Privacy Policy for Plush Art 3D

1. Introduction

Welcome to Plush Art 3D, a mobile application and web service operated by Gamiable. Plush Art 3D enables players of all ages to design, customize, and publish 3D plushie creations, interact with user-generated content (UGC), and share creations across platforms.

We are committed to protecting the privacy of all our users, with special safeguards for children under applicable privacy regulations, including:

• COPPA (Children's Online Privacy Protection Act - United States)
• GDPR / GDPR-K (General Data Protection Regulation - European Union & UK)
• Google Play Families Policy & Apple App Store Safety Guidelines

By downloading, accessing, or using Plush Art 3D (including our mobile app and WebGL web viewer at plush.gamiable.com), you agree to the practices described in this Privacy Policy.

2. Information We Collect

We collect information in three ways: information you provide directly, information collected automatically, and information received from authentication providers.

A. Information You Provide Voluntarily

• Account Registration Information: When you log in using third-party sign-in providers (Facebook Login, Google Play Games Services, or Apple Game Center), we collect your basic public profile details, such as display name, user ID, and avatar image (where permitted by the platform).
• User-Generated Content (UGC): Plushie designs, custom colors, assembling metadata, plushie titles, custom tags, comments, and reports submitted through the app.
• Customer Support & Inquiries: Email address and communications when you contact our support team or file a DMCA/copyright report.

B. Information Collected Automatically

• Device & Technical Data: Device model, operating system version, screen resolution, preferred language, and unique device identifiers (for non-child accounts).
• Usage & Telemetry Data: In-game interactions, feature usage, session duration, crash logs, and performance metrics.
• Network Data: IP address (used for approximate geolocation for regional age-gating and security, purged or anonymized in accordance with child safety laws).

C. Information Collected for Under-Age / Child Accounts

For users identified as children under the age of digital consent in their jurisdiction (e.g., under 13 in the US/Global, under 16 in certain EU countries):

• Zero PII Collection: We do not collect full real names, email addresses, exact geolocation, advertising IDs (IDFA/GAID), or social profile pictures.
• Neutral Age Gate Data: Birth month and year provided during the age gate are processed locally on the device to establish feature restrictions and are never shared or used for profiling.
• Anonymized UGC Data: Plushies created by child accounts are assigned generic, randomized handles (e.g., Artist #402) and stripped of all metadata or device tracking IDs.

3. How We Use Your Information

We process personal data strictly for legitimate operational, security, and community safety purposes:

1. To Provide and Maintain the Service: Processing plushie creations, rendering 3D models on mobile and WebGL platforms, and maintaining user accounts.
2. To Enforce Age-Appropriate Experience: Tailoring app features, disabling social commenting/liking for child accounts, and enforcing safe feed curation.
3. To Ensure Moderation & Safety: Scanning UGC titles, comments, and rendered 3D thumbnails using automated AI filtering tools to prevent profanity, offensive content, and Child Sexual Abuse Material (CSAM).
4. To Support WebGL URL Sharing: Serving view-only WebGL 3D previews without exposing user PII to public web crawlers or unauthenticated visitors.
5. To Process DMCA & Copyright Notices: Investigating copyright infringement reports and communicating with reporting parties or content creators.

4. Third-Party Login Integrations & Public Visibility

A. Facebook, Google Play Games, & Game Center

• In-Game Display: For age-qualified adult accounts, your display name and social profile picture (via Facebook or Google Play Games) may be displayed next to your published plushies within the mobile app feed.
• Game Center Users: Native Game Center handles are displayed; raw personal avatars are not extracted or stored.
• WebGL Web Viewer Safety: Real names, social network profile pictures, and social media IDs are never displayed or rendered on the public WebGL viewer (plush.gamiable.com). WebGL links display only anonymized or in-game generic pseudonyms.

B. Third-Party Service Providers

We may share non-PII or necessary technical data with trusted service providers subject to strict confidentiality agreements:

• Cloud Hosting & CDN Providers (for asset delivery and WebGL hosting)
• Automated Content Moderation APIs (for text and image scanning)
• Analytics Providers (strictly non-targeted, contextual analytics for child accounts)

5. Children's Privacy Safeguards (COPPA & GDPR-K Compliance)

Plush Art 3D is designed for players of all ages. We enforce strict compliance mechanisms for child users:

1. Neutral Age Gate: Age screening is presented without default selections or incentives to alter age.
2. No Behavioral Advertising: We do not display targeted or behavioral ads to children.
3. Disabled Social Features for Children: Child accounts cannot post public comments, give public likes, or share external web URLs.
4. Data Minimization: We do not track children across third-party apps or websites.
5. Parental Rights: Parents or legal guardians may review, request deletion of, or refuse further collection of their child's personal data by contacting us at privacy@gamiable.com.

6. Data Retention & Security

• Security Measures: We use industry-standard encryption (TLS/HTTPS), secure database access controls, and automated payload sanitation to protect user data against unauthorized access, loss, or alteration.
• Retention Period: We retain user account data and UGC for as long as the account remains active or as needed to provide the service. Unpublished local drafts remain on the user's local device storage.
• Takedown Data: Data associated with DMCA notices or moderation violations is retained strictly as necessary to enforce repeat infringer policies and legal compliance.

7. Your Data Rights & Choices

Depending on your jurisdiction (including EU/UK GDPR and California CCPA/CPRA), you possess the following rights:

• Access & Export: Request a copy of the personal data we hold about you.
• Correction: Correct inaccurate account details.
• Deletion: Request permanent deletion of your account, profile data, and published plushies ("Right to be Forgotten").
• Account Disconnection: Revoke Facebook, Google, or Apple app permissions directly from your respective account security settings at any time.

To exercise any of these rights, email us at privacy@gamiable.com or use the in-game account settings menu.

8. International Data Transfers

Your information may be stored and processed on secure servers located outside your home country. We ensure adequate safeguards (such as Standard Contractual Clauses) are in place to protect your data in transit and at rest.

9. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect technological, legal, or operational updates. We will notify users of significant changes by updating the "Last Updated" date at the top of this page and providing an in-game notification where appropriate.

10. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or child safety, please contact our Data Protection Officer:

• Organization: GAMIABLE VIET NAM COMPANY LIMITED
• Privacy Contact Email: privacy@gamiable.com
• Copyright & DMCA Inquiries: copyright@gamiable.com
• Website: https://plush.gamiable.com