Play Hub Terms of Service

Last Updated: [DATE] | Effective Date: [DATE]

1. Introduction and Acceptance of These Terms

These Terms of Service (the “Terms”) are a legally binding agreement between you and [TAP NATION LEGAL ENTITY NAME AND FORM, e.g., TAP NATION SAS], a company incorporated under the laws of [COUNTRY, e.g., France], registered under number [COMPANY REGISTRATION NUMBER], with its registered office at [REGISTERED ADDRESS] (“TapNation”, “we”, “us”, or “our”).

These Terms govern your access to and use of: (a) the Play Hub mobile application (the “App”); (b) the companion web portal available at [WEB PORTAL URL] (the “Web Portal”); and (c) the rewards program made available through them (the “Rewards Program”) (collectively, the “Service”).

By downloading, accessing, or using the Service, you confirm that you have read, understood, and agree to be bound by these Terms and by our Privacy Policy, available at [PRIVACY POLICY URL], which is incorporated into these Terms by reference. If you do not agree to these Terms, you must not access or use the Service.

TapNation’s individual games (the “Connected Games”, as defined below) are separate applications governed by their own terms of service and privacy policies. These Terms apply to the Service only.

2. Definitions

“Connected Games” means the TapNation mobile games that participate in the Play Hub ecosystem, as listed within the App from time to time. The list of Connected Games may change at any time.
“TapCoin” means the display unit used in the App to represent the value of Rewards credited to your Rewards Account. TapCoin is a display representation only: it is not a separate currency, virtual item, cryptocurrency, or blockchain token, and it cannot be transferred or redeemed outside the Service except through Cash Out of the underlying Rewards. [CONVERSION RATE, e.g., 1,000 TapCoin = USD 1.00 — confirm and state the applicable display conversion]. TapCoin as used in the Service is distinct from any similarly named reward unit or asset used in individual TapNation games or third-party programs.
“Rewards” means the amounts credited to your Rewards Account under the Rewards Program. Rewards are displayed in the App in TapCoin, are denominated by reference to U.S. dollar value, and are held as digital assets as described in Section 7.
“Rewards Account” means the account and associated balance maintained for you within the Service, displayed in the App as your “Balance” or “Rewards”.
“Cash Out” means the redemption of Rewards through the Web Portal, as described in Section 8.
“Guest” means a user who accesses the Service without registering an account.

3. Eligibility

To access or use the Service, you represent and warrant that:

you are at least 18 years old (or the age of legal majority in your jurisdiction, whichever is higher) and have full legal capacity to enter into these Terms;
you are located in, and are a resident of, a jurisdiction where the Service is offered. The Service is currently available only in [LIST OF SUPPORTED COUNTRIES/REGIONS]. The Service is not available to residents of, or persons located in, [LIST OF EXCLUDED JURISDICTIONS — e.g., the State of New York (United States) and any other restricted U.S. states; countries subject to comprehensive sanctions]. We may change the geographic availability of the Service, in whole or in part, at any time;
you are not located in a country or territory subject to a comprehensive embargo by the European Union, France, the United Nations, or the United States, and you are not named on any list of prohibited, sanctioned, or restricted parties maintained by the European Union or its member states, the United Nations, the United States, or the United Kingdom;
you will not use a virtual private network (VPN), proxy, emulator, or any other tool or technique to misrepresent, conceal, or alter your actual location, device, or identity;
you are using the Service for your own personal, non-commercial use, and not on behalf of any other person or entity; and
you have not previously been suspended or banned from the Service or from any TapNation product for violation of applicable terms.

If we determine that you do not meet, or have ceased to meet, any eligibility requirement, we may suspend or terminate your access to the Service and withhold or cancel Rewards in accordance with Section 11 and applicable law.

4. Guest Access and Account Registration

4.1 Guest Access

You may begin using the Service without registering an account. When you first launch the App, a Guest profile is created and associated with your device. As a Guest, you can browse Connected Games, participate in the Rewards Program, accumulate Rewards, view your profile, and apply a referral code shared with you. Certain features require a registered account, including Cash Out, editing your profile, and sharing your own referral link.

Important: your Guest profile is tied to your device. If you delete the App, reset your device, or lose access to it before registering an account, your Guest profile and any associated Rewards may be permanently unrecoverable. We strongly recommend registering an account to secure your progress and Rewards.

