1. Introduction
1.1 Welcome to J REYNOLDS SYSTEMS Services, operated by J REYNOLDS SYSTEMS SOFTWARE LLC and its affiliates and related companies (each operating separately and collectively referred to as "J REYNOLDS SYSTEMS," "we," "us," or "our"). J REYNOLDS SYSTEMS takes its responsibilities seriously under applicable privacy laws and regulations ("Privacy Laws") and is committed to respecting the privacy rights and concerns of all users of J REYNOLDS SYSTEMS games (the "Games"), websites, and mobile applications (the "Websites") (we refer to the Games, Websites, and other services mentioned in the Terms of Service as the "Services"). "User" means any person who registers an account or otherwise uses or accesses the Services (individually and collectively, "User," "you," or "your"). We recognize the importance of the personal data you entrust to us and believe we have a responsibility to properly manage, protect, and process your personal data. This Policy ("Privacy
Policy") is intended to help you understand how we collect, use, disclose, transfer, or process the personal data you provide to us, or that we learn about you, whether now or in the future, and to help you make an informed decision before providing any personal information. Capitalized terms used in this Privacy Policy but not otherwise defined herein have the meanings given to them in the J REYNOLDS SYSTEMS Terms of Service.
1.2 "Personal Data" or "Personal Information" means information about an individual, whether true or not, from which that individual can be identified, or from data and other information that an organization has or is likely to have access to. Common examples of Personal Data may include names, identification numbers, and contact information.
1.3 By using the Services, registering an account with us, or accessing our Websites, you acknowledge and agree to accept the practices, requirements, or policies set forth in this Privacy Policy, and you hereby consent to our collection, use, disclosure, or processing of your Personal Data as described herein. If you do not agree to the processing of your Personal Data in accordance with this Privacy Policy, please do not use our Services or access our Games or Websites. If we change our Privacy Policy, we will notify you by posting these changes or the revised Privacy Policy on the Website. We reserve the right to modify this Privacy Policy at any time. To the maximum extent permitted by applicable law, your continued use of the Services or Websites, including making a purchase or placing an order, constitutes your acknowledgment and acceptance of changes to this Privacy Policy.
1.4 This Policy applies alongside other notices, contract terms, and consent terms to our collection, storage, use, and disclosure or processing of your Personal Data, and unless we expressly state otherwise, this Policy is not intended to override such notices or terms.
2. When Does J REYNOLDS SYSTEMS Collect Personal Data?
2.1 We will/may collect Personal Data about you:
When you register for or use our Services, Games, or Websites;
When you submit any form, including but not limited to application forms or other forms related to our products and services, whether online or in physical form;
When you enter into any agreement with us or provide other documents or information related to your interaction with us, or use our products and services;
When you interact with us, such as by telephone (which may be recorded), letter, fax, face-to-face meetings, social media platforms, and email, including when you interact with our customer service personnel;
When you use our electronic services, or interact with us through our Games or Websites, or use our Services. This includes, but is not limited to, cookies that we may deploy when you interact with our Games or Websites;
When you authorize information sharing with our mobile applications or Websites on your device;
When you provide us with feedback or complaints;
When registering for tournaments, games, or specific competition events;
During competitions;
When you submit Personal Data to us for any reason.
The above is not exhaustive but lists some common situations in which your personal information may be collected.
3. What Personal Data Does J REYNOLDS SYSTEMS Collect?
3.1 Personal Data that J REYNOLDS SYSTEMS may collect includes information you provide, information collected automatically, and information from other sources. This information may include, but is not limited to:
Name, username, and user ID;
Chat data (including voice, text messages, or other communications) and other information about the people and accounts you interact with;
Gender, age, or date of birth;
Information sent by or related to the device you use to access our Services;
Marketing and communication data, such as your preferences for receiving marketing materials, communication preferences, and communication history with us and our service providers.
You agree not to submit any inaccurate or misleading information to us and agree to promptly notify us of any inaccuracies or changes to the information. We reserve the right, at our sole discretion, to request additional documents to verify the information you provide, as permitted by applicable law.
