Privacy Policy

Last updated: 27 July 2026

This Privacy Policy explains how Alef Global Consulting FZ-LLC ("Backgammoney", "we", "us") collects, uses, discloses and protects personal data in connection with the Backgammoney mobile application and related services (together, the "Service"). Backgammoney is an online backgammon game, for entertainment purposes, in which you play games, alone or against an opponent, and may use virtual tokens ("Backgammoney") with no real monetary value.

We are ALEF GLOBAL CONSULTING FZ-LLC, a Free Zone Limited Liability Company registered in Ras Al Khaimah, United Arab Emirates (Services Licence No. 47029993), with its registered office at VUET2814, Compass Building, Al Hulaila Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates.

This Policy is drafted to meet the requirements of the EU/EEA and UK General Data Protection Regulation ("GDPR"), the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), other applicable U.S. state laws, the Brazilian data protection law ("LGPD"), and comparable data protection frameworks in other Latin American jurisdictions, as well as any other applicable data protection law depending on your place of residence. Section 11 details your rights by region.

1. Scope of this Policy

This Policy applies to persons who download, install or use the Backgammoney application, whether for free or by purchasing tokens, as well as to visitors of any Backgammoney website linking to this Policy. It does not apply to information processed by Apple, Google or other third parties acting as independent controllers/businesses (for example, your app store account and payment information), which is governed by their own privacy policies.

2. Who we are

Alef Global Consulting FZ-LLC is the controller (GDPR) / "business" (CCPA/CPRA) / "controller" (LGPD) of the personal data processed in connection with the Service, unless otherwise stated in this Policy.

• General privacy enquiries: contact@backgammoney.com
• Postal address: VUET2814, Compass Building, Al Hulaila Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates
• Representative in the European Union (Article 27 GDPR): Ms Laura Lopez, 17 rue de Ponthieu, 75008 Paris, France — email: CONTACT@ALEF-GLOBAL.COM — phone: +33 6 26 17 18 11

3. Personal data we collect

3.1 Information you provide to us

• Username – the display name you choose to play and appear to other players and in the ranking.
• Chat messages – the content of messages you exchange with other players or your friends within the Service, as well as the reports and blocks you make.
• Social relationships – your friends list and the friend codes/friend requests you use.
• Support communications – your email address and the content of any message you send to our support team.
• Age confirmation – the date of birth or age range you confirm upon registration, collected solely to verify that you meet the minimum age requirement to use the Service (see Section 12).
• Sign-in (where applicable) – if you sign in with Apple or Google, an identifier provided by these services to authenticate your account.
• Purchase status – confirmation of your token purchases and platform-provided identifiers (see Section 3.2).

3.2 Information collected automatically

• Technical and device data – device identifier (used as a pseudonymous account identifier), device type, operating system, application version and language settings, necessary for the proper functioning of the application.
• Country – a country code (for example "FR") derived from your device's language/region settings, used to display a flag and for aggregated audience statistics.
• Game data – your games and their history, your level (Elo), your ranking, your wins and losses, the balance and history of your virtual tokens, as well as the cryptographic hashes and seeds that make it possible to prove the fairness of the dice ("provably fair").
• Purchase/platform identifiers – provided by Apple's App Store and Google Play, used to verify and validate your token purchases.
• Limited diagnostic and security data – IP address and connection logs used for the stability of the Service and the prevention of abuse (for example limiting account creations), crash logs and basic usage signals.

We do not collect special categories of data (sensitive data) as defined by the GDPR.

4. Chat and multiplayer

Backgammoney includes social features (friends, chat, games between players) and games that may match you against other users or against automated opponents. Chat messages are visible to the players to whom you address them. The chat is subject to moderation (automatic content filtering, blocking and reporting) intended to ensure the security and integrity of the Service. We may retain and review reported messages for these purposes. Do not exchange highly sensitive personal information about yourself or a third party via the chat.

5. How we use your information

We use personal data to:

• provide the game, match games and manage the ranking;
• create, administer and secure your account, your token balance and your purchases;
• provide the social features (friends, chat) and moderate them;
• respond to support requests;
• ensure the security, integrity and proper operation of the Service, and prevent fraud, cheating or abuse;
• verify that you meet the minimum age requirement to use the Service (see Section 12);
• understand aggregate use of the Service in order to maintain and improve it; and
• comply with our legal obligations.

We do not use your information to serve third-party advertising, and we do not sell your personal data.

6. Legal bases for processing (GDPR/UK GDPR)

Where the GDPR or UK GDPR applies, we rely on the following legal bases:

7. Automated processing and automated opponents

Game matchmaking and some opponents rely on automated systems, which may include artificial intelligence. This processing does not produce a decision that has legal effects concerning you or similarly significantly affects you. We do not use your data to make automated decisions relating to your eligibility for any service, benefit or opportunity of real legal or financial value.

8. Providers and recipients of your data

We share only what is strictly necessary with a limited number of providers who process data on our behalf, under contractual instructions and confidentiality and security obligations:

We do not sell personal data to third parties, and we have not sold or "shared" (as that term is defined by the CCPA/CPRA) personal data in the past twelve months.

