Welcome to Gamepins! We are a provider of casual browser games, including Big City Adventure, Quinn's Aquarium, Solitaire Gardens, Mahjong Cruise, and Mahjong Getaway. The gamepins.com site (site) and the Gamepins games (games) available on the site are published and maintained by us, Jolly Bear Games Limited, NZ company no. 8179884.

This Privacy Policy sets out how we, Jolly Bear Games Limited, will handle personal information we collect about you, including through the site and through the games.

What is 'personal information'?

In this policy, personal information has the meaning given in the New Zealand Privacy Act 2020 (information about the identifiable individual).

Changes we may make to this privacy policy

We may update this privacy policy from time to time. If we do this, we will post the updated privacy policy on the site along with a change notice. We may also send you an email or in-game notice.

We encourage you to review this privacy policy regularly for any changes. Your continued use of the site and games, and your continued provision of personal information to us after the update policy is posted, will be subject to the terms of the then-current policy.

What we collect and how we collect it

Information collected via direct interactions: We collect personal information about you when you directly interact with us.

This includes when you input information into the site, such as through our general support and community forum, and when you make inquiries in other ways, such as through email or by phone.

Information we collect through direct interactions includes contact data, such as your email address, profile data, such as your screen name, and any user generated content you supply us with. Please refer to our Gamepins terms for a list of rules that apply to user generated content.

Information collected via third parties: We may collect this information about you through third parties that you have authorised. Where you use a third party to login to our site, we will be given access to your login details, including screen name and email address.

We use PayPal and Stripe for processing any payments you make, for example when you purchase in-game virtual currencies. When making purchases on the site or in-game, you will be asked to provide your information directly to PayPal or Stripe, who will then process the payment directly.

We do not receive your credit card details or billing information, other than the type of card used and the last four digits of the card. We retain this information for support purposes.

Information collected via automated technologies: We also collect personal information from you using our automated technologies. The personal information we collect here includes technical data such as internet protocol (IP) addresses and other technology on the devices you use to access the site or games. It also includes tracking data such as information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers, as well as usage data, including information about how you use our site and games.

Cookies, tracking and Third Party Analytics Tools: When you use our site, your device or browser may be sent cookies from third parties. Please see our Cookie Policy for more information on how we use cookies and third party analytics tools.

We may aggregate your data: We may also aggregate your data, for use as broader statistical or demographic information. For example, we may aggregate your information to calculate the percentage of users accessing a specific site or game. Please note that aggregated data may still be linked to a login ID.

What happens if you do not provide personal information? If you do not provide us with the personal information we request, you may not be able to enjoy some or all of our services.

Why we collect it, and what we use it for

We will collect and use your personal information for various purposes:

• To enable you to use our games
• To process your transactions for our games, including managing payments, fees and charges, and collecting and recovering money owed to us
• To manage our relationship with you, and exercise and enforce our rights
• To notify you of changes to our products, services, policies, contracts, and other terms
• To assist you to use our site and games, including technical support and similar issues
• To protect our business, our users, or others
• To improve and refine our site, games, marketing, customer relationships and experiences
• To feed into other services that integrate with our site and games
• For internal research and development
• To verify your identity and assist you in case you there are verification or similar issues
• To detect, investigate, and mitigate unlawful acts or other bad behaviour
• General administrative and business purposes.

In addition to the purposes listed in the table, we may collect and use your personal information to comply with New Zealand laws and any applicable overseas laws, to carry out any activity in connection with a legal, governmental, or regulatory requirement, and in other ways permitted by law (including the New Zealand Privacy Act 2020).

Children's Privacy

We encourage parents and guardians to take an active role in their children's online activities and interests. Please see our terms for further information on age appropriate use of our site and games.

Disclosure of Personal information

We may provide your personal information to:

• our related companies and subsidiaries
• vendors and service agencies that we may engage to assist us in providing our services to you. For example, we use a third party to host our site. Such third party entities are obligated to use your personal information solely to provide the services to us
• to persons involved in dispute resolution, where this is necessary to assist in resolving a dispute with us.

We will disclose your personal information if we reasonably believe it is appropriate for legal compliance and law enforcement, to assist with Court proceedings, to enforce any contracts we have with you (including our terms of use), and to protect ourselves, our users, or others.