4.2 Account Registration

You can register an account using a supported sign-in method (email verification, Google Sign-In, or Apple Sign-In), and you may link additional supported sign-in methods to the same account. When you register, your existing Guest profile and any associated Rewards are linked to your account. If you sign in to an existing registered account while holding Rewards under a Guest profile, the Rewards accumulated under the Guest profile are transferred to that account [CONFIRM MERGE BEHAVIOR AND ANY CONDITIONS ONCE FINALIZED WITH THE WALLET INFRASTRUCTURE PROVIDER]. You agree to provide accurate, current, and complete information, and to keep it up to date.

You are responsible for maintaining the confidentiality of your sign-in credentials and for all activity that occurs under your account. You must notify us immediately at [SUPPORT EMAIL] if you suspect any unauthorized use of your account.

4.3 One Account Per Person; No Transfers

You may maintain only one account (including Guest profiles). Accounts and Rewards are personal to you: you may not sell, rent, lend, transfer, or share your account, and you may not buy, sell, or trade Rewards or TapCoin outside the Service. Any attempted transfer is void and constitutes a breach of these Terms.

5. License and Intellectual Property

Subject to your compliance with these Terms, TapNation grants you a limited, personal, non-exclusive, non-transferable, non-sublicensable, and revocable license to install and use the App on a mobile device that you own or control, and to access the Web Portal, solely for your personal, non-commercial use.

The Service (including all software, designs, graphics, animations, text, logos, trademarks, and other content) is owned by TapNation or its licensors and is protected by intellectual property laws. Except for the limited license above, no rights are granted to you. You may not copy, modify, distribute, sell, lease, decompile, or reverse engineer any part of the Service, except to the extent such restriction is prohibited by applicable law.

If you provide feedback, suggestions, or ideas about the Service, you grant TapNation a worldwide, perpetual, irrevocable, royalty-free license to use them without restriction or compensation.

6. The Rewards Program

6.1 Overview

The Rewards Program allows you to receive Rewards based on your activity in Connected Games and, where applicable, in the App itself. Your activity (such as game sessions, advertisements viewed, and advertising revenue attributable to your gameplay) is measured through third-party attribution and analytics technology and reported to the Service. Rewards are granted through three mechanisms: Personal Milestones, the Weekly Leaderboard, and the Referral Program.

6.2 Game Discovery

The App allows you to discover Connected Games. When you tap “Play”, you are directed to the Apple App Store or Google Play Store to download or open the relevant game on your device. Gameplay takes place inside the Connected Games, not inside the App. For your activity to be attributed to your Rewards Account, the Connected Game must be installed [via the App’s referral flow / attribution requirements — confirm and describe any conditions, e.g., whether pre-existing installs are eligible].

6.3 Personal Milestones

Your personal milestone progress is based on the advertising revenue attributable to your activity in Connected Games, as measured by our attribution systems. When your cumulative attributed revenue reaches a milestone threshold, you may claim the corresponding Reward in the App. Milestone thresholds and Reward amounts are set by TapNation, are currently based on [REWARD RATE, e.g., approximately 20% of attributable ad revenue — confirm whether/how this is communicated], and may be modified at any time in accordance with Section 6.8.

6.4 Weekly Leaderboard

The Weekly Leaderboard ranks participating users based on points accumulated from advertisements viewed in Connected Games (including rewarded and interstitial video advertisements) [and, if applicable, in the App]. Each leaderboard cycle runs for one week, starting and ending at [DAY AND TIME, INCLUDING TIME ZONE, e.g., Monday 00:00 UTC].

At the end of each weekly cycle, a prize pool is distributed among participants proportionally to each participant’s share of the total points accumulated during that cycle. The prize pool for each week is funded based on overall player activity across the ecosystem during the preceding week, and its size therefore varies from week to week. [CONFIRM ANY MINIMUM/MAXIMUM POOL SIZE, MINIMUM POINTS THRESHOLD TO QUALIFY, AND ROUNDING RULES.]

Any prize pool amounts, rankings, or estimated rewards displayed during an ongoing cycle are estimates only, may change as other users accumulate points, and are not guaranteed. Only the final distribution at the end of the cycle is binding. TapNation may exclude from the leaderboard, and from any distribution, points or activity that it reasonably determines to be fraudulent, artificial, or generated in breach of these Terms.

