Privacy Policy

1. General information

This privacy policy informs you about the nature, scope, and purpose of the processing of personal data within our apps and the functions and content associated with it. Our privacy policy should be simple and understandable for everyone. For this reason, our privacy policy generally uses the official terms of the General Data Protection Regulation (GDPR). The official definitions are explained in Art. 4 GDPR.

1.1 Controller within the meaning of data protection law

During the data processing described in this Privacy Policy, Dreamx Limited (Dreamx) and KashJoy Limited (KashJoy) (hereinafter "the Controllers") work closely together to provide our users with Dreamx's game apps and KashJoy's associated rewards program. This also concerns the processing of personal data relating to you. In this regard, the Controllers are jointly responsible (Art. 26 GDPR) for the protection of the personal data they process to the extent described below (2.1 – 2.5).

Contact details: Dreamx Limited / KashJoy Limited 7, 29/F, Ningjin Centre, 7 Shing Yip Street, Kwun Tong, Kowloon HONG KONG Workshop 30, 3/f, Blk A, East Sun Ind Ctr No. 16 Shing Yip St Kwun Tong

2. Data collection regarding the use of our apps

We take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy. When you download our apps, register, or log in to the apps and use the apps, certain personal data is processed. Personal data is data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

2.1 Access to and storage of information in terminal equipment

By using our apps, access to information (e.g., IP address) or storage of information (e.g., cookies or similar technologies) in your terminal equipment may occur. This access or storage may involve further processing of personal data pursuant to the GDPR.

In cases where such access to information or such storage of information is strictly necessary for the technically error-free delivery of our services, this is done based on § 25 para. 1 s. 1, para. 2 no. 2 TTDSG.

In cases where such a process serves other purposes (e.g., the needs-based design of our apps), this will only be carried out based on § 25 para. 1 TTDSG with your consent pursuant to Art. 6 para. 1 lit. a GDPR. The consent can be revoked at any time with effect for the future.

For more information on the processing of your personal data and the relevant legal basis in this context, please refer to the following sections on the specific processing activities in our apps.

2.2 Information collected during download of the apps.

When you download the apps, certain required information is transmitted to the app store you have selected (Google Play Store, Apple App Store). In particular, IP address, unique device ID, location, date and time of the request, time zone difference to Greenwich Mean Time (GMT), content of the request (specific page), access status/HTTP status code, amount of data transmitted in each case, app usage data, operating system and its interface language. We have no influence on this data collection and are not responsible for it. The contract is concluded with the respective provider of the store and is handled in accordance with their terms and conditions as well as their privacy policy. Within the scope of your use of the stores, we only process the reviews and associated data published by you on our apps and receive anonymous statistics via the stores, e.g., on download figures, uninstalls and crashes.

2.3 Data processing when using the apps.

As part of your use of the apps, we collect certain data that is required for the provision and use of the apps. The following data is processed for these purposes: internal device ID, version of your operating system, time of access, IP address, content of access, country of access.

This data is collected in order to provide you with the service and related functions and to prevent and resolve misuse and malfunctions. To do so we use our service provider IPQualityScore, LLC to estimate fraud risks and our service provider Ipregistry: PSI IPV Ltd, Oxford, UK to determine the country from which a user logs in based on the IP address.

If you use the KashJoy app, we collect information on your progress in the different game apps of Dreamx as well as your advertising data (see below) and connect this data with you via identifiers (GAID / Google App Set ID/ IDFA / IDFV / JustPlay User ID). To do so we use our service provider AppLovin Corporation, 1100 Page Mill Road, Palo Alto, CA 94304.

This data processing is justified by the necessity of the processing for the performance of the contract between you as the data subject and us pursuant to Art. 6 para. 1 lit. b GDPR for the use of the apps and by our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR in ensuring the functionality and error-free operation of the apps.Our apps are hosted by an external service provider (hoster). We use Google Cloud Services as a hosting service provider that processes data on servers in several global locations. Personal data collected through the apps is stored on the hoster's servers. We have concluded a Data Processing Agreement with the provider in accordance with the requirements of Art. 28 GDPR, in which they commit to protect the data of our customers and not to pass them on to third parties.

For using more functions of the apps, you are asked to provide us with certain data. Such data will only be sent and provided to us after you clicked the respective submit button within the apps.

