LAST UPDATED: 3rd June 2025
Playto respects your privacy and is committed to protecting it. In addition to our Terms of Service, this Privacy Policy (the "Policy") explains the types of information collected by Playto when you use the Platform (as defined in Terms of Service that references this Policy), how we collect, use, share and store such information collected and also explains the rationale for collection of such information, the privacy rights and choices you have regarding your information submitted to us when you use the Services.
For ease of reference, use of the terms "Playto", "we", "us", and/or "our" refer to Sanhik Roy Industries Private Limited (trade name: Playto) - a company incorporated in India, and its affiliates. Similarly, use of the terms "you", "yours" and/or "User(s)" refer to all shall refer to all visitors of the Platform and the Creator(s) (as defined under our Terms of Service).
The Services are governed by this Policy, Terms of Service , and any other rules, policies or guidelines published on the Platform as applicable to you. Please read this Policy carefully prior to accessing our Platform and using the Services. By accessing and using the Platform, providing your Personal Data (defined below), or by otherwise signalling your agreement when the option is presented to you, you consent to the collection, use, disclosure, sharing and storing of information described in this Policy, Terms of Service and any other rules, policies or guidelines published on the Platform as applicable to you (collectively referred to as the "Platform Terms"), and Playto disclaims all the liabilities arising therefrom. If you have inadvertently submitted any Personal Data to Playto prior to reading this Policy, or you do not agree with the way your Personal Data is collected, stored, or used, then you may access, modify and/or delete your Personal Data in accordance with this Policy (refer to the sections about Your Choices and Your Rights).
If any information you have provided or uploaded on the Platform violates the Platform Terms, Playto may be required to delete such information upon informing you of the same where possible and revoke your access to the Platform if required.
Capitalized terms used but not defined in this Policy can be found in our Terms of Service.
If you have any questions about this Policy, please contact us at support@playto.so.
This Policy applies to all users of the Platform, including without limitation, (i) visitors of the Platform, (ii) the Creators (as defined in the Terms of Service), (iii) the Authorized Users (as defined in the Terms of Service), and (iv) Creator's Members (as defined in the Terms of Service).
Acceptance of the Platform Terms and any other specific terms by the Creator in association with their use of the Platform, shall be deemed as acceptance of such terms by all of Creator's Page Users (as defined in the Terms of Service). Creators are solely responsible for publishing any terms and conditions, privacy policies and any other terms and conditions or policies that shall be applicable for their Page Users in accordance with the Platform Terms and applicable laws, including Data Protection Laws (as defined in the 'Personal Data' section below).
You may be allowed to access and view the Platform as a guest/visitor and without creating an account on the Platform or providing any Personal Data; Playto does not validate or takes no responsibility towards information, if any, provided by you as a guest/visitor, except as otherwise required under any law, regulation, or an order of competent authority. To have access to all the features and benefits on our Platform, you are required to first create an account on our Platform. To create an account, you are required to provide certain Personal Data as may be mandatorily required during the time of registration. All other information requested on the registration page, including the ability to receive promotional offers from Playto, is optional. Playto may, in future, include other optional requests for information from you to help Playto customize the Platform to deliver personalized information to you. Playto may keep records of telephone calls or emails received from or made by you for making enquiries, feedback, or other purposes for the purpose of rendering Services effectively and efficiently.
Playto is the 'Controller' (as defined in the Data Processing Addendum ('DPA') you will agree to) of the information, including Personal Data that it directly collects from you (the Creator) and processes in connection with your use of the Platform and the provision of the Services on the Platform ("User Data"). The kind of information we collect in connection with such use is detailed below. It is hereby clarified that User Data specifically excludes Creator Data (defined below).
When it comes to the Content on Creator's Page (as defined in the Terms of Service), any information, materials, media, applications, data, services, subject-matter, including Personal Data, or solutions created and/or uploaded by a Creator on their Page, Page Users' Data (as defined in 'Personal Data' section below) ("Creator Data"), the respective Creators are the 'Controllers' (as defined in the DPA) of such Creator Data. In this case, Playto only acts as a 'Processor' (as defined in the DPA) and processes the Creator Data on behalf of the Creator.
We clarify that the Page User(s) Data processed and stored by the Creator outside the purview of the Platform shall be the sole responsibility of the Creator.
You as a Creator acknowledge and agree that you are responsible for complying with all applicable laws and regulations related to the protection of information, including Personal Data for which you are the Controller or the Processor, as applicable. You are also responsible for providing an appropriate privacy notice and cookies policy to your Page Users that detail, among other things, the processing activities and security measures undertaken by you in respect of your Page Users' Data (as defined below) within and beyond the scope of this Platform in accordance with applicable laws. You will need to prepare and make available your own Data Processing Addendum if you act as a controller for your Members' data.