6.5 Referral Program

Registered users may invite friends using a personal referral link or code. When a referred user joins the Service through your link and generates attributable activity, you receive a referral Reward equal to [REFERRAL PERCENTAGE, currently 5%] of the [revenue basis — e.g., net advertising revenue] attributable to that referred user [for a period of TIME LIMIT, if any, or indefinitely — confirm]. A referred user can apply a referral code in the App [ELIGIBILITY WINDOW FOR APPLYING A CODE, IF ANY].

Referral Rewards are only granted for genuine, new users. Self-referrals, referrals of accounts you control, referrals generated through bots, emulators, purchased installs, or other artificial means, and any other manipulation of the referral program are prohibited. We may withhold, review, and cancel referral Rewards that we reasonably believe were generated in breach of this Section.

6.6 No Guaranteed Reward Amounts

Participation in the Rewards Program does not entitle you to any specific, minimum, or guaranteed amount of Rewards. Reward rates, milestone thresholds, point values, conversion rates, and prize pool amounts depend on many factors (including advertising market conditions and overall ecosystem activity) and may change at any time. Any amounts shown in our advertising or marketing materials are illustrative examples only and do not reflect guaranteed reward amounts.

6.7 Errors and Adjustments

If Rewards are credited to your Rewards Account in error (including as a result of a technical malfunction, incorrect attribution, duplicate crediting, or fraud), TapNation may correct the error, including by adjusting or deducting the erroneously credited amounts, and will inform you of any material correction where practicable.

6.8 Changes to the Rewards Program

TapNation may modify, suspend, or discontinue the Rewards Program or any of its mechanics (including reward rates, thresholds, the list of Connected Games, and available features) at any time. Where a change materially reduces the Rewards you can receive, we will provide notice through the App where reasonably practicable and as required by applicable law. Rewards validly accrued and credited to your Rewards Account before such a change remain redeemable in accordance with Section 8, unless they were obtained in breach of these Terms.

6.9 Nature of the Program

Participation in the Rewards Program is free of charge. No purchase or payment is necessary to participate or to receive Rewards. The Rewards Program is a promotional loyalty and engagement program based on your activity; it is not a lottery, a game of chance, gambling, betting, or wagering, and it is not an investment product, savings product, or employment relationship.

7. Rewards, Balances, and Underlying Digital Assets

7.1 How Your Balance Is Displayed

Your Rewards balance is displayed in the App in TapCoin [CONFIRM WHETHER A USD EQUIVALENT IS ALSO DISPLAYED ANYWHERE]. The underlying value of your Rewards is held in the form of USDC, a U.S. dollar–referenced stablecoin issued by a third party (Circle Internet Group, Inc. or its affiliates), recorded on the [Arbitrum] blockchain network [list any additional networks used].

7.2 Your Blockchain-Based Rewards Account

To hold your Rewards, a self-custodial digital asset account (a blockchain “wallet” using multi-party computation technology) is created for you automatically, at the point it is needed to receive and hold your Rewards, through our third-party wallet infrastructure provider, [WALLET INFRASTRUCTURE PROVIDER, e.g., Sequence (Horizon Blockchain Games Inc.)]. This account is created and operated in the background so that you do not need to manage keys, addresses, or blockchain transactions yourself.

The wallet is non-custodial: TapNation does not hold or control the private key material for your wallet and does not take custody of your Rewards. Access to the wallet is secured through your device and, once registered, your account credentials. [CONFIRM DESCRIPTION WITH FINAL ARCHITECTURE AND WITH COUNSEL — the custody characterization has significant regulatory consequences (including under MiCA).]

7.3 Not a Bank Account; No Interest; No Deposit Protection

Your Rewards Account is not a bank account, deposit account, electronic money account, or payment account. TapNation is not a bank, credit institution, or licensed payment or electronic money institution. Rewards do not bear interest. Rewards and the underlying digital assets are not covered by any deposit guarantee or investor compensation scheme (including the French Fonds de Garantie des Dépôts et de Résolution or the U.S. FDIC).

7.4 Digital Asset and Network Risks

The value of USDC is intended to track the U.S. dollar, but this is not guaranteed by TapNation. Digital assets involve risks, including the risk that an issuer fails to maintain the asset’s value or redeemability, and risks arising from blockchain network congestion, forks, outages, or vulnerabilities. TapNation is not responsible for the acts or omissions of the stablecoin issuer, blockchain networks, or other third parties outside its reasonable control, to the extent permitted by applicable law.

