current data centre is in France. Estonia is where our company is registered (section 1) — it is not where the servers are, and the two are stated separately here on purpose. If you play in a country outside the EU/EEA, your data reaches the servers named here by leaving it, and what your own law calls that transfer is in your country's integration (section 7).

We do not transfer data outside the EU/EEA except to the recipients below. Where a transfer is covered by Standard Contractual Clauses, we rely on the Standard Contractual Clauses incorporated in the provider's data processing terms; some of these providers are also certified under the EU-U.S. Data Privacy Framework (DPF). (The social media platforms of section 10 receive a photo only under its marketing consent, and act as independent controllers on their own services.)

  • Stripe (Stripe Payments Europe, Ltd., Ireland, and its affiliate Stripe, Inc., United States), our payment processor. For the transfer to the United States we rely on the Standard Contractual Clauses incorporated in the provider's data processing terms; Stripe, Inc. is also certified under the DPF.
  • Google LLC (United States), for two things, both described in section 11. Firebase Cloud Messaging delivers push notifications to the Android app: what Google receives is your installation's registration token and the fixed title and text of the notification, never the content of a message, a name or a score. Google Sign-In, only if you choose it, tells Google that you are signing in to MeetPlayNow. We rely on the Standard Contractual Clauses incorporated in the provider's data processing terms; Google LLC is also certified under the DPF.
  • Apple Inc. (United States), only if you sign in with Apple — in the iPhone app or on the website — or use the app on an iPhone. If you choose "Sign in with Apple", Apple is told at sign-in that you are signing in to MeetPlayNow, and if you use Apple's private e-mail relay, the service e-mails we send you are additionally routed through Apple's relay servers in the United States for as long as the relay is in place. If you allow notifications on an iPhone, our server hands them directly to Apple's push service, which receives your installation's device token and the fixed title and text of the notification, never the content of a message, a name or a score. We rely on the Standard Contractual Clauses incorporated in the provider's data processing terms; Apple Inc. is also certified under the DPF.
  • Meta Platforms Ireland Ltd (Ireland) and, through it, Meta Platforms, Inc. (United States), only if you allow marketing cookies on the website or turn on "Advertising measurement" in the Android app: the Pixel and the Conversions API described in sections 8 and 11, for which we and Meta are joint controllers. What Meta receives is listed in section 2 — hashed email and user id, IP address, user agent, the two server-side events, and then, from the website, the Meta cookies and what the Pixel reports from your browser, or, from the Android app, the device description (and, for an account created with an earlier version of the app, the advertising identifier recorded then). For the transfer to the United States we rely on the Standard Contractual Clauses incorporated in the provider's data processing terms; Meta Platforms, Inc. is also certified under the DPF.
  • Resend, Inc. (United States), which delivers every email we send — service emails, the help message, promotional emails if you agreed to them, the waiting-list emails, and contact-form messages on their way to our support inbox — using Amazon Web Services' email infrastructure. It receives your email address and the content of each email, which may include your name, a competition or an amount paid; and, only while you consent to promotional emails, the contact copy described in "The emails we send you" (section 3). We rely on the Standard Contractual Clauses incorporated in the provider's data processing terms.
  • Anthropic, PBC (United States), the provider of the chatbot's language model, only if you have given chatbot consent: it receives what section 9 lists. We rely on the Standard Contractual Clauses incorporated in the provider's data processing terms.
  • Porkbun, LLC (United States), which receives the email sent to our @meetplaynow.com addresses — privacy@, support@ and the contact form among them — and forwards it to a mailbox hosted by our email provider, where we read it. It handles what you write to us. We have no agreement with Porkbun containing Standard Contractual Clauses: this transfer rests on GDPR Art. 49(1)(b), because forwarding your message is necessary to answer the request you sent us.

13. Security

We apply industry-standard safeguards: TLS in transit, hashed passwords, principle of least privilege, audit logging, and regular review of access rights.

