AI AVATAR Pte. Ltd. (“Company,” “we,” “our,” or “us”) operates the mobile application R10 Ronaldinho Playground and related websites, software, and online services (collectively, the “Services”). This Privacy Policy explains in detail how and why we collect, process, use, disclose, transfer, and safeguard your personal information when you use the Services. It also describes your legal rights under applicable data protection and privacy laws in your country or region of residence.
By accessing or using the Services, you acknowledge that you have read, understood, and agreed to this Privacy Policy. If you do not agree, please uninstall the application and discontinue use.
1. Scope and Applicability
This Privacy Policy applies to all users worldwide who download, install, register for, or otherwise use the Services.
It governs information collected through the R10 Ronaldinho Playground mobile app, official websites, customer support channels, promotional campaigns, and social media integrations operated by us.
This Privacy Policy does not apply to information collected offline, information related to employees, contractors, or job applicants, or information processed by third-party platforms beyond our control.
2. Definition of Personal Information
For the purposes of this Policy, “Personal Information” refers to information as defined under the Act on the Protection of Personal Information of Japan (APPI), including but not limited to data that can identify a specific individual such as names, dates of birth, and other identifiers, as well as personally identifiable codes and any data that is associated with a particular individual, including email addresses and physical appearance.
3. Information We Collect
a. Information You Provide Directly: When you create an account or interact with the Services, you may provide us with personal information such as your full name, username, password, email address, country of residence, date of birth, and contact details. If you make in-app purchases, transaction records (item purchased, date, amount, and transaction identifier) are collected from app marketplaces.
When you record videos or create other media within the Services, we collect and process these recordings for your use inside the app and to enable optional export or sharing to external platforms of your choice. These recordings remain private within your account unless you choose to share them outside the Services.
Communications sent to customer support, survey responses, and feedback are also included.
b. Information Collected Automatically: We automatically collect device identifiers (e.g., IDFA, Google Advertising ID, Vendor ID), IP addresses, operating system type and version, app version, device type, performance logs, crash data, and gameplay metrics such as progress, scores, achievements, tutorial completions, and frequency of play. Location information may be inferred from your IP address; precise geolocation is only collected if you enable it in your device settings.
c. Information from Third Parties: If you connect your account with third-party authentication services (e.g., Facebook, Google, Apple), we may receive profile data including your name, avatar, and friends list where permitted. From app marketplaces (e.g., Apple App Store, Google Play), we receive information necessary to verify purchases. We may also obtain aggregated insights from advertising and analytics partners where legally permitted.
4. Purposes of Processing
We process your personal information for the following purposes:
1. To provide, operate, and maintain the Services, including enabling gameplay, tutorials, competitions, and progress tracking.
2. To personalize your experience, including adjusting difficulty levels, recommending content, and delivering tailored in-game events or promotions.
3. To process payments, verify entitlements, and manage purchases made through authorized marketplaces.
4. To communicate important notices such as security alerts, technical updates, or changes to policies and terms.
5. To conduct analytics, surveys, and market research to improve our Services and user experience.
6. To prevent, detect, and investigate fraud, cheating, unauthorized use, violations of Terms of Use, and other illegal or harmful activities.
7. To enforce contractual obligations and protect the rights, safety, and property of the Company, other users, and third parties.
8. For marketing and promotional activities, including targeted advertising, where consent is obtained or permitted by law.
9. To comply with applicable legal and regulatory obligations, respond to lawful requests, and cooperate with law enforcement authorities.
5. User Recordings
- You may create recordings (such as freestyle football videos) within the Services for your own training and performance tracking. These recordings remain private to your account unless you choose to export or share them outside the Services.
- We do not host or make your recordings publicly viewable within the Services for other users.
- When you export or share recordings to external platforms (e.g., social media), those platforms’ privacy policies will apply. The Company is not responsible for how third parties handle your data once it is shared externally.
- You must not create or share illegal, infringing, or offensive content using the Services.
6. Advertising and Monetization
At present, monetization of the Services is primarily through in-app purchases. Payment details are processed by app marketplaces and not stored directly by the Company.
In the future, the Services may display advertising, including interest-based or personalized ads. Where required by law, your prior consent will be obtained before activating targeted advertising features.
We may share advertising identifiers (IDFA, Google Ad ID), IP addresses, gameplay engagement data, and inferred interests with authorized ad-tech partners for purposes of delivering relevant ads, measuring effectiveness, and conducting attribution analysis.
Users can manage ad preferences by limiting ad tracking, resetting advertising identifiers, or withdrawing consent through device settings or in-app privacy settings, depending on jurisdiction.
7. Sharing and Disclosure
Personal information may be shared with the following categories of recipients:
- Affiliates: including AI AVATAR Pte. Ltd. and other group entities for operational purposes.