9. International data transfers

We are established in the United Arab Emirates, and our hosting provider Render hosts game data in its United States region (Render "US West / Oregon"). Where hosting or a provider is located outside the EEA (for example in the United States), the country concerned is not necessarily the subject of an adequacy decision by the European Commission.

Where we transfer personal data from the EEA, the United Kingdom or Switzerland to a third country, we rely on the European Commission's Standard Contractual Clauses (2021 version, supplemented where applicable by the UK International Data Transfer Addendum), together with, where our transfer risk assessment indicates it is necessary, additional technical and organisational measures. A copy of the applicable safeguards is available on request at contact@backgammoney.com.

For users in Brazil and other Latin American jurisdictions subject to cross-border transfer requirements (for example the LGPD), we apply contractual and technical safeguards designed to provide a comparable level of protection, and we will provide further information on such transfers on request.

10. Retention

We retain account, game and token data for as long as your account is active, then for the period necessary for the purposes described in this Policy. Chat messages and moderation data are retained for the period necessary for the security and integrity of the Service. Data is then deleted or anonymised, unless a longer retention period is required by law (for example, accounting or tax obligations). You may request the deletion of your account, as described in the Terms of Use and in Section 11.

11. Your privacy rights by region

11.1 European Economic Area, United Kingdom and Switzerland

If the GDPR, the UK GDPR or the Swiss FADP applies to you, you have the right: to access your personal data; to request its rectification or erasure; to restrict or object to certain processing; to request the portability of your data; and to withdraw your consent at any time without affecting prior processing. You also have the right to lodge a complaint with the supervisory authority of your habitual residence, your place of work, or the place of the alleged infringement (for example, the CNIL in France or the ICO in the United Kingdom). We endeavour to respond to verified requests within one month, extendable if necessary in accordance with applicable law.

11.2 California (CCPA/CPRA)

If you reside in California, you have the right: to know what personal information we collect, use and disclose; to request its deletion; to request its correction if inaccurate; to limit the use and disclosure of sensitive personal information; and not to be discriminated against for exercising these rights. We do not sell or "share" personal information within the meaning of California law. Verified requests are processed within 45 days (extendable by a further 45 days where the law permits). You may designate an authorised agent to submit a request on your behalf.

11.3 Other U.S. states

Residents of other U.S. states with comprehensive data protection laws (including, where applicable, Virginia, Colorado, Connecticut, Utah, and others) have similar rights to access, correct, delete and obtain a copy of their personal data, as well as the right to appeal the denial of a request. To exercise these rights, contact us at contact@backgammoney.com; we will identify and apply the relevant framework according to your state of residence.

11.4 Brazil and other Latin American jurisdictions

If the Brazilian LGPD or a comparable law of another Latin American country applies to you (for example in Mexico, Colombia, Chile or Argentina), you generally have the right: to confirm the existence of processing; to access your data; to have incomplete, inaccurate or outdated data corrected; to request the anonymisation, blocking or deletion of unnecessary or excessive data; to request the portability of your data; to obtain information about the entities with which we have shared your data; to revoke your consent; and, where applicable, to lodge a complaint with the competent supervisory authority (for example, the ANPD in Brazil).

11.5 Other jurisdictions

If you reside elsewhere, we will endeavour to respond to your requests in accordance with the principles described in this Policy and any locally applicable law. Contact us at contact@backgammoney.com.

12. Children's privacy

The Service is intended for adults and is not directed at children. Given the presence of virtual tokens staked within the game, it is restricted to persons at least 18 years old. We do not knowingly collect personal data from persons under 18, nor, for users in the United States, from children under 13 within the meaning of COPPA. If you believe that a minor has provided us with personal data, please contact us at contact@backgammoney.com and we will delete it.

• Age verification screen: upon registration, we ask you to confirm your date of birth or age range through a neutral screening step before you can access the Service. This is not an identity check (we do not ask for official ID), but a reasonable and proportionate measure to identify and exclude users who do not meet the minimum age requirement. If, despite this screening, your conduct suggests that you may be a minor, we may limit or suspend your access and, where applicable, delete the associated data.

13. Security

We implement appropriate technical and organisational measures to protect personal data and limit access to personnel and providers who need it to perform their duties. No method of transmission or storage is entirely secure, and we cannot guarantee absolute security.

14. Data breach notification

In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authorities and the individuals concerned in accordance with applicable law, including, where applicable, within the 72-hour deadline provided for in Article 33 GDPR.

15. Changes to this Policy

We may update this Policy from time to time. A revised version will bear a new update date and take effect upon publication. Where changes are material, we will notify you by an additional means (for example, via the application) before they take effect. Continuing to use the Service after a revised Policy takes effect constitutes acceptance of the changes, to the extent permitted by applicable law.

16. Contact us

Alef Global Consulting FZ-LLC VUET2814, Compass Building, Al Hulaila Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates Email: contact@backgammoney.com