Privacy Policy

Last updated: July 29, 2026

Introduction

Thank you for using MakePlay! Before using MakePlay, please read this Privacy Policy carefully to learn how we collect, use, disclose, and protect your personal data.

This Privacy Policy (“Privacy Policy”) explains how Shanda Group Corp (“we”, “us”, “our”) collects, uses, discloses, and protects personal data for which we are the controller in connection with our products, applications, websites, and services (collectively, the “Services”) — including when you use MakePlay (makeplay.ai) or visit our websites. Where we rely on your consent, we will obtain it as required by applicable law; where permitted, we also process personal data on other lawful bases, such as performance of our contract with you, our legitimate interests, and compliance with legal obligations, as described below.

If you do not agree with the terms of this Privacy Policy, you must not access or use any Services.

Unless otherwise specified, this Privacy Policy does not apply to any products and/or services provided by any third party independently through our Services (for example, third-party sign-in providers). We are not responsible for the privacy practices of third parties.

I. Collection of Personal Data

Personal Data You Provide Directly

• Account Information: When you create a MakePlay account, we collect your email address and, if you sign in with Google or Apple, the basic profile information they share with us (such as your name and email). If you set a password, we store it in hashed form and never in plain text.
• Public Profile Information: Your display name and a pixel-art avatar are generated for your account and shown on your public profile, along with your level and the games you have published.
• User Content: The prompts and chat messages you exchange with our AI while building a game, reference images you upload, comments, message-board posts, likes, favorites, remixes, and the games you publish (including their title, description, cover image, and play statistics).
• User Feedback: Ratings, bug reports, and other improvement suggestions, together with related conversation history, are stored when you provide feedback.
• Communications: Correspondence via our support channels is retained, including contact details and message content.

Automatically Collected Technical Data

• Device/Connection Metadata: device specifications, network information (ISP, IP-derived approximate location), and unique identifiers.
• Usage Analytics: access timestamps, navigation paths, and feature utilization patterns.
• System Logs: error reports, application state during incidents, and related user-provided context.
• Tracking Technologies: cookies and similar tools (see our Cookie Policy) enable user recognition, personalization, optimization, and — where applicable — communications.

Content Generation and Model Data Sources

To power the AI systems that build your games, we and the third-party AI model providers we engage may draw on publicly available internet sources, commercially licensed third-party datasets, user-contributed and crowd-worker-sourced materials, and internally generated synthetic data.

II. How Do We Use Your Personal Data

• Service Provision & Account Management: to build the games you describe, host and serve published games, display profiles and leaderboards, deliver notifications, administer your account, and enforce anti-abuse and fair-use limits.
• Communication & Support: to contact you regarding service updates, security alerts, and (where permitted) promotional materials, and to respond to inquiries and provide support. Where we use your personal data for direct marketing, we will do so in accordance with applicable law and give you an easy way to opt out at any time.
• Security & Compliance: to detect, prevent, and investigate fraud, abuse, or violations; to comply with legal obligations and enforce our Terms and Acceptable Use Policy; and to protect the security and integrity of our systems.
• Service Improvement & Research: to debug errors, optimize performance, and conduct research and development to improve MakePlay, including the AI systems used to build games. Your game descriptions, chat messages, and uploaded reference images are sent to the AI model providers we use (which may include third-party providers) in order to generate your game; those providers process this data pursuant to their own applicable terms, in addition to ours.
• Model Improvement. Depending on the feature you use and, where such a setting is offered, your account preferences, we and/or our AI model providers may use your Inputs and Outputs to improve the AI systems used to build games. In all cases, we may use content as necessary for safety, security, and legal-compliance purposes, and we may use de-identified or aggregated data. Where an opt-out setting is available, you may exercise or change your choice at any time through your account settings or by contacting us at support@makeplay.ai; opting out will not affect your access to the core features of the Services.

III. How Do We Use Cookies and Similar Technologies

We may use cookies and similar technologies (including browser cookies and web beacons) to authenticate users, remember your preferences, analyze trends, and understand how our Services are used. Some functions of our Services depend on cookies. If you disable or delete cookies, some features may not operate as intended. Please refer to your browser documentation to manage your cookie preferences, and see our Cookie Policy for how to control non-essential cookies, including how we honor Global Privacy Control (GPC) signals.

