Last Update: May 8, 2026
1. This Privacy Policy (“Policy”) explains how Phynd’s services (also “we”, “our” or “us”) collect, use, store, protect, and share your personal information. Swanston Labs, Inc. is the data controller of the personal information collected through the services (as defined in our Terms of Service (“Terms”)).
2. How we handle your information depends on which services you use, and how you use them. This Policy is grouped into these sections:
Sections
3. We encourage you to read this Policy carefully. If you have questions, please contact us.
4. This Policy is designed to explain how we process your personal information and how you can exercise control over our processing. Capitalized terms that are used but not defined in this Policy are defined in our Terms. The Terms describe how the Services work in general, and establish a contract between you and us governing your use of the Services.
1. If you have any questions or feedback about this Policy, contact us at privacy@phynd.co. To exercise your privacy rights online, use our request form (forthcoming).
1. We will update this Policy when necessary to reflect changes in our services, how we use Personal Data, or the applicable law. Anytime we modify the Policy, we revise the Last Update atop this Policy.
2. If we make material changes to this Policy, we will provide notice or obtain consent regarding such changes as may be required by law.
Phynd doesn’t control Game environments and this Policy doesn’t cover data they may collect.
1. This Policy applies to you when you use the Services, effective as of the Last Update. However, some collection and use of information falls outside this Policy:
2. We and our third-party service providers collect and process information when you interact with the Services. This includes:
3. The following tables describe, comprehensively, how the services collect and use your information, and the purpose behind that processing.
| What we collect | Why we process it | Legal basis |
|---|---|---|
| Account management data – credentials, permissions, and account actions (such as when you create an account, login or change your account). | To create and maintain an account at your direction. | Account management data is processed as part of the performance of a contract. |
| Games & subscription data – games you save or play and others you connect to | To create and maintain an account at your direction. | Product & order data is processed as part of the performance of a contract. |
| Communication data – interactions with or through Phynd, via our SMS or email service providers | To send you relevant marketing emails. To improve our Services. | Consent. Opt-out of marketing messages anytime. Our legitimate interests in providing a valid and relevant service to our users and in continuing to improve our products and services. |
| User feedback and satisfaction data – including ratings and plain text feedback on how we can improve our Services. | To inform our product roadmap and services with user feedback. | Our legitimate interest in operating, managing, and improving our Services. |
| What we collect | Why we process it | Legal basis |
|---|---|---|
| Device information – IP address, device identifiers, user agent. | For fraud prevention. To administer your account and tailor the Services based on your geography. | Our legitimate interests in keeping our services safe and secure and to provide a valid and relevant service to our users. |
| Geolocation data – Depending on your device and app settings, we collect geolocation data when you use the Services | For fraud prevention. To administer your account and tailor the Services based on your geography. | Consent. We only use precise location data, and only when you have not indicated that you do not wish to share it. |
| Activity data – the web page you came from, the URL you go to next, your interactions with content or advertising on the Services, and the time and duration of the activity. | For fraud prevention. To improve our Services. | Our legitimate interests in understanding how users interact with and use our Services; and keeping our Services safe and secure. Activity data is monitored to prevent harmful activity and unauthorized use as part of the performance of a contract. |
| What we collect | Why we process it | Legal basis |
|---|---|---|
| Social Login data – if you use a Social Login (like a Samsung, Google or Apple account) to log into your Phynd account we may receive name, profile picture, public profile information, and email address | To make signing into and using the Services easier and more secure. To authenticate you as a user of both Phynd and the third party, and to populate your account or profile as you instruct | Consent – If you no longer wish to share data with Phynd from your Social Login account, you can adjust what your Social Login communicates to the Services or, in most circumstances, migrate to direct, Phynd-based authentication. |
| Analytics and advertising data – we receive unique identifiers and demographic, location and interest-based info | To present advertising relevant to your interests. To develop and enrich datasets about visitors, users and others. In many cases, Phynd cannot, or does not, associate this data with information you’ve provided | Our legitimate interest in operating affordable services and matching you to Games and experiences tailored to your preferences, history and/or demography |
| App Store Data – we receive information about subscription and your payments, such as partial payment-card details, and the shipment and delivery of orders, from payment processors and logistics partners | To associate purchases with your account or profile. To validate purchases and interactions attributable to activity on the Services | As part of the performance of a contract and our legitimate interest in operating, managing, and improving our Services. |
Any personal information that Phynd obtains from other third-party sources will be processed by Phynd in accordance with this Policy and all applicable laws. For example, our use and transfer of information via Google APIs will adhere to the Google API Services User Data Policy, including its Limited Use requirements.