- Service Providers: hosting, analytics, payment verification, marketing, and customer support providers bound by contractual obligations.
- Business Partners: with your explicit consent, for joint promotions or campaigns.
- Legal Authorities: when required by applicable law, court order, or regulatory authorities.
- Corporate Transactions: in the event of merger, acquisition, reorganization, or sale of assets.
- Other Users: when you participate in competitions, leaderboards, or publicly share UGC.
7.a Disclosure to Third Parties
We may provide personal information to AI AVATAR Pte. Ltd. for the following purposes, via written or electronic means:
- To provide, plan, develop, and improve the Services
- To conduct marketing activities such as statistical analysis, surveys, and service improvement
- To respond to inquiries and consultations
- To send important notices and communications related to the Services
- To investigate and prevent illegal or unauthorized activities
- To perform administrative tasks necessary for the operation of the Services
8. Minors
The Services are not intended for children under: 13 years (U.S., Japan), 16 years (EU unless a lower age is recognized locally), and 18 years (Brazil under LGPD).
We do not knowingly collect information from minors without verified parental or guardian consent. If we become aware of unauthorized collection, we will delete such data promptly.
Parents and guardians are encouraged to monitor their children’s use of the Services and activate device-level parental controls where available.
9. International Data Transfers
The Company is headquartered in Japan and data may be stored and processed in Japan, Singapore, or other jurisdictions where we and our service providers operate.
Where personal data is transferred internationally, we implement appropriate safeguards consistent with applicable data protection laws, including Standard Contractual Clauses (SCCs) under GDPR, adequacy mechanisms, or equivalent legal safeguards under LGPD.
By using the Services, you consent to such international transfers, subject to mandatory legal protections in your jurisdiction.
10. Your Rights
Depending on your country of residence, you may have rights under GDPR, LGPD, or APPI, including:
- Right of Access: obtain confirmation and a copy of your personal data.
- Right to Rectification: request correction of inaccurate or incomplete data.
- Right to Erasure: request deletion of personal data in certain circumstances.
- Right to Restriction: request limitation of processing under specific conditions.
- Right to Object: object to processing, including for direct marketing purposes.
- Right to Data Portability: receive your personal data in a structured, machine-readable format and transmit it to another controller.
- Right to Withdraw Consent: withdraw consent at any time without affecting the lawfulness of prior processing.
- Right to Review Automated Decisions: request human review of significant automated processing outcomes.
Requests should be submitted through the contact details in Section 15. We may require verification of identity. We will respond within the time limits established by law (15 days under LGPD, 1 month under GDPR, extendable by 2 months where justified). Requests may also be submitted by an authorized representative in accordance with applicable law. Please note that we may decline requests to the extent permitted or required by law, and we will provide reasons for such denial when legally required.
11. Security
We employ technical and organizational measures designed to protect personal data against unauthorized access, destruction, loss, alteration, or disclosure. These measures include encryption, access controls, firewalls, and secure hosting arrangements.
While we strive to maintain industry-standard safeguards, no system or transmission over the internet is completely secure. Users are responsible for safeguarding their account credentials and devices.
12. Retention
We retain personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, or as required by law.
Retention periods depend on criteria including account activity, legal obligations (e.g., tax, audit), and technical needs (e.g., crash logs, dispute resolution).
When personal information is no longer necessary, we will securely delete or irreversibly anonymize it.
13. Third-Party Services
The Services may contain links to or integrations with third-party websites, platforms, or applications (e.g., social media, app stores).
We are not responsible for the privacy practices or content of third parties. Users are encouraged to review the privacy policies of third-party services before interacting or sharing data.
14. Amendments
We may update this Privacy Policy periodically. Material changes will be communicated through reasonable means such as in-app notifications, emails (if available), or prominent posting on our website.
The revised version becomes effective as of the date indicated at the top of this Policy. Continued use of the Services constitutes acceptance of the updated Policy.
14A. Legal Bases for Processing (LGPD / GDPR)
For users in jurisdictions such as the European Union under GDPR and Brazil under LGPD, we rely on the following legal bases to process personal data:
- Consent: for example, when you allow us to use your videos or content for analysis.
- Contractual Necessity: to provide the Services you signed up for, including gameplay and purchases.
- Legal Obligation: to comply with laws, regulatory requests, or enforceable governmental orders.
- Legitimate Interests: to improve our Services, ensure safety and integrity, and protect our rights.
Where applicable, you have the right to object to processing based on legitimate interests.
15. Governing Law
This Privacy Policy shall be governed by and construed in accordance with the laws of Japan.
However, mandatory consumer and data protection laws of your country of residence (such as GDPR in the EU and LGPD in Brazil) will also apply and prevail where required.
16. Contact Information
If you have questions, concerns, or requests related to this Privacy Policy or the processing of your personal information, please contact us: support@r10playground.com.
Effective Date: September 17, 2025