14. Updates to This Policy

We may update this Privacy Policy. Material changes will be notified by email or in-app notice; the current version is always available at /privacy. The previous versions remain accessible on request via privacy@meetplaynow.com.

15. Contact

For any privacy-related question or request: privacy@meetplaynow.com.

Country integration

Additional terms for Thailand

Last updated: 2026-10-20 (version 2026-10-20-v4)

This section applies only to players in Thailand. It adds to the policy above and does not replace it; where local law requires something different, this section prevails for those players.

This part is for accounts that belong to Thailand. It adds to the Privacy Policy above and replaces none of it: what we collect, why, how long we keep it, who processes it for us and how you exercise your rights are all as stated there. Below is only what Thai law does differently, so that you do not have to read eight thousand words twice to find the paragraph that concerns you.

The law in question is the Personal Data Protection Act B.E. 2562 (2019) — the PDPA.

Version 2026-10-20-v4 — revised together with version 2026-10-20-v18 of the policy above. Section 2 now lists the chat with your opponent in a match still to be played under the contract, and the chat consent covers only the chat outside your matches; it also lists the read receipts in a direct chat between two people under legitimate interest. Section 5 now says that notifications on an iPhone are delivered by Apple, not Google. Nothing else has changed.

1. Here the age is 20, not 18 (section 7)

In Thailand a person becomes an adult at 20 (Civil and Commercial Code, section 19), and the PDPA (section 20) treats consent given below that age as something the holder of parental power must give. We have no way to reach a parent, to verify that they are one, or to record what they agreed to — so a date of birth below 20 does not open an account here. Where we hold both your date of birth and your market at sign-up, it is refused there and then. Where an account was opened without them — signing in with Google leaves the date of birth empty, and an account can exist before any country is chosen — the refusal lands the moment that account asks to join Thailand, and it is left with no access to this market. Either way, there is no route by which a parent can open an account on a minor's behalf.

Two consequences, stated plainly. The default of 18 named in section 7 is not your number. And the 18 in section 10 still is: a photo of a person under 18 is never published outside the platform, in Thailand as everywhere else. The two numbers answer different questions — one asks who can enter into a contract, the other asks who is a child — so moving the first to 20 does not make a 19-year-old a child for the purposes of a photograph.

2. What the PDPA calls the bases listed in section 3

The processing is the same one described above. The article numbers behind it are not:

  • Contract — section 3's contract performance is PDPA section 24(3): your account, your entries, your payments, your results, the chat with your opponent in a match still to be played, the publication of your competitive record, service notifications in the app, service emails (including the one telling you that a player has named you as their doubles partner), and the delivery of a prize you won.
  • Legitimate interest — PDPA section 24(5), for exactly the purposes section 3 lists: security and audit logs, fraud prevention, moderation, platform integrity, the dispute channel, the device list in the app, the read receipts in a direct chat between two people (which you can object to by blocking that player or by writing to us), answering a message sent through the contact form, and the one help message described in "The emails we send you" — which you can stop with the "Unsubscribe from these emails" link it carries.
  • Legal obligation — PDPA section 24(6), for the accounting and invoicing records. The obligation itself is Estonian, because that is where the invoices are issued; the PDPA is what makes keeping them lawful towards you.
  • Consent — PDPA section 19. Every consent named in section 3 is a PDPA consent when you are here: non-essential cookies (including advertising measurement with Meta), promotional emails, your profile photo, your biography, an optional phone number, player-to-player chat outside your matches, the chatbot, each of the two uses of a match photo, and the waiting lists for a city and for the shop. Each is recorded with the text and the version you accepted, and section 19 gives you the right to withdraw any of them at any moment, with no consequence for your account.

We hold none of the data PDPA section 26 protects — no health data, no biometric data, no religion, no criminal record. The fingerprint or the face you may use to unlock the app is checked by your phone and never reaches us; section 11 above explains why we could not read one if we tried.