3.3 If you do not wish us to collect the above information/Personal Data, you may opt out at any time by notifying our Data Protection Officer in writing. For more information on opting out, please refer to the section below titled "How Can You Withdraw Consent, Delete, Request Access to, or Amend the Information You Provide to Us?" Please note, however, that opting out or withdrawing your consent to our collection, use, or processing of your Personal Data may affect your use of the Services.
4. Collection of Other Data
4.1 Like most websites and mobile applications, information sent by your device may include data recorded by web servers about you when you use our Services. This typically includes, but is not limited to, your device's Internet Protocol (IP) address, computer/mobile device operating system and browser type, mobile device type, mobile device characteristics, mobile device unique device identifier (UDID), or mobile equipment identifier (MEID).
4.3 When you browse pages or content in our Websites or mobile applications, the information sent to us is largely the same (including but not limited to IP address, operating system information, etc.); however, what your device sends is content information, that is, advertisements viewed, rather than page views or what software was installed and when.
5. How Do We Use the Information You Provide?
6.1 We may collect, use, disclose, or process your Personal Data for one or more of the following purposes:
(a) To consider or process your application/transaction with us, or your transaction or communication with third parties through the Services;
(b) To administer, operate, provide, or manage your use of or access to our Services, Websites, and Games (including but not limited to preferences), and your relationship with us and user accounts;
(c) To respond to, process, handle, or complete transaction requests for certain products and services, and to notify you of service issues and abnormal account activity;
(d) To enforce our Terms of Service or any applicable end-user license agreement;
(e) To protect the personal safety and rights, property, or security of others;
(f) For identification or verification purposes;
(g) To maintain, manage, and improve any software updates or other updates, and support services, including troubleshooting, reporting, or resolving any issues that may need to be addressed (for example, responding to error or crash reports), to ensure the smooth operation of the Games or Services;
(h) To process or assist with customer service, execute your instructions, and process or respond to any inquiries made by you or on your behalf (or purported to be made by you);
(i) To contact or communicate with you by voice call, text message, fax, email, postal mail, or other means to manage or administer your relationship with us or your use of our Services, such as but not limited to communicating administrative information related to our Services. You acknowledge and agree that we may communicate with you through postal letters, documents, or notices, which may involve disclosing certain personal information about you to complete delivery, as well as on the outer envelope/mailing package;
(j) To allow other users to interact, communicate, or contact you, including notifying you when other users send you private messages or post comments through the Games or Websites;
(k) To conduct research, analysis, and development activities (including but not limited to data analysis, surveys, product and service development or analysis, analyzing how you use our Services, improving our Services or products, or enhancing your customer experience);
(l) To allow advertising and other audits and surveys (through offline and online surveys, including on third-party platforms such as Google Forms) to verify the size and composition of target audiences and understand their experiences with J REYNOLDS SYSTEMS services;
(m) Marketing and advertising for any marketing campaigns, and recommending products or services relevant to your interests, providing you with product- or service-related communications, marketing, and promotional information and materials through various media and methods (including email or text message) (including but not limited to: J REYNOLDS SYSTEMS (or its subsidiaries or affiliates) may sell, market, or promote third-party products or services, whether such products or services currently exist or are developed in the future, and J REYNOLDS SYSTEMS may cooperate or collaborate with them. You may unsubscribe from marketing communications at any time through the unsubscribe function in electronic marketing materials. We may use your contact information to send newsletters or marketing materials from us and our affiliates;
(n) To respond to legal processes, or to comply with or pursuant to applicable laws, government, or regulatory requirements of any relevant jurisdiction, including but not limited to disclosures required under any law binding on J REYNOLDS SYSTEMS or its affiliates or related companies;
(o) To produce statistics and research for internal and statutory reporting or record-keeping requirements;
(p) To conduct due diligence or other screening activities (including but not limited to background checks) in accordance with legal or regulatory obligations or requirements that may be implemented in legal or risk management procedures;
(q) To audit our Services or the business of J REYNOLDS SYSTEMS;
(r) To prevent or investigate any actual or suspected violation of the Terms of Service, such as fraud, illegal activity, omissions, or misconduct, whether in connection with your relationship with us or arising from any other matter in our relationship;
(s) To store, host, or back up (whether for disaster recovery or other purposes) your Personal Data, whether within or outside your jurisdiction;
(t) To process or facilitate business asset transactions or potential business asset transactions involving J REYNOLDS SYSTEMS as a participant, or involving only affiliates or subsidiaries of J REYNOLDS SYSTEMS, or involving J REYNOLDS SYSTEMS or its affiliates as a participant, and possibly other third-party organizations participating in such transactions. "Business asset transaction" means a transaction involving an organization, or part of an organization, its business activities, or assets; or
(u) To verify your eligibility or submit an application/request when registering for a specific Game's competition, event, or contest, and, where applicable, to provide rewards; and
(v) Other purposes permitted by applicable law and notified to you when we obtain your consent.