If you are using additional payment options in our apps we may ask for your full name and address details and pass this information to the external payment service provider. The payment providers are either PayPal: 2211 N 1st St, San Jose, CA, USA, Tangocard: 4700 42nd Ave SW #430, United States or Tremendous: 592 Union St Ste 502, San Francisco, California, 94123, United States. However, please note that we do not process your payment data and bank account details but use external providers that handle the payments.

For the purpose of managing our customers, we may process user data in internally used systems. We base this data processing on Art. 6 para. 1 lit. b. and f. GDPR. We use our service providers Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland and Metabase, Inc 9740 Campo Rd. Suite 1029, Spring Valley, CA 91977 for this purpose.

You may request the deletion and change of entered data any time via message to [email protected]. Please note that this might not apply to data whose processing is needed for legitimate needs. This is in accordance with the “right to erasure” of GDPR.

If the data processed for providing the apps services are considered personal data, such data processing is based on Art. 6 (1) b. or f. GDPR for the purpose of providing our service and analysing those data based on our legitimate interests of improving our product and research purposes.

2.4 Technical functions of the apps

Only if further functions of the apps are to be used in addition to the basic functions, the following accesses can be requested:

Push Notifications: Push notifications are sent to keep you informed about various aspects of the app. Specifically, you will receive notifications regarding:

Status changes in your earnings.

Reminders related to your account or activities.

Updates to the app or its features.

Promotions and offers that may be of interest to you.

2.5 Contact via contact form, e-mail.

If you send us requests via our contact form or email, your details from the contact form or email, including the contact data you have provided there, will be stored for the purpose of processing your request and in the event of follow-up questions. Under no circumstances will we pass on this data without your consent. The legal basis for processing the data is our legitimate interest in responding to your request pursuant to Art. 6 para. 1 lit. f GDPR and, if applicable, Art. 6 para. 1 lit. b GDPR, provided that your request is aimed at concluding a contract.

You can object to the processing of your personal data at any time in the case of Art. 6 para. 1 lit. f GDPR. We may also contact you via app/email for purposes related to the use of the Apps or similar services based on Art. 6 (1) b. or f. GDPR.

In this context, we use our service providers Gmail, 1600 Amphitheatre Parkway in Mountain View, California Twilio Ireland Limited, 3 Dublin Landings, North Wall Quay, Dublin 1, Ireland and Zendesk, Inc, 1019 Market Street San Francisco California 94103.

3. Data transfer and recipients

Your personal data is not transferred to third parties, unless
we have explicitly pointed this out in the description of the respective data processing.
you have given your explicit consent in accordance with Art. 6 para. 1 lit. a GDPR.
the transfer pursuant to Art. 6 para. 1 lit. f GDPR is necessary for the assertion, exercise or defence of legal claims and our legitimate interests are not overridden by your fundamental rights and freedoms.
there is a legal obligation to transfer data pursuant to Art. 6 para. 1 sentence 1 lit. c GDPR, and
required by Art. 6 para. 1 sentence 1 lit. b GDPR for the execution of contractual relationships with you.

In addition, we use external service providers for the processing of our services, whom we have carefully selected and commissioned in writing. They are bound by our instructions and are regularly monitored by us. Required data processing agreements pursuant to Art. 28 GDPR are concluded before the commission. In particular, these contracts concern app-hosting services, the dispatch of emails and IT updates and maintenance.

When you use our apps, your data may also be processed in third countries outside the European Union (EU) and the European Economic Area (EEA) without an adequate level of data protection, e.g., in the U.S., especially if you have consented to a transfer of your data to our advertising partners.

To ensure an adequate level of data protection when transferring your data to third countries, standard contractual clauses of the European Commission are concluded in accordance with Art. 46 (2) lit. c DSGVO. They oblige the recipient of the data to process it in accordance with the European level of protection. A copy of the standard contractual clauses can be requested via the contact channels indicated above.

If the standard data protection clauses alone are not sufficient to ensure the level of protection, additional technical, contractual or organisational measures are taken to safeguard the transfer of data. Furthermore, it is regularly reviewed and evaluated whether these additional measures continue to ensure a sufficient level of data protection or whether further supplementary measures may need to be taken.