When you use and interact with the Services, software automatically collects Usage Data. To give you more insight, this section summarizes the main types of technologies the Services use to generate and collect Usage Data:
Cookies and Local Storage
1. Cookies and local storage may be set and accessed on your device. Upon your first visit to the Services, a cookie or local storage will be sent to your device that uniquely identifies your browser. “Cookies” and local storage are small files containing a string of characters that map predetermined fields to custom values based on your visit or interactions with the web service that writes the cookie. Most web services use cookies to provide useful features for their users, like remembering you when you return.
2. Pixel Tags. The Services also use “pixel tags,” which are small graphic files that allow us and third parties to monitor the use of the Services and collect Usage Data. A pixel tag can collect information such as the IP address of the device that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time (and length of time) the page containing the pixel tag was viewed; the type of browser that retrieved the pixel tag; and the identification number of any cookie previously placed by that server on your device.
3. App Technologies. Our apps collect information about your installation, use, and updating of our apps as well as information about your device, including technical identifiers. More specifically, these tracking technologies allow us to collect data about your device, your use of our apps, and the content you interact with. App-based technologies cannot be controlled by browser settings.
1. Phynd has implemented technical, administrative and physical security measures designed to protect your information from unauthorized access, use or disclosure. Still, no data transmission online is 100% secure, so we cannot guarantee or warrant the security of any information you provide, and you do so at your own risk. We cannot promise that your information will remain absolutely secure in all circumstances. We are not responsible for the circumvention of any privacy settings or security measures we may provide.
2. This section describes how and why we exchange personal information with contractors and third parties. It also describes our disclosures for marketing and advertising efforts and for legal reasons. We also often disclose deidentified and/or anonymized data for these purposes.
1. We also contract with other businesses to provide certain services related to the functionality and features of the Services, including payment processing, email and hosting services, software development, shipping and fulfillment, data management, and administration of contests and other promotions. We refer to them as “contractors.”
2. Contractors may collect information about you on our behalf, such as Personal Identifiers, Commercial Information, Internet Activity and Device Information, as necessary for them to perform their services. At other times, we disclose information about you to contractors.
3. Contractors are not permitted to use information about you for any purpose other than performing their services for us. In the past twelve (12) months, we have disclosed these types of information to the following types of contractors:
We use and disclose your information for marketing purposes in the following ways:
Matched Identifier Communications.
Some third party services allow us to reach users with online marketing about our content or services by sending deidentified representations of contact information (typically, a long alphanumeric sequence of characters deidentified from an email address or phone number) to keep the original information from being revealed. The third party compares our deidentified representations with the deidentified representations in its own database and there will be a match only if you have used the same contact information with us and the third party. If there is a match, Phynd can then choose whether or not to send Phynd marketing to you on or through that third party service, and can optimize and better measure the effectiveness of such marketing.
Direct marketing
1. We only disclose contact information for direct marketing purposes if you opt in to such sharing or do not opt out when prompted.
Targeted ads
1. Technology from advertising partners collects data about you to make the advertising you experience on the Services more relevant to you. We also market the Services to you through ads facilitated by marketing vendors.