3. Your rights, under their PDPA numbers (section 5)

Nothing about how you use them changes here: the same address, the same /dashboard/privacy, the same 30 days for an answer. What changes is the law you are invoking:

  • access, and a copy of what we hold — sections 30 and 31;
  • portability — to receive your data in a machine-readable form, or have it sent to another controller — section 31;
  • objection to processing that rests on legitimate interest — section 32;
  • erasure, subject to the records we are required by law to keep — section 33;
  • restriction of processing — section 34;
  • rectification of data that is inaccurate, incomplete or out of date — section 35;
  • withdrawal of consent, at any time — section 19.

The PDPA has no counterpart to GDPR Article 22 on automated decisions. What section 5 says stands regardless: we take no automated decision about you with legal or similarly significant effect.

4. The authority you can complain to (section 6)

Section 6 names the Estonian supervisory authority. You may also complain to the Thai one: the Office of the Personal Data Protection Committee (PDPC) — สำนักงานคณะกรรมการคุ้มครองข้อมูลส่วนบุคคล — at pdpc.or.th. PDPA sections 73 to 76 govern that complaint. It costs you nothing, and you do not have to come to us first.

5. Your data does leave Thailand (section 12)

Section 12 says where the servers are: the European Union — France today, with Contabo GmbH. For an account here that is a cross-border transfer under PDPA sections 28 and 29, and it happens to every account, on every request. It is not a setting you can turn off and keep playing, because the platform itself runs there.

What makes it lawful. The transfer to the European Union is necessary to perform the contract you enter into when you create an account — the platform that holds your account, your entries and your results runs there — which is the ground in PDPA section 28(3). Once it arrives, your data is protected by the GDPR, the standard the policy above is written to from end to end; we say so as a fact about the destination, not as the legal ground for the transfer.

From the European Union, some data goes on to the recipients listed in section 12. Each of those transfers rests on a ground of PDPA section 28, or on the safeguards of section 29, depending on why the data is going:

  • Necessary for the contract — PDPA section 28(3): Stripe (United States), for the payments you make; Google (United States), to deliver the Android app's notifications and, if you choose it, to sign you in with Google; Apple (United States), if you sign in with Apple (in the iPhone app or on the website) or use the app on an iPhone — signing in with Apple, its email relay and the delivery of the iPhone app's notifications; Resend (United States), to deliver the service emails; Porkbun (United States), to receive the emails you send to our addresses about your account.
  • Steps you asked us to take, before any contract — PDPA section 28(3): Resend (United States), to deliver the emails of a waiting list you joined and to bring a contact-form message to our inbox; Porkbun (United States), to receive a message you send to our addresses without an account, so that we can answer it.
  • Appropriate safeguards — PDPA section 29: Resend (United States), to deliver the one help message to an account that has not entered a competition. Sending it rests on our legitimate interest (section 2); it is not needed to run your account, so its transfer does not rest on the contract but on the safeguards Resend is bound by: the Standard Contractual Clauses in its data processing terms. The "Unsubscribe from these emails" link it carries stops it.
  • Your consent — PDPA section 28(2): Meta (Ireland and the United States), only with marketing cookies or "Advertising measurement" in the Android app (the iPhone app takes no part in it); Anthropic (United States), only with chatbot consent; Resend (United States), for promotional emails and the contact copy that goes with them, only with that consent. The PDPC has not recognised the United States as having adequate personal data protection standards, and its rules are not the PDPA's. We tell you this here so that each of these consents is given knowing it; you can withdraw any of them at any time (section 2), which stops the transfer from then on.

Except for Porkbun (section 12), each recipient is also bound to protect the data by the provider's data processing terms (Standard Contractual Clauses); some are also certified under the EU-U.S. Data Privacy Framework.

6. Who you write to

GiBSeS OÜ in Estonia is the data controller for Thailand as for every other market, and the address and email in section 1 are the ones to use. We have no branch, office or subsidiary in Thailand at present. If that changes, this integration changes with it.