As stated in our Terms of Service, to register on the Platform you must meet the 'Age Requirements' (as defined in our Terms of Service). If you are a "Minor" or "Child" i.e., an individual who does not meet the Age Requirements, then you may not register on the Platform without appropriate parental or guardian consent as outlined in the Terms of Service.
We do not knowingly collect any Personal Data directly from a Child for account creation without verifiable parental consent. If you are a Parent and you are aware that your Child has provided us with any Personal Data without your consent for purposes of their own account, please contact us at support@playto.so. If we become aware that we have collected Personal Data from a Child for their own account in a manner not compliant with applicable laws, we will take steps to remove such information from our servers or obtain verifiable consent.
Furthermore, as stated above, our Platform is not primarily directed at Minors/Children for unsupervised use. However, Creators may offer content suitable for Minors/Children. In your use of the Services, if you offer services/content targeted at Minors/Children, then it shall be your sole responsibility to comply with all applicable laws relating to the privacy rights of children, including the Children's Online Privacy Protection Rule (COPPA) in the US, and similar laws globally. Playto shall not be liable for your non-compliance of the applicable laws, including the Data Protection Laws, concerning your Members.
For the purpose of the Platform Terms -
We request you to not provide Playto with any Personal Data unless specifically requested by us for the provision of our Services to you. In the event you share with Playto any Personal Data without us having specifically requested for the same, then we bear no liability in respect of such Personal Data provided by you.
Further, we do not intend for our platform tools to be used by Creators to collect, process, or store Sensitive Personal Data from their Members, beyond what is inherent in community interaction or basic profile information. Accordingly, you (Creator) shall not use the Services to systematically collect, process, or store Sensitive Personal Data from your Members, such as personal health information, detailed banking and credit card information (beyond what our payment processors handle for transactions), unless you have explicit consent and robust safeguards in place compliant with all applicable laws. If you do use the Platform and/or the Services to collect, store or otherwise process any Sensitive Personal Data from your Members, then you do so at your own risk and you are responsible for ensuring compliance with all applicable laws.
We only collect information about you if we have a reason to do so — for example, to provide our Services on the Platform, to facilitate payouts, to comply with legal obligations, to communicate with you, or to make our Services better.
It is hereby clarified that we do not directly collect extensive Personal Data from your Authorized Users and Members, beyond what is necessary for them to use the Platform features enabled by you (e.g., login credentials if they register, interaction data). We primarily process Members' Personal Data as collected and directed by you (the Creator) through your Page, in accordance with your instructions and our DPA (when in place). Further, we do not generally contact or solicit your Authorized Users and/or Members directly for marketing purposes; any essential platform-related correspondence with Members will typically be facilitated through you or clear platform notifications.
We collect this information from the following sources:
We collect and process your Personal Data based on the following legal parameters depending upon the nature of Personal Data and the purposes for which it is processed:
We may process your Personal Data in connection with any of the purposes and uses set out in this Policy on one or more of the following legal grounds:
We do not use your Personal Data for making automated decisions that produce legal effects concerning you or similarly significantly affect you, other than what is described in this Policy (e.g., for fraud prevention or content moderation based on pre-defined rules).
Where the processing of your Personal Data is based on your consent, you have the right to withdraw your consent at any point in time in accordance with this Policy. Please note that should the withdrawal of consent result in us not being able to continue offering our Services to you (e.g., if you withdraw consent for processing necessary payment information), we reserve the right to withdraw or cease from offering our Services to you upon your consent withdrawal. You may withdraw consent by contacting us with a written request to the contact details provided in the 'Grievances' section below. Upon receipt of your request to withdraw your consent, the consequences of withdrawal may be communicated to you. Upon your agreement to the same, your request for withdrawal will be processed.
We use/process your information in the following manner:
We share the information collected as per terms of this Policy only in the manner specified hereinbelow. We do not sell your Personal Data (as "sell" is traditionally defined, i.e., for monetary or other valuable consideration) for third parties' independent use. Further, only authorized representatives of Playto and on a need-to-know basis use any information received from you and as consented by you. In the event of any identified unauthorized use or disclosure of information or upon your complaint as stated under the 'Grievances' section below, we will investigate any such complaint and take the appropriate action as per the applicable Data Protection Laws.
You are responsible for protecting your Page Users Data that you collect, and for processing that information in accordance with applicable privacy laws including the Data Protection Laws.
When a Creator creates an account and makes available Content on the Platform, the Content on Creator's Page (including their public profile) will be viewable by their Members and potentially other users of the Platform (e.g., if a community is public or discoverable).