4. Storage period

The period for which the personal data will be stored is determined by the relevant statutory storage periods (e.g., from commercial law and tax law). The corresponding data is deleted routinely upon expiry of the respective period. If data is required for the fulfilment of a contract or contract initiation, or if we have a legitimate interest in further storage, the data will be deleted if they are no longer required for these purposes or if you make use of your right of withdrawal or objection. Your profile and account data are deleted after you deleted such data in your apps account or deleted the entire account via the respective button in the apps, which is more or less immediately after such deletion according to our deletion routines.

5. Cookies

Our apps use so-called “cookies” and similar technologies.
Cookies and similar technologies have various functions. They are technically necessary, as certain apps functions would not work without them. Some are used to evaluate user behaviour or display advertising.

The processing of data using strictly necessary cookies or similar technologies is based on § 25 para. 1 s. 1, para. 2 no. 2 TTDSG and a legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR in the technically error-free delivery of our services.

The processing of personal data using other cookies or similar technologies is based on consent in accordance with § 25 para. 1 TTDSG, Art. 6 para. 1 lit. a GDPR. The consent can be revoked at any time with effect for the future.

You can find more information about processing purposes and our advertising partners below. Purposes: 01 - Store and/or access information on a device
02 - Select basic ads
03 - Create a personalised ads profile
04 - Select personalised ads
05 - Create a personalised content profile
06 - Select personalised content
07 - Measure ad performance
08 - Measure content performance
09 - Apply market research to generate audience insights
10 - Develop and improve products


List of partners:
Ad Colony: 901 Mariners Island, Blvd, Suite 250, San Mateo, CA94404, United States
AD4Game: Ad4Game Inc on behalf of Liquid Media SARL, Ile Bizard, Quebec, Canada
AdJoe GmbH: An der Alster 42, 20099 Hamburg, Deutschland
Amazon: A9.com inc, 130 Lytton Ave Ste 300 Palo Alto, CA 94301, USA
AppLovin: Applovin Corporation, 849 High Street, Palo Alto CA 94301, United States
BidMachine: 1640 Boro Place, 4th Floor McLean, Virginia 22102, USA
Criteo: 32 Rue Blanche, Paris, France
Digital Turbine: 110 San Antonio St #160, Austin, Texas, USA
Doit (Google cloud reseller): 6 Liberty Square #2305 Boston, MA 02109, USA
Facebook A: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
FaceTec: 707 Village Center Cir Ste 250, Las Vegas, Nevada, 89134, United States
Fyber Germany: Fyber GmbH, Wallstr. 9-13, 10179 Berlin
Fyber Israel: Fyber MONETIZATION, 4 Hapsagot Street, St. Petach, Tikva na 49551447 Israel
Google Ads: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Google Ad Mob Network: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4 Ireland
Google In App Purchases (PlayDox Games): Google Payment Ireland Ltd. 70 Sir John Rogerson's Quay Dublin 2, Ireland
Index: 20 California St 6th Floor, San Francisco, United States
Inmobi: Cecil Street 19-08, PRUDENTIAL T SINGAPORE"
Ironsource (=SuperSonic Network): Azrieli Sarona Tower, Derech Menachem Begin 121, Tel Aviv 6701318 Israel
Kayzen: Ackerstraße 29, 10115 Berlin, Deutschland
LINE: Shibuya, 27F, Shibuya Hikarie, 2-21-1, Japan
Liftoff: 900 Middlefield Rd 2nd Floor, United States
LoopMe: 32-38 Saffron Hill, London, United Kingdom
MediaNet: 2505 2nd Ave. Suite 410 Suite 300 Seattle, Washington, 98121, United States
Mintegral (=Adlogic): 6 EU TONG SEN STREET 11-20 THE CEN, SINGAPORE
Mobilfuse: PO Box 37, Stirling, NJ 07980, USA
MOLOCO: 601 Marshall St #5th, Redwood City, United States
Ogury: Classic House, Martha's Buildings, 174-180 Old St, United Kingdom
OpenX: 177 E. Colorado Blvd. #3039. Pasadena, CA 91105 USA
Pangle: 13929 34th Rd Apt 6C, Flushing, New York, 11354, United States
PubMatic: 601 Marshall St, Redwood City, United States
Reklamup: Arsus Technologies Ltd., Free Port and Region, Mersin 10, Turkey
SEON Technologies Kft., Rákóczi út 42, 1072 Budapest
Sharethrough: 5455 Av. de Gaspé #730, Montreal, Canada
Smaato: San Francisco, 240 Stockton St, 9th Floor, San Francisco, CA 94108, USA
Start.io: 584 Broadway, New York City, USA
Tapjoy: 353 Sacramento St 6th Floor, San Francisco, United States
Tappx: Carrer de Rosselló i Porcel, 21, 15B, 08016 Barcelona, Spain
Triplelift: 53 W 23rd St 12th Floor, New York, NY 10010, USA
Unity Ads: Unity Technologies SF, 30 3rd Street, San Francisco, Califonia 94103, USA
Verve / PubNative: Verve Group Europe GmbH , Karl-Liebknecht-Str. 32, 10178 Berlin, Deutschland
Vungle / Liftoff: Vungle Inc., 1255 Battery Street, Suit 500, San Francisco, CA 94111, USA
Xandr: 1 Rockefeller Plaza, New York City, United States
You can change your privacy settings or withdraw your consent at any time by opening the menu point Privacy Settings.