7.5 Network Fees

Blockchain network (“gas”) fees for transactions performed within the Service are currently paid by TapNation on your behalf. [CONFIRM WHETHER ANY FEES ARE PASSED ON FOR SPECIFIC OPERATIONS, e.g., external crypto transfers, and describe them here or in the fee schedule referenced in Section 8.5.]

8. Cash Out

8.1 Cash Out Through the Web Portal

Rewards can be redeemed only through the Web Portal, which you can access from the App via the “Cash Out” action. Cash Out is not available inside the App itself. When you access the Web Portal from the App, you are authenticated automatically through a secure sign-on link.

8.2 Account and Identity Verification

Cash Out is available only to registered users. Before processing a Cash Out (or at any time thereafter), TapNation and/or its third-party payout partners may require you to verify your identity, age, and place of residence, including by providing identity documents (“KYC” checks), where required by applicable law or reasonably necessary for fraud prevention. If you do not complete a required verification, we may decline or hold the Cash Out and, where the failure persists, restrict your account, in each case in accordance with applicable law.

8.3 Cash Out Options

Available Cash Out options may include: (a) gift cards; (b) bank transfers (fiat payout); and (c) transfers of digital assets to an external wallet address. Cash Out options are provided through third-party providers [LIST OF PAYOUT / OFF-RAMP PROVIDERS — current primary candidate: Cryptorefills for gift cards; bank transfer and external transfer providers TBD], and their availability varies depending on your location, the amount redeemed, and provider availability. TapNation does not guarantee that any particular option will be available to you at any given time.

8.4 Minimums, Limits, and Frequency

Cash Outs are subject to: a minimum amount of [MINIMUM CASH OUT AMOUNT PER METHOD]; maximum limits of [MAXIMUM LIMITS, IF ANY]; and frequency limits of [FREQUENCY LIMITS, IF ANY]. Current thresholds and limits are displayed in the Web Portal and may be updated from time to time.

8.5 Fees and Conversion

Third-party providers may charge fees, apply exchange rates, or apply spreads to Cash Out transactions. Any fees applicable to a Cash Out will be displayed to you before you confirm the transaction. [LINK TO FEE SCHEDULE, IF ANY.]

8.6 Processing, Holds, and Refusals

Processing times vary by Cash Out method and provider. TapNation may place a Cash Out on hold for a reasonable period, not exceeding [MAXIMUM HOLD PERIOD, e.g., 30 days] except where a longer period is required by law or by an ongoing investigation, in order to complete verification or fraud review. TapNation may refuse a Cash Out where it reasonably believes the underlying Rewards were obtained in breach of these Terms, or where processing it would violate applicable law.

8.7 Third-Party Provider Terms

Cash Out options are performed by third-party providers under their own terms and privacy policies, which you may be required to accept. TapNation is not a party to your relationship with those providers and, to the extent permitted by applicable law, is not liable for their acts or omissions.

8.8 Irreversible Transfers

Transfers of digital assets to an external wallet address are irreversible once executed on the blockchain. You are solely responsible for ensuring that any external address you provide is correct and compatible with the asset and network used. TapNation cannot recover assets sent to an incorrect address at your instruction.

9. Inactivity, Expiry, and Dormant Balances

[POLICY DECISION REQUIRED — confirm with legal counsel whether V1 includes reward expiry and/or dormant account handling, and on what conditions. A common market practice (e.g., comparable rewards apps) is expiry of unredeemed rewards after 6–12 months of inactivity, subject to prior notice. Any such rule must be assessed against consumer protection law in each supported jurisdiction.]

[IF ADOPTED:] If your account (including a Guest profile) shows no activity for a continuous period of [INACTIVITY PERIOD], we may notify you using the contact details associated with your account (where available) and, if no activity resumes within [NOTICE PERIOD], your unredeemed Rewards may expire and your account may be deactivated, in each case to the extent permitted by applicable law.