Please note that all information shared by you, whether as part of your public profile or Content, in Public Forums, or other public portions of the Creator's Page, is deemed as public information. Since the same is publicly available, we cannot control how others treat it; so please keep that in mind when deciding what information, you choose to include, and refrain from sharing your Sensitive Personal Data and those of others in public forums.
To the extent permitted by law, we will attempt to give you prior notice before disclosing your information in response to such a request.
Your information may be shared for reasons not described in this Policy, however, we will seek your consent before we do the same or share information upon your direction, unless otherwise permitted or required by law.
Your information including any Personal Data is stored, processed, and transferred in and to the servers and databases primarily located in India (e.g., Mumbai, Bangalore, or other locations as our infrastructure evolves). Playto may also store, process, and transfer information in and to servers in other countries depending on the location of its affiliates (if any) and service providers.
Please note that these countries may have differing (and potentially less stringent) privacy laws and that Personal Data can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies, and private persons, as a result of applicable governmental or regulatory inquiry, court order or other similar process.
If you use our Platform from outside India, including in the USA, EU, EEA, and UK, your information will be transferred to, stored, and processed in India and potentially other countries where our service providers operate. By accessing our Platform or otherwise giving us information, you consent to the transfer of information to India and other countries outside your country of residence.
For transfers of Personal Data from the EEA, UK, or Switzerland to countries not considered adequate by the European Commission, we rely on appropriate safeguards, such as Standard Contractual Clauses (SCCs) approved by the European Commission, and/or your consent where applicable.
Generally, when you delete any of the information provided by you or when you delete your account on the Platform, we aim to delete it from our active servers. When you delete your account (regardless of the reason), all Content on Creator's Page, including Page Users Data processed by us on your behalf, may no longer be available through the live platform and may be irrecoverable after a certain period. Playto is not responsible for the loss of such Content on Creator's Page upon deletion. Hence, prior to initiating deletion of your account, please ensure to take necessary back-ups of all Content on Creator's Page, including Members' Data for which you are the controller.
In certain cases, we will retain User Data (Creator's direct data) for as long as it is required for us to retain for the purposes stated hereinabove, including for the purpose of complying with legal obligations (e.g., financial records, KYC data) or business compliances, resolving disputes, and enforcing our agreements. It is clarified that Content on Creator's Page and Page Users Data (for which the Creator is the controller) is generally aimed for deletion from our active systems upon account termination, subject to technical limitations and backup cycles.
Further, please note that we may not be able to delete all communications or photos, files, or other documents publicly made available by you on the Platform in public forums (for example: comments, feedback, etc.), however, where feasible and appropriate, we may anonymize your Personal Data in such a way that you can no longer be identified as an individual in association with such information made available by you on the Platform. We will never disclose aggregated or de-identified information in a manner that could identify you as an individual without appropriate safeguards.
Note: If you wish to exercise any of your rights (as specified in 'Your Rights' section below) to access, modify and delete any or all information stored about you, then you may do so by using the options provided within the Platform. You can always write to us at support@playto.so for any clarifications needed.
In general, all Users have the rights specified herein this section regarding their Personal Data processed by Playto as a controller. However, depending on where you are situated, you may have certain specific rights in respect of your Personal Data accorded by the laws of the country you are situated in. To understand your rights, please refer to the Country Specific Additional Terms below.
If you are a Creator, you may exercise many of these rights by using the options provided to you within the Platform upon your login. If, however, you are facing any issues or require any clarifications, you can always write to us at the address noted in the 'Grievances' section below, and we will address your concerns to the extent required by the applicable law.
We collect and process Personal Data about you only where we have a legal basis to do so under GDPR. Specific legal bases applied will depend on the type of Personal Data collected and the context in which the same is being processed, including the Services involved.
We value your privacy and your rights as a data subject. If Playto is considered to be targeting data subjects in the EU/EEA or UK to an extent that requires a representative, we will appoint one. For now, please direct your inquiries to support@playto.so or our Grievance Officer at the address provided. [*(Self-correction: The user said "do whatever Graphy is doing." Graphy does name a representative. If Playto wants to mirror this, they would need to engage a service like Prighter. I will include the Prighter placeholder for now, and Playto can decide if they will actually use them or remove this specific part.*) We have appointed Prighter as our privacy representative in the EU, EEA and UK and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g., requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit the following website: https://prighter.com/q/ (You will need to register with Prighter and get your specific link if you choose this service)].
If you are a California state resident, then you have the following rights to the extent, and in the manner, set out in the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):
The above rights, the manner in which you can exercise the same and the category of and the manner in which we collect your information, are detailed below.
For purposes of the CCPA, in collecting the information described in Section F ("Information we collect") of this Policy, we collect the categories of Personal Data listed below from you: