Privacy Policy

This Privacy Statement explains how we collect, use, and disclose your personal information when you use the “Redvilla service” to access “Redvilla content” as those terms are defined in the Redvilla Terms of Use (redvilla.tech/terms-of-use). It also explains what privacy rights you have and how to exercise them. Certain functionalities or apps that are part of the Redvilla service may also provide you with contextual privacy information or choices, in addition to the information and choices described in this Privacy Statement. Please note that this Privacy Statement may be easier to navigate when viewed on your web browser.

Contacting Us

For questions about this Privacy Statement, our use of your personal information, or how to exercise your privacy rights, please contact our Data Protection Officer at info@redvilla.tech. For general questions about the Redvilla service, your account, or how to contact customer service, please visit redvilla.tech/contact.

Physical Address: 1001 S. Main Street, STE 500, Kalispell, MT – 59901, USA

Name and Representative: Redvilla Inc, Vedant Dighe

Contact Information: vedant@redvilla.tech

Section A: Our Collection, Use, and Disclosure of Personal Information

Data Minimization Commitment

Lawfulness, Fairness, and Transparency (GDPR Article 5(1)(a)): We process your personal data lawfully, fairly, and in a transparent manner. This Privacy Statement explains our processing activities in clear and plain language, specifying the legal basis for each type of processing, retention periods, and your rights.

We collect personal information that is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed (data minimization principle under GDPR Article 5(1)(c)). We collect information to provide our streaming and downloading services, process payments, improve user experience through analytics, and comply with legal obligations.

The Categories of Personal Information We Collect

We collect the following categories of personal information about you:

• Personal details: When you create your Redvilla account, we collect your contact information (such as your email address) and authentication information for your login (such as a password). Depending on how you subsequently set up your account and method of payment, and which features you use, we also collect one or more of the following: first and last name, phone number, and other identifiers you provide to us.
• Payment details: We collect your payment details, and other information to process your payments, including your payment history, billing address, and gift cards you have redeemed.
• Redvilla account/profile information: We collect information that is associated with your Redvilla account and/or Redvilla profiles on your account (such as profile name and icon, Redvilla game handle, ratings and feedback you provide for Redvilla content), “Playlist” (titles from playlist), account/profile settings, and choices in connection with your use of the Redvilla service.
• Usage information: We collect information about your interaction with the Redvilla service (including playback events, such as play, pause, etc.), choices made when engaging with interactive titles, your Redvilla game activity (such as gameplay, game use and interaction information, and progress or saved game information), Redvilla viewing and gaming history, search queries on the Redvilla service, and other information about your use and interaction with the Redvilla service (such as app clicks, text input, time and duration of access, and camera/photo access for QR-code and similar functionality).
• Device and network information: We collect information about your computer or other Redvilla capable devices you might use to access our service (such as smart TVs, mobile devices, set top boxes, gaming systems, and other streaming media devices), your network, and network devices. The information includes:
  • device IDs or other unique identifiers, including for your network devices (such as your router), and devices that are Redvilla capable on your network;
  • IP addresses (which can be used to tell us the general location of your device, such as your city, state/province, and postal code);
  • device and software characteristics (such as type and configuration), referring source (for example, referrer URLs), standard web browser and mobile app log information, and connection information including type (such as wifi or cellular);
  • performance data such as crash reports, timestamps, and debug log messages; and
• Communications: If you communicate with Redvilla (such as contacting customer support via online chat or voice call), engage in our surveys or feedback requests (such as when you cancel), we collect the contents of such communications. We also collect details of communications that we send you (such as via email, push notifications, text message, or within the Redvilla service), and information about your interaction and engagement with these communications.

Where We Collect Personal Information From

We collect your personal information from the following sources:

• Directly from you: When you register with the Redvilla, update your Redvilla account or profile, correspond with us, or respond to our surveys, you may provide (and we will collect) the following categories of personal information: personal details, payment details, Redvilla account/profile information, and communications.
• Automatically when you use our service: We automatically collect the following categories of personal information in connection with your use of the Redvilla service: Redvilla account/profile information, Location (Country), usage information, device and network information, and communications.
• From other sources: We may collect the following categories of personal information about you from other sources: personal details, payment details, and device and network information. These sources include:
  • Service Providers such as vendors, agents, and contractors that collect or provide personal information to Redvilla in connection with services they perform on our behalf (“Service Providers”). This may include Service Providers such as those that:
    • help us determine a general geographic location based on your IP address in order to customize our service and for other uses consistent with this Privacy Statement;
    • provide us with information to secure our systems, prevent fraud, and help us protect the security of Redvilla and our users;
    • provide us with payment processing services including payment or balance information, or updates to that information; and
    • provide Redvilla games, or portions or features of those games, as part of the Redvilla service (for example, some Redvilla games are licensed from and run by Service Providers).
  • We use analytics service provider under a Data Processing Agreement that includes Standard Contractual Clauses for international transfers. Analytics service provider processes your usage information and device data on our behalf and is prohibited from using your data for their own purposes.
  • Specific Third-Party Sources include:
  • Payment processors
  • Geolocation Services
  • Analytics providers
  • Cloud services
• Third-party sites and forums where we provide support for the Redvilla service (such as an online support forum for Redvilla customer support or for a particular Redvilla game).
• Publicly available sources such as public posts on social media platforms (for example, where you have tagged Redvilla in a publicly-available social media post, or shared or liked content we have made available on social media) and other information available through public databases, in accordance with applicable laws.

We collect this information using our proprietary tracking technologies, which do not share your data with third parties.

Legal Basis for Processing (GDPR)
We process your data under the following legal bases:

• Contractual Necessity: Payment details for subscription fulfillment and basic service delivery.
• Legitimate Interests: Usage data necessary to improve core service functionality & prevent fraud.
• Consent: Session replay analytics, detailed behavioral tracking through our Analytics Service Providers, marketing communications, and personalized content recommendations beyond basic service requirements (you may withdraw anytime).

Detailed Processing Activities (GDPR Articles 13 & 14 Requirements)

• Data Controller : Redvilla Inc., 1001 S. Main Street, STE 500, Kalispell, MT – 59901, USA
• Data Protection Officer Contact : info@redvilla.tech
• Processing Purposes with Specific Legal Basis :
• Account creation and management: Contractual necessity (Article 6(1)(b))
• Content streaming and downloading: Contractual necessity (Article 6(1)(b))
• Payment processing: Contractual necessity (Article 6(1)(b))
• Fraud prevention and security: Legitimate interests (Article 6(1)(f)) – our legitimate interest in protecting our service and users
• Website analytics via Analytics Service Providers: Consent (Article 6(1)(a)) – you can withdraw anytime
• Marketing communications: Consent (Article 6(1)(a)) – you can withdraw anytime
• Legal compliance (tax records): Legal obligation (Article 6(1)(c))”

Explicit Legal Basis Mapping

• Payment Processing: Contractual necessity (Article 6(1)(b))
• Fraud Prevention: Legitimate interests (Article 6(1)(f))
• Behavioral Analytics: Consent (Article 6(1)(a))
• Content Recommendations: Consent (Article 6(1)(a))
• Data Retention for Tax Compliance: Legal obligation (Article 6(1)(c))

Consent Requirements and Jurisdiction-Specific Rights

For users in the European Union and United Kingdom: We obtain your explicit consent before activating session replay functionality and behavioral analytics through Analytics Service Provider. When you first visit our service, you will see a consent banner allowing you to accept or decline analytics tracking. You can withdraw this consent at any time through your account security settings or by contacting us at info@redvilla.tech, though this may limit our ability to provide personalized recommendations and identify service improvements.

For users in California: Under the California Consumer Privacy Act, you have the right to opt out of the sharing of your personal information for analytics purposes. While we do not sell your personal information in the traditional sense, our use of analytics providers may constitute ‘sharing’ under California law. You can opt out of this sharing by visiting your account security settings or emailing info@redvilla.tech.

For users in South Korea: We obtain your explicit consent for all data processing activities, including analytics and session recording, as required under Korean Personal Information Protection Act (PIPA). This consent is obtained through our registration process and can be modified in your account settings.

For users in Canada: Under PIPEDA, we rely on your consent for analytics processing that goes beyond what’s necessary to provide our basic service. You can withdraw consent for analytics while maintaining your subscription to our core streaming service.

For users in Australia: We process your personal information in accordance with Australian Privacy Principles. For analytics and behavioral tracking that isn’t essential to service delivery, we obtain your consent through our privacy preference settings.

Age Restrictions & Children’s Privacy
We comply with COPPA (US) and GDPR (EU). Our service is designed for users aged 18 and older. However, we recognize that some content may appeal to younger audiences. If you are under 18, you must have parental consent to use our service. We do not knowingly collect personal information from children under 13 (US) or under 16 (EU) without verified parental consent. If we discover we have collected such information, we will delete it immediately. Parents/guardians may contact us at info@redvilla.tech.

Data Retention Periods (with Legal Basis)

• Payment Data: 7 years for tax compliance. (Tax compliance (26 USC §6001))
• Account Data: Retained while active + 2 years post-cancellation. (Contract administration)
• Usage Data: 1 year for service improvements. (Legitimate interests)
• Support Communications: 1 year (Service improvements)

International Transfer Details (GDPR Articles 44-49):

• Analytics Services: Data transferred to US under EU Standard Contractual Clauses with additional security measures including end-to-end encryption
• Payment Processing: Data transferred to US under adequacy decisions and/or Standard Contractual Clauses
• Cloud Storage: Data processed in US with data localization controls where legally required
• Transfer Safeguards: All transfers include contractual data protection obligations, technical security measures, and the right to challenge disproportionate government access requests

We implement age-gating during registration and do not process data for users under 16 without verified parental consent.

How We Use Your Personal Information

We use your personal information to provide, maintain, improve, and promote the Redvilla service, and to communicate with you. This involves using the categories of personal information listed above for the following purposes:

• To provide our service including all features and functionalities, websites and apps, user interfaces, and content and software associated with the Redvilla service. This includes personalized recommendations for Redvilla content that we think will be of interest to you (learn more regarding recommendations for shows and movies: redvilla.tech/how-redvilla-works). This may also include personalizing the features and functionalities of the service (such as the way in which the recommendations are presented to you), and localizing Redvilla content relevant to your geography in compliance with our content partners’ licensing terms. We use the following categories of personal information for this purpose: personal details, Redvilla account/profile information, usage information, device and network information, and communications.
• To administer and operate our business including purposes such as processing payments and any gift cards you redeem, sending transactional communications to you (such as confirmation of subscription start date or information about changes to your account), determining your internet service provider to support network troubleshooting issues, responding to your inquiries and requests, and assisting you with operational requests such as password resets. We use the following categories of personal information for this purpose: personal details, payment details, Redvilla account/profile information, usage information, device and network information, and communications.
• To research, analyze, and improve our services such as analyzing and understanding our audience to improve our services and optimize Redvilla content selection and service delivery. This may also include processing your personal information in connection with any surveys you participate in. We use the following categories of personal information for this purpose: personal details, payment details, Redvilla account/profile information, usage information, device and network information, and communications.
• To send marketing and informational messages including news and promotional communications about our service, new features, available Redvilla content, and special offers, as well as Redvilla marketing on third party services. Any of these messages, including Redvilla marketing on third party services, may be personalized for you or your likely interests. Please see the section “Communication Preferences” below to change your communications preferences. To understand your choices in connection with Redvilla’s marketing on third party services, please see the “Cookies” section below. Depending on the nature of the message we send, we may use the following categories of personal information for this purpose: personal details, Redvilla account/profile information, usage information, device and network information, and communications.
• For safety, security, and fraud prevention including to secure our systems, protect our business, and to investigate, prevent, and detect prohibited or illegal activities and other security/technical issues. We use the following categories of personal information for this purpose: personal details, payment details, Redvilla account/profile information, usage information, device and network information, and communications.
• To comply with law and enforce our Terms of Use including to satisfy applicable law, regulation, legal process, or governmental request, and to protect against harm to the rights, property or safety of Redvilla, its users or the public, as required or permitted by law. This also includes enforcing our terms, such as determining whether and for which Redvilla signup offers you are eligible and whether a particular device is permitted to use the account consistent with our Terms of Use. We use the following categories of personal information for this purpose: personal details, payment details, Redvilla account/profile information, usage information, device and network information, and communications.

Who We Disclose Personal Information To

We may disclose your personal information to the following parties:

• The Redvilla family of companies: We share your personal information among the Redvilla family of companies (see redvilla.tech/privacy-policy) as needed for the following purposes: to provide our service; to administer and operate our business; to research, analyze, and improve our services; to enable Partner integrations and promotions; to send marketing and informational messages; for safety, security, and fraud prevention; and to comply with law and enforce our Terms of Use.
• Service Providers: We use Service Providers to perform services on our behalf or to assist us with the provision of services to you. For example, we use Service Providers to provide communications, security, infrastructure and IT services, game-related services, to personalize and improve our service, and to process payments. We do not authorize them to use or disclose your personal information except in connection with providing their services (which may include maintaining and improving their services). To help maintain the safety and security of our service and users, we and our Service Providers may monitor and record message content (such as chat functionality) to identify harmful behavior, security risks, and violations of our Terms of Use and community guidelines. Our Service Providers may process your personal information for the following purposes: to provide our service; to administer and operate our business; to research, analyze, and improve our services; for safety, security, and fraud prevention; and to comply with law and enforce our Terms of Use.
• Promotional collaborations: We may collaborate with third parties to offer promotions. To fulfill these types of promotions, we and the third parties may use your personal information for the following purposes: to enable Partner integrations and promotions; and to send marketing and informational messages.
• Corporate transactions: In connection with a reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer personal information provided the receiving party agrees to respect your personal information in a manner that is consistent with this Privacy Statement. We may disclose your personal information in such instances for the following purposes: to provide our service; to administer and operate our business; to research, analyze, and improve our services; to enable Partner integrations and promotions; to send marketing and informational messages; for safety, security, and fraud prevention; and to comply with law and enforce our Terms of Use.
• Safety, security and fraud prevention: Redvilla may disclose your personal information to third parties where we reasonably believe disclosure is needed for the purpose of: safety, security, and fraud prevention.
• Compliance with law and enforcing our Terms of Use: We may disclose your personal information as necessary to comply with applicable law, regulation, legal process, or governmental request, and processing necessary to protect against harm to the rights, property or safety of Redvilla, its users or the public, as required or permitted by law. We may disclose personal information for the following purpose: to comply with law and enforce our Terms of Use.

We share personal data with the following categories of service providers:

Payment Processing Services (card networks and payment gateways)
• Digital Analytics and Performance Monitoring Services
• Cloud Infrastructure and Data Storage Services
• Email Communication and Customer Support Services
• Content Delivery and Streaming Infrastructure Services

International Transfers of Personal Information

Redvilla operates from various countries around the world, as do its Service Providers, Partners, and other third parties to whom we may need to disclose your personal information, as described above. This means that when you use or interact with Redvilla, your personal information may be transferred to other countries that have different data protection laws than those where you reside.