10. Prohibited Conduct

In connection with the Service, you must not:

provide false, inaccurate, or misleading information, or impersonate any person or entity;
create or use more than one account, or create accounts on behalf of others;
use emulators, virtual machines, simulated or virtualized devices, device farms, or modified operating environments to access the Service or Connected Games, or otherwise misrepresent your device;
use bots, scripts, macros, automation tools, or any non-human means to generate activity, points, impressions, installs, or Rewards;
engage in advertising fraud of any kind, including generating artificial ad impressions or views, click injection or spoofing, faking, replaying, or manipulating attribution events, callbacks, or postbacks, or otherwise falsifying activity data;
intercept, tamper with, modify, or replay network traffic between the Service, Connected Games, and our or our partners’ servers, or probe, scan, or test the vulnerability of the Service;
use a VPN, proxy, or similar technique to conceal or misrepresent your location or identity, or to access the Service from an unsupported jurisdiction;
buy, sell, rent, trade, or transfer accounts, Rewards, or TapCoin, or offer to do so;
abuse the referral program as described in Section 6.5;
exploit any bug, error, or unintended behavior of the Service for gain. If you discover a bug or vulnerability, you must report it to [SECURITY / SUPPORT EMAIL] and must not exploit or disclose it publicly;
reverse engineer, decompile, or disassemble any part of the Service, except to the extent expressly permitted by applicable law notwithstanding this restriction;
use the Service for money laundering, terrorist financing, sanctions evasion, or any other unlawful purpose; or
use any username, avatar, or other content that is unlawful, infringing, hateful, sexually explicit, or otherwise inappropriate.

11. Monitoring and Enforcement

We use technical and organizational measures to detect fraud and abuse, which may include device integrity checks, emulator and VPN detection, device fingerprinting, IP analysis, server-side validation of activity data, and manual review. These measures are described further in our Privacy Policy.

If we reasonably believe you have breached these Terms (including the eligibility requirements in Section 3 or the prohibitions in Section 10), we may, proportionately to the seriousness of the breach: (a) issue a warning; (b) withhold, cancel, or reclaim Rewards that we reasonably determine were obtained through, or are attributable to, the breach; (c) suspend or restrict your access to some or all of the Service; (d) terminate your account and ban your associated devices; and/or (e) take legal action and report the matter to competent authorities.

Except where prohibited by law or where doing so would compromise an investigation or security measures, we will inform you of the measure taken and its reasons, and you may contest it by contacting [SUPPORT EMAIL]. We will review contested decisions with human involvement where required by applicable law.

12. Connected Games, App Stores, and Third-Party Services

Connected Games are separate applications governed by their own terms and privacy policies. Your use of the Apple App Store and Google Play Store is governed by their respective terms. The Service relies on third-party services, including attribution and analytics providers, wallet infrastructure providers, advertising networks, and payout providers; where those services process your personal data, this is described in our Privacy Policy.

The Service may contain links to third-party websites or services. TapNation does not control and is not responsible for third-party websites or services, and linking does not imply endorsement.

13. Additional Terms for App Store Distributions

These Terms are between you and TapNation only, and not with Apple Inc. (“Apple”) or Google LLC (“Google”). Apple and Google are not responsible for the App or its content, and have no obligation to provide maintenance or support for the App.

To the extent required by Apple’s Licensed Application End User License Agreement: (a) in the event of any failure of the App to conform to an applicable warranty, you may notify Apple, and Apple will refund any purchase price paid for the App (the App is free of charge); to the maximum extent permitted by law, Apple has no other warranty obligation with respect to the App; (b) Apple is not responsible for addressing any claims by you or a third party relating to the App, including product liability claims, claims that the App fails to conform to legal or regulatory requirements, and consumer protection or similar claims; (c) in the event of a third-party claim that the App infringes intellectual property rights, TapNation, not Apple, is responsible for the investigation, defense, settlement, and discharge of such claim; and (d) Apple and its subsidiaries are third-party beneficiaries of these Terms and may enforce them against you.

You represent that you are not located in a country subject to a U.S. Government embargo or designated as a “terrorist supporting” country, and that you are not listed on any U.S. Government list of prohibited or restricted parties.

14. Disclaimers

The Service is provided “as is” and “as available”. To the maximum extent permitted by applicable law, TapNation disclaims all warranties, whether express, implied, statutory, or otherwise, including implied warranties of merchantability, fitness for a particular purpose, and non-infringement. We do not warrant that the Service will be uninterrupted, error-free, or secure, or that activity in Connected Games will always be accurately attributed.

Nothing in these Terms limits or excludes any warranty or guarantee that cannot be limited or excluded under the mandatory consumer protection laws applicable in your country of residence.