IV. How Do We Disclose Your Personal Data

• Internal & Affiliated Entities: we share personal data within our corporate group and affiliated entities to provide, maintain, and improve our Services.
• Service Providers & Business Partners: we engage trusted third parties for hosting and infrastructure, AI model providers that help generate your games, compliance and auditing, research and data processing, and customer support.
• Legal & Compliance Disclosures: we may disclose personal data to comply with legal obligations, to protect safety, rights, or property, and to enforce our Terms and Acceptable Use Policy.
• Business Transfers: if we undergo a merger, acquisition, or asset sale, personal data may be transferred as part of the transaction.
• Third-Party Integrations: our Services include sign-in integrations (such as Google and Apple) that operate under their own privacy policies.
• With Your Consent: we will share personal data with additional third parties only with your explicit permission.
• Published Games and Public Profile Information: When you publish a game, the game itself (including its title, description, cover image, and play statistics), your public profile (display name, avatar, level, and list of published games), your comments, message-board posts, leaderboard entries, and remix lineage (which game a remix is based on) are visible to other users and visitors of the Services. Studio chat messages you exchange with the AI while building an unpublished game, and files for unpublished drafts (game code, uploaded reference images, and playtest screenshots), remain private to your account — accessible only to you while signed in, or through short-lived signed preview links that the Services themselves create. Your email address is never shown publicly.

We do not sell your personal data for money, and we do not “sell” or “share” it for cross-context behavioral advertising as those terms are defined under California law.

V. How Your Personal Data May Be Transferred Globally

• Depending on where you are located and the features you use, your personal data may be transferred to, and stored and processed in, the United States, Singapore, and other countries where we, our affiliates, or our service providers (including cloud hosting and AI model providers) operate. These locations may change from time to time as we update our infrastructure and service providers.
• These countries may have data protection laws that differ from those in your jurisdiction.
• We take appropriate safeguards to ensure your personal data remains protected in accordance with this Privacy Policy and applicable laws. Where we transfer personal data across borders, we use legally valid transfer mechanisms and take steps designed to ensure a comparable standard of protection, including through contractual protections with the recipients of the data.

VI. How Do We Retain Your Personal Data

We retain personal data only as long as necessary for legitimate business needs or legal compliance. In determining retention periods we consider the amount, nature, and sensitivity of the data, the purposes for which we process it, whether we can achieve those purposes by other means, and applicable legal, tax, accounting, and reporting requirements. For example, account information is generally retained for the life of your account and for a limited period afterwards, and system logs are retained for a shorter period. In some cases we may retain data even after account deletion (for example, to comply with law, resolve disputes, or preserve games you have published and that other users have remixed). Once no longer needed, we securely delete or anonymize the data.

VII. How We Protect Your Personal Data

We implement industry-standard technical and organizational security measures to protect your personal data, including encryption (in transit and at rest), a comprehensive Information Security Program, malware protection, and access controls. However, no internet or wireless transmission can be 100% secure. You are responsible for maintaining the confidentiality of your account password and device security.

Data Breach Notification. Where required by applicable law, we will notify the relevant authorities and affected individuals of a data breach involving your personal data without undue delay and in accordance with applicable law.

VIII. How Do We Process Children’s Personal Data

Our Services are not directed towards, and we do not knowingly collect personal data from, children under the age of 13. If you become aware that a child under 13 has provided personal data to us, please email us at support@makeplay.ai and we will investigate and, if appropriate, delete the personal data.

Users between the age of 13 and the age of legal majority in their place of residence may only use the Services with the involvement and consent of a parent or legal guardian, consistent with our Terms of Service.

IX. Your Rights to Your Personal Data

Depending on the jurisdiction in which you reside, you may have the right to: access your personal data; erase or delete your personal data; update or correct your personal data; data portability; restrict or object to processing; withdraw your consent; and/or make a complaint to your data protection authority. You can exercise some of these rights through your account, or by submitting a request to support@makeplay.ai. We will respond within the time required by applicable law. We will not discriminate against you for exercising your privacy rights.

X. Additional Information for California Residents

If you are a California resident, the California Consumer Privacy Act (as amended by the CPRA) gives you the right to know the categories and specific pieces of personal information we collect, use, and disclose; to delete personal information; to correct inaccurate personal information; to opt out of the “sale” or “sharing” of personal information; to limit the use of sensitive personal information; and to be free from discrimination for exercising these rights. As stated in Section IV, we do not sell or share your personal information. We honor opt-out preference signals, including Global Privacy Control (GPC). To exercise your rights, contact us at support@makeplay.ai; you may use an authorized agent, and we will verify your request as required by law. Some of the information you provide (for example, the contents of your communications with the Services) may be “sensitive personal information”; you may request that we limit our use of it, and we do not use sensitive personal information to infer characteristics about you.

XI. How to Update the Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, regulatory, technical or business developments. Any changes will be communicated by updating the Privacy Policy accessible via the Services. For material changes, we will provide additional prominent notice (for example, by email or in-product notice) before the change takes effect. The updated Privacy Policy will become effective on the date specified.

XII. How to Contact Us

If you have any questions about this Privacy Policy, or any complaints or requests regarding your personal data, you can contact us by email at support@makeplay.ai.