However, whenever we transfer personal information to other countries, we ensure that the personal information is transferred in accordance with applicable data protection laws and this Privacy Statement. Specifically, we use a variety of contractual, technical, and organizational measures as appropriate for such transfers, including data protection agreements, technical protections, and practices to challenge disproportionate or unlawful government authority requests. You can find out more about how we disclose and transfer your personal information internationally here: redvilla.tech/privacy-policy.

Data transfers outside your jurisdiction use EU Standard Contractual Clauses or UK International Data Transfer Addendum.

Safeguards for Transfers

• All transfers outside EEA/UK use EU Standard Contractual Clauses (SCCs) or UK IDTA.
• Copies of transfer mechanisms available at: redvilla.tech/data-transfer-safeguards
• Third-country recipients: Analytics Service (USA), Payment Service Provider (Global), Web Hosting Service (USA/EU)

Supplemental Privacy Disclosures

We provide supplemental information regarding certain aspects of the Redvilla service (such as certain Redvilla games features) in the section “Supplemental Privacy Disclosures for Certain Services” below.

Content Licensing

All content hosted on Redvilla is either (i) originally created by Redvilla Inc., (ii) licensed under open-source, public domain, or equivalent licenses that permit free commercial use, or (iii) legally obtained from authorized providers with verified non-infringing status. We do not host, sell, or distribute pirated, unauthorized, or infringing material.

To know more about how content is shared, visit our Licensing and Copyright Policy page.

To know more about content usage and ownership, visit our Public Domain Compliance Policy page.

Section B: Your Rights and Controls

Your Privacy Rights

• Access, correct, update, or delete your personal information: You have a right to confirm whether we process your personal information and to access and receive a copy of the personal information we process about you. You may also correct or update out-of-date or inaccurate personal information or request that we delete personal information that we hold about you.
  
  To request a copy of your personal information, please visit redvilla.tech/my-account/edit-account. In addition, under the “Edit Account” section of our website, you can access and update information about your account, including your contact information, payment information, and various related information about your account. You must be logged in to access the “Edit Account” section.
  
  For information about deletion, removal, and retention of personal information, please see: redvilla.tech/my-account/security/privacy-controls.
• Portability and downloading a copy of your personal information: You can request portability of or download a copy of your personal information. If you are the account owner, to download a copy of your personal information go to: redvilla.tech/my-account. For more information, please see: redvilla.tech/privacy-policy.
• Objection, restriction, and withdrawal of consent: You can object to or request that we restrict processing of your personal information. If we have collected and are processing your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. For more information, please see redvilla.tech/privacy-policy.
• Right to complain: You have the right to complain to a data protection authority about our processing of your personal information but we encourage you to first contact us with any questions or concerns.
• Right to rectification: You have right to correct inaccurate data about your account on Edit Account option inside your My account page
• Right to restriction of processing:  You may request the restriction of processing of your personal data When you contest the accuracy of your data (restriction lasts until we verify accuracy), When processing is unlawful, and you oppose erasure and instead request restriction, When we no longer need the data for processing, but you require it for legal claims, When you have objected to processing under Article 21, and verification of our legitimate grounds is pending. You can request us at info@redvilla.tech. Upon receiving your request, we will temporarily suspend processing of the relevant data (except storage) until the matter is resolved. You will be informed before the restriction is lifted.
• Right to object: You have the right to object at any time to the processing of your personal data based on Legitimate interests pursued by us or by a third party, Direct marketing (including profiling for marketing purposes). You can Opt out of Marketing, Interest processing on Privacy controls options of the My account page.
• Data portability format specifications: You may request to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format and to transmit it to another controller. Upon your request, we will provide your data within one month (extendable by two months for complex cases, with notice). The data can be provided in JSON (JavaScript Object Notation) – machine-readable and widely used, CSV (Comma-Separated Values) – for tabular data, XML (Extensible Markup Language) – where system compatibility requires it.
• Right not to be subject to automated decision making: You may have a right not to be subject to a decision made solely using automated means, where such decision would have a legal effect on you or produce a similarly significant effect.

Your Privacy Rights under GDPR

• Access : Obtain confirmation of processing and copy of personal data (Article 15)
• Rectification : Correct inaccurate data
• Erasure : Delete data under Article 17 conditions
• Portability : Receive data in structured, machine-readable format
• Object : Restrict processing under Article 21
• Withdraw Consent: For analytics/marketing at any time

Detailed Right of Access (GDPR Article 15 Compliance): When you submit a verified access request, we will provide you with:

• Confirmation of whether we process your personal data
• A copy of your personal data in a commonly used electronic format
• The purposes of processing and legal basis for each purpose
• Categories of personal data we process about you
• Recipients or categories of recipients of your data, including our service providers Analytics Service Provider, Payment Gateway and cloud infrastructure providers
• Retention periods or criteria for determining retention periods
• Information about the source of your data when not collected directly from you
• Details of any automated decision-making, including profiling (our content recommendation system)
• For international transfers: the country of destination and safeguards in place (Standard Contractual Clauses)

You can exercise the rights described above when we receive a verified request in accordance with applicable law.