We can also release personal information to others if you authorise us to do so, and may release information in other ways permitted by New Zealand law (including the Privacy Act).

We may transfer your personal information to a successor entity upon a merger, consolidation or other corporate reorganization in which we participate or to a purchaser of all or substantially all of our assets to which this site relates.

Links to, and use of, third party sites

The site may provide links to external websites, and you may find and use the games on or through an external website. Certain information, content and advertisements displayed on or within the games on an external website may be provided by third parties.

Such links, or the distribution of the games on these external websites, do not constitute an endorsement by us. We provide these links to you only as a convenience.

We are not responsible for the content, security or practices of such external websites. Your use of external websites (and the games on such websites) is subject to the terms of use and privacy policies located on that particular website.

How we store your personal information

We will store your personal information we collect from you in accordance with relevant law, including the Privacy Act 2020, and will take reasonable steps to ensure the security of personal information we hold.

We use firewalls, password protection, virus checking software, encryption, and other security measures to help prevent unauthorized access to your personal information. Each external website will have its own security and we are not responsible for its security or data collection or use practices.

Your personal information is stored on an encrypted database hosted by AWS (Amazon Web Services), which is currently located on the East coast of the United States. Analytics data that we collect is stored through Google Analytics. Analytics data is currently anonymised and does not link to an individual user. While personal information is currently stored in US databases, our staff may access your personal information from other jurisdictions, including New Zealand and Canada, for the reasons outlined in this policy.

Retention of Personal Information

We will only keep your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Where you provide us information about others

If you provide us with personal information about someone else, you must ensure that you are authorised to provide that information to us, so that we may lawfully collect, use and disclose that information for the purposes described in this privacy policy. In particular, you must take reasonable steps to ensure the individual is aware of, and has read and understood, this policy.

Special notice to European users

The information you enter on the site or games may be transferred outside of the European Union to the United States, which does not offer an equivalent level of protection to that, required in the respective country.

The United States of America uses a "sectoral" model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation.

The European Union's General Data Protection Regulation ("GDPR") allows for transfer of personal data from the European Union to a third country in certain situations. By agreeing to the privacy policy, and to our terms, you agree to the transfer of all such information to the United States, and to the processing of that information by us (or our agents) on servers located in the United States.

We may adopt other means, such as entering into a Data Processing Agreement and Model Contract Clauses, or enter into different certification programs under applicable law for ensuring adequate safeguards.

Your rights

You have rights under the New Zealand Privacy Act to find out what personal information we hold about you, to get a copy of that information, and to ask to us to consider amending or deleting that information. If you would like to take any of these actions, please contact us at privacy@gamepins.com.

In addition, if the GDPR applies to you, you have the following rights:

• The right to be informed: that's an obligation on us to inform you how we use your personal information (and that's what we're doing in this Privacy Policy);
• The right of access: that's a right to make what's known as a 'data subject access request' for a copy of the personal information we hold about you;
• The right to rectification - that's a right to make us correct personal information about you that may be incomplete or inaccurate;
• The right to erasure - that's also known as the 'right to be forgotten' where in certain circumstances you can ask us to delete the personal information we have about you (unless there's an overriding legal reason we need to keep it);
• The right to restrict processing - that's a right for you in certain circumstances to ask us to suspend processing personal information;
• The right to data portability - that's a right for you to ask us for a copy of your personal information in a common format (for example, a .csv file);
• The right to object - that's a right for you to object to us processing your personal information (for example, if you object to us processing your email for support); and
• Rights in relation to automated decision making and profiling - that's a right you have for us to be transparent about any profiling we do, or any automated decision making.

If we are not the "controller" of the personal information, you must contact the relevant controller to request your rights.

Responding to requests

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We will respond to all legitimate requests within the relevant statutory timeframe or, where there is no statutory timeframe, within approximately one month.

You have the right to make a complaint at any time to the supervisory authority for data protection issues in your country of residence. In New Zealand, this authority is the Office of the Privacy Commissioner. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

Questions

If you have any questions regarding this privacy policy, please contact us via email at privacy@gamepins.com. You may also write to us at our service address, 28 Constellation Drive, Rosedale, Auckland, 0632, New Zealand.

Version control

This privacy policy was last updated on 1 May, 2025.