(Collectively, the "Purposes")
6.2 You acknowledge, agree, and consent that J REYNOLDS SYSTEMS may access, preserve, and disclose your account information and content when necessary to comply with the law or in accordance with an order from a court or any government or regulatory agency with jurisdiction over J REYNOLDS SYSTEMS, or when it believes in good faith that such access, preservation, or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with requests from any government or regulatory agency with jurisdiction over J REYNOLDS SYSTEMS; (c) enforce J REYNOLDS SYSTEMS' Terms of Service or this Privacy Policy; (d) respond to any threatened or actual litigation against J REYNOLDS SYSTEMS, or other claims that any content infringes the rights of third parties; (e) respond to customer service requests; or (f) protect the rights, property, or personal safety of J REYNOLDS SYSTEMS, its users, or the public.
6.3 Because the purposes for which we collect, use, disclose, or process your Personal Data will depend on the circumstances, some purposes may not be shown above. However, unless processing is permitted by Privacy Laws, we will obtain your consent and inform you of other purposes before acquiring the relevant data without your consent.
6. How Does J REYNOLDS SYSTEMS Protect and Retain Customer Information?
7.1 We implement multiple security measures and operational controls to strive to ensure the security of your Personal Data within our systems. User Personal Data is stored in secure networks accessible only to a small number of employees with special access privileges. However, absolute security cannot be guaranteed.
7.2 We will retain Personal Data in accordance with Privacy Laws or other applicable laws. That is, when we reasonably determine that (i) retaining such Personal Data no longer serves the purpose for which it was collected; (ii) retention is no longer necessary for any legal or business purpose; and (iii) there is no other legitimate interest supporting further retention of such Personal Data. If you stop using our Services, or your license to use the Websites, Games, or Services is terminated or revoked, we may continue to store, use, or disclose your Personal Data in accordance with this Privacy Policy and our obligations under Privacy Laws. We may process your Personal Data securely and without prior notice to you as required by and in accordance with applicable laws.
7. Children's Information
The Services are not intended for children under the age of 13. We do not knowingly collect or maintain any Personal Data, nor non-personally identifiable information, from anyone under the age of 13, and no part of our Websites, Games, or other Services is directed to them. As a parent or legal guardian, please do not allow such children to submit Personal Data to J REYNOLDS SYSTEMS; please refer to J REYNOLDS SYSTEMS' Terms of Service for more information. If Personal Data of a child under 13 in your care is disclosed to J REYNOLDS SYSTEMS, you hereby consent to the processing of the child's Personal Data and agree to comply with the terms of this Privacy Policy on behalf of the child. If you do not truly consent to the processing of Personal Data of a child under 13 in your care, please contact our Data Protection Officer. We will close all accounts specifically directed to such children and delete or remove any personal information submitted without
parental consent, as required by applicable law.
8. Will J REYNOLDS SYSTEMS Transfer Your Information Overseas?
12.1 Your Personal Data or information may be transferred to, stored, or processed in countries outside your country. J REYNOLDS SYSTEMS will only transfer your information overseas in accordance with Privacy Laws and this Policy. By accepting this Policy, you consent to the cross-border transfer of your information to any country where we operate, including our partners, developers, servers, or databases. In most cases, your Personal Data will be processed in Singapore, where our central databases and servers operate. Because data protection requirements may differ across jurisdictions, we will take steps to implement appropriate safeguards to protect your data.