User Rights & Response Times
We respond to access/deletion requests within 30 days. If denied, you may appeal via info@redvilla.tech.

Communication and Marketing Preferences & Consent Management

Email and Text Messages: If you no longer want to receive certain communications from us via email or text message, please access the “Privacy Controls” option for the relevant profile within the “Security” section of our website. Alternatively, click the “unsubscribe” link in the email or reply STOP (or as otherwise instructed) to the text message.

Analytics and Behavioral Tracking: You can control our use of analytics services and behavioral tracking through your Security > Privacy Controls. This includes:

• Session replay recording and user interaction analysis
• Detailed usage analytics beyond basic service functionality
• Behavioral profiling for personalized content recommendations
• Cross-session tracking and long-term usage pattern analysis

Granular Consent Controls: In your Security Settings, you can separately opt out of:

• Marketing communications (email, push notifications)
• Advanced analytics tracking (detailed behavioral analysis)
• Personalized content recommendations (algorithmic suggestions)
• Session replay functionality (user interaction recording)

Important: Withdrawing consent for analytics and behavioral tracking may limit our ability to provide personalized recommendations, but will not affect your access to our core streaming and downloading services. Changes to your consent preferences take effect within 48 hours.

Consent Withdrawal Confirmation: After making changes to your privacy preferences, you will receive a confirmation email confirming your new settings. You can modify these preferences at any time.

Data Subject Rights Exercise Process (GDPR Article 12 Compliance):

• Response Time : We will respond to your request within one month, with possible extension to three months for complex requests
• Verification : We may request additional information to verify your identity before processing requests.
• No Fee : We do not charge fees for reasonable requests, but may charge for excessive or repetitive requests.
• Request Methods : Email info@redvilla.tech or use our online portal at redvilla.tech/my-account.
• Appeal Process : If you are dissatisfied with our response, you may appeal by contacting our Data Protection Officer or lodge a complaint with your local supervisory authority.

Automated Decision-Making
We use automated profiling to personalize content recommendations. Opt-out by emailing info@redvilla.tech.

Automated Profiling

Cookie Choices

Your choices in connection with our use of cookies and similar technologies are described in the “Cookies” section below.

Contact and Questions

If you want to exercise any of your rights, or have a question regarding our privacy practices, please contact our Data Protection Officer at info@redvilla.tech.

CCPA Opt-Out
We do not sell your data.

Section C: Access to Account and Profiles

• Sharing your account with others: As a Redvilla member, if you share your account with others in your household, please ensure that they are aware of and have read this Privacy Statement. This Privacy Statement applies to their use of Redvilla (except sections that only apply to the member, such as those related to payments). Please note that the member controls the Redvilla account and all profiles, the information in the account and all profiles, and whether to share (or stop sharing) the account with individuals in their household.
  If you share or otherwise allow others to have access to your account, they may be able to see viewing information, account information in the “Edit Account” section of the service, and game related information such as chat contents and saved game information. This remains true even when you use the profiles feature. Please note that viewing history, recommendations, and similar information may be made available through various features and user experiences, such as Partner interfaces that are integrated with the Redvilla service.
• Profiles: Profiles allow users on a Redvilla account to have a personalized Redvilla experience, built around the Redvilla content of interest to them, as well as separate watch histories. Please note that profiles are available to everyone who uses your Redvilla account, so that anyone with access to your Redvilla account can navigate to and use, edit or delete profiles, and information within or associated with the profile (although, as noted above, you can add a Profile Lock PIN on a profile). You should explain this to others with access to your account, and if you do not want them to use or change your profile, be sure to let them know. Profile users may be offered the opportunity to add an email address, phone number, or other information to the profile and will be provided with a notice at the time such information is provided (the “Profile Privacy Notice” applies – see redvilla.tech/privacy-policy). We also have various parental controls available and you can learn more here: redvilla.tech/my-account/security/privacy-controls.
• Profile Transfers: The profile transfer feature on your account allows you and users with access to your account to transfer an eligible profile from your account to a separate account (including information such as viewing history and recommendations). You can change the setting for this feature in the “Security” section of our website. You can learn more here: redvilla.tech/my-account/security.
• Account Login Features: You may have the option to use certain account login features, such as email-based or text message-based login, or easier login to the Redvilla app on certain devices. Please note that any device that is logged into your account will remain logged in unless you log out of those devices (following the instructions in the section below).
• Removing device access to your Redvilla account: To remove access to your Redvilla account from devices that are logged into the account, visit the “Security” section of our website, locate the “Sign out of all devices” option under Devices option, and follow the instructions to sign out of your devices. Users of public or shared devices should log out at the completion of each session. If you sell or return a computer or Redvilla ready device, be sure to first log out. If you or other users on the account do not maintain the security of your email address, password, and signed-in devices, or fail to log out a device you sell or return, then subsequent users on that device will likely be able to access your Redvilla account, including your personal information.