6. Your rights

In the following, you will find information about your data subject rights, which the current data protection law grants you against the controller concerning the processing of personal data:

The right, pursuant to Art. 15 GDPR, to obtain information about your personal data processed by us. In particular, you may request information about the purposes of processing, the categories of personal data concerned, the categories of recipients to whom your data has been or will be disclosed, the envisaged period for which the data will be stored, the existence of the right to request from the controller rectification or erasure or personal data or restriction of processing of personal data concerning you or to object such processing, the existence of a right to lodge a complaint with a supervisory authority, the origin of your data, if these have not been collected by us, and the existence of automated decision-making including profiling and, if applicable, meaningful information about the logic involved, as well as the significance and the envisaged consequences.

The right to obtain without undue delay the rectification of inaccurate personal data concerning you. in accordance with Art. 16 GDPR.

The right to request the erasure of your personal data stored by us in accordance with Art. 17 GDPR, unless the processing is necessary to exercise the right of freedom of expression and information, to fulfil a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims.If you would like to have your personal data deleted please contact [email protected].

The right, pursuant to Art. 18 GDPR, to demand the restriction of the processing of your personal data if the accuracy of the data is contested by you, the processing is unlawful, but you oppose the erasure and we no longer need the data for the purposes of processing, but they are required by you for the establishment, exercise or defence of legal claims or you have filed an objection against the processing pursuant to Art. 21 GDPR.

The right, in accordance with Art. 20 GDPR, to receive the personal data concerning you, which you have provided to us in a commonly used and machine-readable format and the right to transmit those data to another controller. The right to withdraw your given consent pursuant to Art. 7 para. 3 GDPR with effect in the future at any time. The right to lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR, in particular in the Member State of your habitual residence, place of work.

The right to withdraw your given consent pursuant to Art. 7 para. 3 GDPR: You have the right to withdraw your given consent concerning the processing of your personal data with effect for the future at any time. In the event of withdrawal, we will delete the data concerned without delay, unless further processing can be based on a legal basis for processing without consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

7. Right to object

If your personal data is processed by us based on legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR, you have the right, pursuant to Art. 21 GDPR, to object at any time to the processing of your personal data on grounds relating to your situation. If the objection is directed against the processing of personal data for the purpose of direct marketing, you have a general right of objection without the requirement of stating a particular situation.

8. Necessity of providing personal data

The provision of personal data for the decision on the conclusion of a contract, the fulfilment of the contract or for the implementation of pre-contractual measures is voluntary. However, we can only make the decision in the context of contractual measures if you provide such personal data that is required for the conclusion of the contract, the fulfilment of the contract or pre-contractual measures.

9. Automated decision making / profiling.

For the purpose of fraud detection and prevention, certain criteria such as IP addresses and gaming behaviour are evaluated automatically. If several criteria apply that indicate fraudulent behaviour, players are partially or completely excluded from using the app. This data processing is necessary to properly process the contract concluded with the user (Art. 6 para. 1 lit. b GDPR, Art. 22 para. 2 lit. a GDPR). The data will be deleted after the evaluation.

10. Subject to change

We reserve the right to adapt or update this privacy policy, if necessary, in compliance with the applicable data protection regulations. In this way, we can adapt it to the current legal requirements and take account of changes to our services, e.g., the introduction of new services. The most current version applies to your visit.
Status of this privacy policy: 11 Oct 2023