12.2 If you are a user in India, your Personal Data will be processed and stored on our servers located in India or Singapore. J REYNOLDS SYSTEMS will only transfer your information overseas in accordance with Privacy Laws, and you hereby consent to such transfer and processing.
12.3 For more information about the transfer of Personal Data or information related to EU users outside the EU, please see the section titled "Additional Terms for EU Users Only."
9. How Can You Withdraw Consent, Request Access to, or Correct the Information You Provide to Us?
13.1 Withdrawing Consent
13.1.1 You may withdraw your consent to our collection, use, or disclosure of, or request deletion of, the Personal Data we hold by contacting our Data Protection Officer by email at [email protected]. We will act in accordance with this Privacy Policy and our obligations under applicable privacy and other applicable laws.
13.1.2 However, your withdrawal of consent or request for deletion of Personal Data we own or control may mean that we can no longer continue to provide Services to you, and we may need to terminate your existing relationship or contract.
13.2 Requesting Access to or Correction of Personal Data
13.2.1 If you have an account with us, you may personally access or correct the Personal Data we currently hold or control through the Website or tabs. If you do not have an account with us, you may request access to or correction of the Personal Data currently held or controlled by us by submitting a written request to us. We require sufficient information from you to determine your identity and the nature of your request so that we can process it. Please submit your written request by emailing our Data Protection Officer. In addition, where required by law, we will take steps to notify any third party that has received or used your Personal Data to make corrections.
13.2.2 Where permitted by applicable law, we reserve the right to refuse certain requests, or may charge you a reasonable fee to process your request for access to your Personal Data. In such cases, we will notify you and provide you with a written estimate of the relevant fees. Subject to applicable law, upon your payment of the relevant fees, the requested Personal Data will be provided to you within a reasonable time.
13.2.3 Please submit your written request by emailing our Data Protection Officer. In accordance with applicable law, we reserve the right to respond only to data subject requests submitted in accordance with this Policy.
10. Other User Rights
14.1 Additional Terms for EU Users Only
14.1.1 The terms in this section apply only to users located within the European Union. These terms take precedence over inconsistent terms elsewhere in this Privacy Policy.
14.1.2 Portability
You have the right to obtain from us the Personal Data you previously provided to us and that we process with your consent, in a structured, commonly used, and machine-readable format, and to request the transfer of such Personal Data to another party. If you want us to transfer Personal Data to another party, please be sure to specify that party, and note that we can only provide it where technically feasible. We are not responsible for the security of the Personal Data or how the third party handles it after receiving the data. We may also not provide you with certain safeguards if providing the Personal Data would interfere with the rights of others (for example, providing the Personal Data we hold about you would expose information about others).
14.1.3 Deletion
You have the right to request that we delete the Personal Data we hold about you in the following circumstances:
(a) You believe we no longer need to retain the Personal Data about you;
(b) We are processing the Personal Data we hold about you based on your consent, and you wish to withdraw your consent and there is no other reason for us to process the Personal Data;
(c) We are processing the Personal Data we hold about you based on legitimate interests, and you object to this. Please provide us with details of your reasons so that we can assess whether there are overriding interests in processing and retaining such Personal Data;
(d) You no longer wish us to use the Personal Data we hold about you to send you promotions, special offers, marketing, and lucky draws; or
(e) You believe the Personal Data we hold about you is being processed unlawfully.
Please specify the reasons for your request in as much detail as possible so that we can determine whether you have a valid basis for deletion. However, if there are legitimate grounds under applicable law (for example, we have a legal obligation or right to retain certain information for the exercise or defense of legal claims, freedom of expression, etc.), we may retain the Personal Data, but we will notify you if this is the case. Please note that after deletion of Personal Data, we may not be able to provide you with the same level of service, as we will not know your preferences, and in some cases, you may no longer be able to use our Services.