• We Comply with GDPR Article 15(2): Upon verified request, we provide: (a) Data sources, (b) Recipient categories, (c) Int’l transfer safeguards

Section D: Cookies

Use of Cookies

We, and our Service Providers, use cookies, other similar technologies (such as pixel tags), and resettable device identifiers for various reasons. This section explains the types of technologies used, what they do, and your corresponding choices. To choose whether or not to receive cookies and similar technologies, please see the section below “How can I exercise choice regarding these technologies?”

Cookies and Tracking Technologies

Redvilla uses first-party cookies and similar technologies to:

• Keep you logged in
• Remember your preferences
• Analyze how our service is used
• Personalize your content recommendations

We use cookies to understand user behavior and improve our service. These cookies track your interactions across sessions and may create a behavioral profile for analytics purposes. EU and UK users can manage these preferences through our consent banner, while all users can adjust settings in their account preferences. Session replays exclude: Password fields, payment forms, and medical information. Data is pseudonymized within 24 hours.

Why Does Redvilla Use These Technologies?

We use these types of technologies for various reasons, including to provide our service (for example, by making it easy to access our service by remembering you when you return); to administer and operate our business, to research, analyze and improve our services (for example, to improve site performance, monitor visitor traffic and actions on our site, and to test the effectiveness of our user interface); to send marketing and informational messages (for example, to deliver and tailor our marketing, and to understand interactions with our emails, marketing, and marketing on third party services); for safety, security and fraud prevention; and to comply with law and enforce our Terms of Use.

We use pixel tags in our emails to understand how members interact with our services. Our use of pixel tags helps us understand when links within messages are clicked, or the emails are opened.

Redvilla uses resettable device identifiers to display marketing for our service or Redvilla content on third party services

We use session replay technology to record anonymized user interactions with our service, including mouse movements, clicks, and page navigation. This helps us identify usability issues and improve user experience. Session replays do not capture passwords, payment information, or other sensitive fields. You can opt out of session replay recording in your account security settings.

To learn more about How Redvilla works, please click here.

How can I exercise choice regarding these technologies?

• To exercise choice regarding cookies
  
  For more information about cookies set through our service and to exercise choices regarding cookies, click here. We do not currently respond to web browser “do not track” signals.
• To exercise choice regarding resettable device identifiers
  
  To exercise choice regarding Redvilla’s use of resettable device identifiers (for marketing the Redvilla service or Redvilla content), please configure the appropriate setting on your device (usually found under “privacy” or “ads” in your device settings). If you choose not to allow this, you may still see marketing messages promoting Redvilla on that device but it will not be selected based on the use of a resettable device identifier. Note that your choice regarding the resettable device identifier is specific to that device.
• To exercise choice regarding other similar technologies
  
  In addition to any choices we may offer you in the Redvilla service, there are several ways to exercise choice regarding technologies that are similar to cookies, such as browser storage and plugins (for example, HTML5, IndexedDB, and WebSQL). For example, many popular browsers provide the ability to clear browser storage, typically in the settings or preferences area. See your browser’s help function or support area to learn more. Most email clients have settings that allow you to prevent the automatic downloading of images, including pixel tags, and the automatic connection to the web servers that host those images. Other technologies may be cleared from within the application.

Section E: Other Important Privacy Disclosures

Sharing Functionality in our Service

You can use sharing functionality available in our service to disclose your personal information in the following ways:

• certain portions of our service may give you options to share information by email, text message, and social or other sharing applications, using the clients and apps on your device; and
• social plugins and similar technologies that allow you to share information.

Social plugins and social applications are operated by third-party social networks, and are subject to their terms of use and privacy policies. Similarly, some Redvilla game features may require use of a third party service, which is subject to that service’s terms of use and privacy policy.

Security

We use reasonable administrative, logical, physical, and managerial measures to safeguard your personal information against loss, theft, and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information.

Security Measures
Data is encrypted in transit (TLS 1.2+) and at rest (AES-256). We undergo annual third-party security audits.

Data Breach Notification
We take the protection of your personal information very seriously. In the unlikely event of a personal data breach, we will act in accordance with applicable data protection laws, including the European Union General Data Protection Regulation (GDPR) and other international privacy frameworks.

1. Notification to Supervisory Authorities

• If a breach of personal data is likely to result in a risk to the rights and freedoms of individuals, we will notify the relevant Data Protection Authority without undue delay and, where feasible, no later than 72 hours after becoming aware of the breach, as required by the GDPR.
• If notification cannot be made within 72 hours, we will provide reasons for the delay and supply the information in phases as it becomes available.

2. Notification to Affected Users

• If the breach is likely to result in a high risk to your rights and freedoms (e.g., identity theft, financial loss, reputational damage, or other significant harm), we will notify you without undue delay.
• This notification will be made in clear and plain language and will include:
• A description of the nature of the breach.
• The categories and approximate number of individuals affected.
• The categories and approximate number of records involved.
• The name and contact details of our Data Protection Officer (or designated contact).
• Likely consequences of the breach.
• Measures we have taken or propose to take to address the breach and mitigate possible adverse effects.