2. For example, we use Google to serve ads on the Services and we may market the Services to you on third party services through Google. Google uses cookies or unique device identifiers, in combination with their own data, to show you ads based on your visits to many web services, including our Services. You can opt out of the use of the Google cookie by visiting the related Google privacy policy.
3. Most third-party advertising technology providers require us to enter contracts that allow them to optimize their ad services and products. Essentially, they combine any information they may gather about you through our Services with information they receive from their other clients. This helps them target ads to you on behalf of their other clients, not just us.
4. In the past twelve months, we have shared these categories of personal information with third parties to personalize advertising:
1. We may periodically ask for your consent to share your contact information to third parties. Whenever we ask your consent for this reason, we will summarize the purpose and scope of the disclosure. For example, we may offer discounts to you if you consent to join our mailing list or participate in a promotion involving direct marketing communications.
1. Finally, we may disclose personal information:
2. We retain your information only as long as we need it for the purposes described under Information we collect & how we use it, except when longer retention is required by our compliance policies and efforts toward applicable legal, tax, accounting and regulatory requirements.
3. Retention determinations always consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from its unauthorized use or disclosure and whether we can achieve those purposes without using the personal information.
4. People under age 16 may only use our Services with the consent of a parent or guardian. We do not knowingly share or sell information about anyone under 16.
1. As a user of the Services, you have rights and choices about your personal information. We want you to be in control of your information, so we want to remind you of the following options and tools available to you:
Exercising rights: If any of the local privacy laws listed below apply to you, see Requesting information to exercise your rights.
1. The Personal Data we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers process data. Currently, we primarily use data centers in the United States. The storage location(s) are chosen to operate efficiently and improve performance. We take steps designed to ensure that Personal Data is processed and protected as described in this policy wherever the data is located.
2. Location of Processing European Personal Data. We transfer Personal Data from the European Economic Area (EEA), United Kingdom (UK), and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use legal mechanisms, including contracts, to help ensure your rights and protections.
1. The Services operate from the United States, but this Policy applies worldwide. Our practices generally do not differ based on your location, but your rights and choices depend in part on the law where you live.
2. If any of these local privacy laws apply to you, that section overrides any contrary descriptions elsewhere in the Policy as they relate to you. If you have questions about your rights under other data privacy laws, please contact us.
Submitting requests
1. To exercise any rights described in this Policy, please contact us or use our Opt-Out Request Form (when available). Your request must:
Verifying requests
1. We verify requests by attempting to match information in the request to information we maintain. We may require you to confirm your identity by authenticating via your account or other access method.
Responses to requests
1. We will respond to your request as quickly as we can, taking into account the nature of your request and the volume of pending requests. The content of our response will vary with the nature of your request, but we will always respond in accordance with any deadlines or requirements specified by the laws that apply to you.
Appealing decisions
1. Residents of jurisdictions that provide for an appeal mechanism may appeal a decision we have made regarding their requests by contacting us.
1. Exercising your rights: If you are a resident of California, Colorado, Connecticut, Utah, Virginia or another state with a similar data-privacy law, you may have additional rights that you (or, in certain states, an authorized agent acting on your behalf) can exercise by contacting us, including the right to:
2. You also have the right to not be discriminated against for exercising your rights. You may also have the right to opt out of “sales” of your information and “sharing/processing of your information for targeted advertising.”
3. Certain information may be exempt from the requests above under applicable law. For example, we need to retain certain information in order to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request.
If you have any questions about these rights, wish to exercise them, or request an appeal, see Requesting information or contact us.
1. In addition to the rights described above, consumers residing in California are afforded the right to certain additional information with respect to their personal information under laws like the California Consumer Privacy Act (“CCPA”). If you are a California resident, this section applies to you.
2. Our collection and use of personal information: Information we collect falls into these CCPA-defined categories of personal information:
3. For more information about what we collect and the sources of such collection, please see the “Information we collect & why we use it” section of the Privacy Policy. To the extent we collect or use sensitive personal information as defined by law (such as CCPA), we do so in accordance with applicable legal requirements, and we do not use or disclose it other than for purposes for which there is not a right to limit under CCPA.