14.1.4 Retention of Personal Data
We may retain your Personal Data for as long as necessary to provide services or products, or as required or permitted by applicable law (such as tax and accounting laws), or for the exercise or defense of legal claims. If you make a request for deletion of your Personal Data and we determine that your request is justified, we will make every effort to delete the Personal Data within 30 days of your request, or notify you if a longer period is required.
14.1.5 Objection to Profiling and Targeted Marketing
You have the right to object at any time to our processing of Personal Data about you for the purpose of sending you promotions, special offers, and marketing information, including profiles we have built for this purpose, and we will stop processing Personal Data for this purpose. Please specify the reasons for your request in as much detail as possible so that we can determine whether you have a reasonable objection. However, we may retain Personal Data if there are legitimate legal grounds.
14.1.6 Processing Restricted to Storage Only
You have the right to request that we restrict the processing of Personal Data we hold about you to storage purposes only in the following circumstances:
(a) You believe your Personal Data is inaccurate while we verify its accuracy;
(b) We wish to delete the Personal Data, but you only want us to store it;
(c) We wish to delete the Personal Data because it is no longer necessary for our purposes, but you need it stored to establish, exercise, or defend legal claims; or
(d) You object to our processing of the Personal Data we hold about you based on legitimate interests and wish us to stop processing while we determine whether there are overriding interests in processing and retaining the Personal Data.
14.1.7 Transfer of Personal Data Outside the EU
Your Personal Data may be transferred outside the EU. We take appropriate measures to ensure that recipients of your Personal Data are subject to confidentiality obligations and implement measures such as appropriate contractual clauses to ensure that recipients receiving such transfers can protect and process your Personal Data in accordance with all applicable personal data protection laws.
14.1.8 Children's Information
The Services are not intended for children under the age of 16 located within the EU. We do not knowingly collect or maintain any Personal Data, or non-personally identifiable information, from anyone under 16 in the EU, and no part of our Websites, Games, or other Services is directed to children under 16 located in the EU. We will close all accounts specifically directed to such children and delete or remove Personal Data we believe has been submitted by any child under 16 residing in the EU.
14.2 Additional Notice for Users Whose Data Is Subject to California Law
14.2.1 Under the California Consumer Privacy Act ("CCPA"), we do not "sell" personal information, and have not sold any personal information of users as defined by the CCPA in the past 12 months prior to the effective date of this Policy. California's "Shine the Light" law also provides California residents with the right to opt out of the sharing of certain categories of personal information (as defined by the "Shine the Light" Act) with third parties for their direct marketing purposes in certain circumstances. We do not share your personal information directly with third parties for their own marketing purposes.
14.2.2 The user personal information that J REYNOLDS SYSTEMS collects, uses, or discloses, and has collected, used, or disclosed in the months prior to the effective date of this Policy, may include personal information as defined by the CCPA, depending on how you access and interact with the Website and with us.
14.2.3 Under the CCPA or other applicable laws, you may have the right to: (i) request confirmation that we are processing your personal information; (ii) access or copy your personal information; (iii) receive an electronic copy of your personal information, or request that we send it to another entity; (iv) restrict our use of your personal information, including the right to opt in or opt out of the sale of personal information to third parties, in accordance with applicable law; (v) seek correction or rectification of inaccurate, untrue, incomplete, or improperly processed personal information; and (vi) request deletion of personal information held by J REYNOLDS SYSTEMS about you, subject to certain exceptions provided by law.
14.2.4 If you wish to exercise any of the above rights, please contact us by emailing our Personal Data Protection Officer. We will process such requests in accordance with applicable law. To protect your privacy, we may need to take steps to verify your identity to fulfill your request. If you are a California resident, you have the right not to be discriminated against by us for exercising your rights under the CCPA.
11. Questions, Concerns, or Complaints? Contact Us
15.1 If you have any questions, concerns, or complaints about our Privacy Policy, please feel free to contact our Data Protection Officer at [email protected].
Last Modified Date: September 19, 2026