3. Exceptions to User Notification

We may not be required to notify you directly if:

• We have implemented appropriate technical and organizational measures (such as encryption) that render the data unintelligible to unauthorized persons.
• We have taken subsequent measures to ensure the high risk to your rights and freedoms is no longer likely to materialize.
• Direct notification would involve disproportionate effort, in which case we will make a public communication or take similar measures to inform you effectively.

4. Recordkeeping

We will document all personal data breaches, including the facts relating to the breach, its effects, and the remedial actions taken, regardless of whether notification is required.

Retention of Personal Information

We may retain personal information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes, and as otherwise necessary to fulfill the purposes described in this Privacy Statement.

Specifically, we retain personal information for as long as necessary to provide our service; to administer and operate our business; to research, analyze, and improve our services for safety, security, and fraud prevention; and to comply with law and enforce our Terms of Use. Our retention of personal information is based on many factors such as your relationship with Redvilla (for example, whether you are a current Redvilla member), the nature of the personal information, our legal obligations, and the need to defend or resolve current or anticipated legal claims.

We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required. For information about deletion, removal, and retention of personal information, please see: redvilla.tech/privacy-policy.

Data Protection Impact Assessment: We conduct annual DPIAs for high-risk processing activities including: Behavioral analytics, Payment processing, and Children’s data handling. Full DPIA reports available upon request to info@redvilla.tech

Data Protection by Design and by Default (Article 25)

We are committed to ensuring that privacy and data protection are integral to all aspects of our platform, in line with the GDPR and international best practices. We apply the principles of data protection by design and by default, meaning that we integrate security and privacy controls into our systems, processes, and products from the outset.

Specific technical and organizational measures include:

• Encryption Standards
• All personal data is encrypted during transmission using TLS 1.3 with AES-256 for secure connections.
• Data at rest is protected with AES-256 encryption.
• Passwords are stored using strong one-way hashing with bcrypt (minimum cost factor 12).

• Access Controls and Authentication
• Role-based access control (RBAC) ensures that employees can only access the data necessary for their job functions.
• Multi-factor authentication (MFA) is required for administrative and privileged accounts.
• Automatic session timeouts and account lockouts are enforced to prevent unauthorized access.

• Data Minimization Practices
• We collect only the personal data strictly necessary for the stated purpose.
• By default, optional fields are not mandatory, and unnecessary data is not retained.
• Anonymization and pseudonymization techniques are applied wherever possible (e.g., analytics data).
• Retention schedules are enforced, and data is deleted or anonymized when no longer required.

• Regular Security Assessments
• Quarterly vulnerability assessments and annual penetration tests are conducted by independent security professionals.
• Ongoing monitoring of systems and access logs detects unusual or unauthorized activity.
• Security controls and policies are reviewed at least once per year and updated to align with evolving industry standards.
• Employees undergo annual data protection and cybersecurity training.

Other Websites, Platforms and Applications

The Redvilla service may use, be provided through features operated by third party platforms (such as the display of social media content, or the provision of voice controls), or contain links to sites operated by third parties. In addition, you may encounter third party applications that interact with the Redvilla service. These third parties have their own privacy policies.

For example, you may be able to access the Redvilla service through platforms such as smart TVs, mobile devices, set top boxes, gaming systems, and other internet-connected devices. These platforms have separate privacy statements, notices, and terms of use, which we recommend you review.

We may provide support for the Redvilla service (such as an online support forum for Redvilla customer support, or a particular Redvilla game). Information that you post or make available on such sites and forums are publicly available (unless otherwise noted on the site or forum).

Kids

You must be at least 18 years of age or older (or the age of majority in your country of residence) to subscribe to the Redvilla service.

Changes to this Privacy Statement

We will update this Privacy Statement from time to time in response to changing legal, regulatory, or operational requirements. We will provide notice of any such changes (including when they will take effect) as required by law. Your continued use of the Redvilla service after any such updates take effect will constitute acknowledgement and (as applicable) acceptance of those changes. If you do not want to acknowledge or accept any updates to this Privacy Statement, you may cancel your account. To see when this Privacy Statement was last updated, please see the “Last Updated” date below.

To see the prior version of the Privacy Statement, please go to redvilla.tech/privacy-policy.

Section F: Supplemental Privacy Disclosures for Certain Services

The Supplemental Privacy Disclosures for Certain Services below apply in addition to disclosures above in this Privacy Statement.

Redvilla Games Supplemental Privacy Disclosures

When you play Redvilla games, we will collect, use, and disclose your personal information as described in the Redvilla Privacy Statement. These Redvilla Games Supplemental Privacy Disclosures provide additional examples and information applicable to Redvilla games that have features such as leaderboards, achievements, local multiplayer, online multiplayer, friend-related features, text chat, Redvilla game controller, and user-generated content.