4. Disclosure of personal information: CCPA groups “Our disclosures of information to others” into the following categories of business or commercial purposes.
5. California’s ‘Shine the Light’ law. Under certain circumstances, Californians can request information about third parties who’ve received contact information and certain other types of personal information (as defined in the Shine the Light law), for their direct marketing purposes. We only share your personal information with third parties for their own direct marketing purposes with your consent and, if you have consented, only until you withdraw your consent. Consensual disclosures for direct marketing are generally exempt from Shine the Light’s disclosure requirement.
If you have any questions about these rights, wish to exercise them, or request an appeal, see Requesting information or contact us.
1. Overview: As described in the “How to control your privacy” section of the Policy, all our users have control over their information and can limit what data we process. In addition to these rights, users residing in the U.K., European Union and Switzerland are afforded the right to certain additional information with respect to their personal information under the GDPR. If you reside in any of those jurisdictions, this section applies to you.
2. Data retention and destruction: We retain personal information until we determine it is no longer necessary for (1) the processing purposes justifying its collection or (2) legal compliance purposes.
3. Exercising your rights: All our users have control over their information and can directly edit or delete information from their account and limit what data we process. Users in the European Union and Switzerland have additional rights that you can exercise by contacting us. Those rights include:
4. If you have any questions about these rights, wish to exercise them, or request an appeal, see Requesting information or contact us. Additionally, you may contact Phynd’s Privacy Officer by emailing privacy@phynd.co.
1. We comply with the Privacy Act 1988 (Cth) including the Australian Privacy Principles. You may contact us with questions or to complain about any privacy issues by emailing privacy@phynd.co. If you believe that we have failed to resolve the privacy complaint satisfactorily you have the option of contacting the OAIC. Contact details of the OAIC may be found here.
1. Overview: As described in the “How to control your privacy” section of the Policy, all our users have control over their information and can limit what data we process. In addition to these rights, users residing in Brazil are afforded the right to certain additional information with respect to their personal information under the Lei Geral de Proteção de Dados (LGPD). If you are a Brazilian resident, this section applies to you.
2. Exercising your rights: All our users have control over their information and can directly edit or delete information from their account and limit what data we process. Users in Brazil have additional rights that you can exercise by contacting us. Those rights include:
3. Questions or concerns about your privacy? You can email us at privacy@phynd.co.
1. Overview: As described in the “How to control your privacy” section of the Policy, all our users have control over their information and can limit what data we process. In addition to these rights, users residing in Canada are afforded the right to certain additional information with respect to their personal information under the Personal Information and Electronic Documents Act (PIPEDA). If you are a Canadian resident, this section applies to you.
2. Exercising your rights: Users in Canada have additional rights that you can exercise by contacting us. Those rights include:
3. If you have any questions about these rights, wish to exercise them, or request an appeal, see Requesting information or contact us. Additionally, you may contact Phynd’s Privacy Officer by emailing privacy@phynd.co.
1. Overview: As described in the “How to control your privacy” section of the Policy, all our users have control over their information and can limit what data we process. In addition to these rights, users residing in the Republic of Korea are afforded the right to certain additional information with respect to their personal information under the Personal Information Protection Act. If you are a Republic of Korea resident, this section applies to you.
2. Data retention and destruction: We retain personal information until we determine it is no longer needed for the processing purposes for which we collected or retain it or for legal compliance.
3. Exercising your rights: All our users have control over their information and can directly edit or delete information from their account and limit what data we process. Users in the Republic of Korea have additional rights that you can exercise by contacting us. Those rights include:
4. If you have any questions about these rights, wish to exercise them, or request an appeal, see Requesting information or contact us. Additionally, you may contact Phynd’s Privacy Officer by emailing privacy@phynd.co.