Public Visibility Warning
Text chats and user-generated content (e.g., in games) may be visible to others. Exercise caution when sharing personal details.

The Categories of Personal Information We Collect

When you play Redvilla games, we collect the categories of personal information described in the Redvilla Privacy Statement. If you play games with the features mentioned above (or similar features), the following provides additional examples of the personal information we may collect:

• Redvilla account/profile information: We collect information that may be associated with your Redvilla account/profile, such as your friend or team list selections and the names of those teams, when you use features such as local multiplayer (for example, when players connect to your “Redvilla Game on TV” by scanning a code on the TV) and online multiplayer (interacting with other online players who are logged into their Redvilla accounts).
• Usage Information: We collect information about you and your use of Redvilla games, such as:
  • Your leaderboard status, score, and game achievements;
  • Whether you are online and/or playing a game in order to display your online or availability status to other players in the game and/or to your friend or team list;
  • Your searches for and connections with other players within a Redvilla game (for example, searching for and connecting to a player);
  • Your gameplay, interactions, or text chat with other players as a part of local multiplayer and online multiplayer features;
  • Your reports of violations of the Redvilla Games Community Guidelines (redvilla.tech/privacy-policy) and any similar guidelines for Redvilla games, and reports from other players about your potential violations; and
  • Your input of user-generated content within a Redvilla game, such as drawings, uploaded content (such as photos, videos, sound recordings, or other content), or your selection of content from a third party service.
• Device and network information: When you use Redvilla game controller functionality to connect to a Redvilla game (such as a “Redvilla Game on TV”), we collect information about the app, device, and the Redvilla account (if you are logged in) on which the Redvilla game controller is running.

How We Use Your Personal Information

When you play Redvilla games, we use personal information as described in the Redvilla Privacy Statement. If you play games with the features mentioned above (or similar features), the following provides additional examples of how we may use your personal information:

• To provide our service: When you play Redvilla games that include these features (or similar features), we use your personal information in order to provide the game including the features, as described below. We use the following categories of personal information used to provide our service with these features: Redvilla account/profile information, usage information, and device and network information. In particular:
  • For features such as leaderboards and game achievements, we use your personal information (such as your game handle), in order to display the leaderboard and achievements to you and other players;
  • For features that enable you to find or interact with other players in Redvilla games (such as online multiplayer games), we use your personal information and the personal information you provide about others in order to find that player and send them your connection request (and for them to find you and send you a connection request);
  • For online multiplayer games, we may use the general location of your device (such as your city, state/province, or country) to match you with other players that are close to the relevant game server so that your gameplay is less likely to be interrupted by internet delays;
  • For communication features, such as text chat, we transmit text communications you send to another player or group of players and to deliver text communications they send to you. Note that we may use Service Providers to perform services related to these communications on our behalf (as described in the Privacy Statement), which may include providing text chat, moderation, and related services; and
  • For user-generated content features, we use your personal information to display your user-generated content to other players in the Redvilla game, or in accordance with how you have shared the user-generated content (for example, on a third party service).

Who We Disclose Personal Information To

When you play Redvilla games, we may disclose personal information as described in the Redvilla Privacy Statement. If you play games with the features mentioned above (or similar features), the following provides additional examples of how we may disclose your personal information:

• Compliance with law and enforcing our Terms of Use: When you play Redvilla games with communications features (such as text chat), Redvilla and its Service Providers may access, preserve, and disclose your information in response to legal requests from third parties, including government agencies and civil litigants. We respond to legal requests where we have a good faith belief that we are required by law to respond, or where we have a good faith belief that a response is required by law in that jurisdiction and the request is consistent with internationally recognized standards such as the International Covenant on Civil and Political Rights. We disclose personal information for the following purposes: to comply with law and enforce our Terms of Use.

Other Players

Information such as your game handle, your gameplay, text chat, and user-generated content (including personal information and other information you provide in these features), and your online status will be publicly available to other players when you participate in a Redvilla game with features such as leaderboards, local multiplayer, online multiplayer, text chat, Redvilla game controller, and user-generated content. Please use good judgment when using text chat and user-generated content functions (note that even if you remove text chat, or user-generated content, players that have already seen that information may have saved it).

Games on TV and on redvilla.tech

Some “Redvilla Games on TV and on redvilla.tech” (see redvilla.tech/privacy-policy) allow you to connect to a game on a Redvilla member’s account using a Redvilla app on your device – for example, by scanning a code on their TV so you and the member can play a game together. For some of these games, you may not need to be logged into a Redvilla account in order to play the game. In that case, some of the disclosures in the Privacy Statement and these Redvilla Games Supplemental Privacy Disclosures will not apply to you, such as those relating to collection and use of personal details (see definition above), and the sections related to payment details and billing. Information that is collected as part of “Redvilla Games On TV or redvilla.tech,” such as usage information, device and network information, communications, and saved games or game activity, may be linked to the Redvilla account on which the game is running.

Notification of Changes
Major updates will be communicated via email or in-service notices 30 days prior to effect.

Last Updated: August 21, 2025