15. Limitation of Liability

To the maximum extent permitted by applicable law: (a) TapNation shall not be liable for indirect or consequential losses, loss of profits, loss of data, or loss of opportunity arising out of or in connection with the Service; and (b) TapNation’s total aggregate liability arising out of or in connection with these Terms and the Service shall not exceed the greater of (i) the value of the validly accrued, unredeemed Rewards credited to your Rewards Account at the time the liability arose, and (ii) [LIABILITY CAP, e.g., EUR 100].

Nothing in these Terms excludes or limits TapNation’s liability for: death or personal injury caused by its negligence; fraud or fraudulent misrepresentation; gross negligence or willful misconduct; or any other liability that cannot be excluded or limited under applicable law. If you are a consumer in the European Union, you benefit from the mandatory provisions of the law of your country of residence, and nothing in these Terms affects your rights under those provisions.

16. Indemnification

To the extent permitted by applicable law, you agree to indemnify and hold harmless TapNation and its affiliates, officers, employees, and agents from and against any claims, liabilities, damages, losses, and expenses (including reasonable legal fees) arising out of or related to: (a) your breach of these Terms; (b) your fraudulent or unlawful use of the Service; or (c) your violation of any third-party right. This Section does not apply to the extent prohibited by mandatory consumer protection law in your country of residence.

17. Suspension and Termination

17.1 Termination by You

You may stop using the Service at any time and may delete your account through [ACCOUNT DELETION METHOD — in-app setting and/or written request to SUPPORT EMAIL]. Before deleting your account, you should Cash Out any eligible balance. [POLICY DECISION: describe treatment of balances below the minimum Cash Out threshold upon deletion.]

17.2 Suspension and Termination by TapNation

TapNation may suspend or terminate your access to the Service: (a) immediately, in case of a serious or repeated breach of these Terms, fraud, or where required by law; or (b) for any other reason, upon at least [NOTICE PERIOD, e.g., 30 days] prior notice. Except in cases of fraud or Rewards obtained in breach of these Terms, we will give you a reasonable opportunity to Cash Out validly accrued Rewards before or after termination, subject to Section 8.

17.3 Effect of Termination

Upon termination, your license to use the Service ends. Sections that by their nature should survive termination (including Sections 5, 7.3, 7.4, 8.8, 11, and 14 through 20) survive.

18. Changes to These Terms

We may update these Terms from time to time, including to reflect changes to the Service, the Rewards Program, or applicable law. If we make material changes, we will notify you at least [NOTICE PERIOD, e.g., 30 days] before they take effect, through the App and/or by email where available. If you do not agree to the updated Terms, you must stop using the Service before the changes take effect and may Cash Out any eligible balance in accordance with Section 8. Your continued use of the Service after the effective date constitutes acceptance of the updated Terms.

19. Governing Law and Dispute Resolution

These Terms are governed by the laws of [GOVERNING LAW, e.g., France], excluding its conflict-of-law rules. If you are a consumer residing in the European Union, you also benefit from the mandatory consumer protection provisions of the law of your country of residence, and nothing in this Section deprives you of that protection.

Before initiating formal proceedings, please contact us at [SUPPORT EMAIL] so we can try to resolve the issue amicably. If you are a consumer residing in France, you may also refer the dispute free of charge to the consumer mediator designated by TapNation: [NAME AND CONTACT DETAILS OF CONSUMER MEDIATION BODY — mandatory under the French Consumer Code]. Consumers residing in the European Union may also use the European Commission’s Online Dispute Resolution platform at https://ec.europa.eu/consumers/odr.

Subject to any mandatory jurisdiction rules protecting consumers (which may allow you to bring or defend proceedings in the courts of your country of residence), the courts of [VENUE, e.g., Paris, France] shall have jurisdiction over disputes arising out of or in connection with these Terms.

[US-SPECIFIC DISPUTE TERMS — DECISION REQUIRED: if the Service is offered in the United States, decide with US counsel whether to include a US-user arbitration agreement and class action waiver (common for US rewards apps), and if so insert it here as a separate subsection applicable to US residents only.]

20. General Provisions

Entire agreement. These Terms, together with the Privacy Policy and any additional terms expressly referenced, constitute the entire agreement between you and TapNation regarding the Service.
Severability. If any provision of these Terms is held invalid or unenforceable, the remaining provisions remain in full force, and the invalid provision will be replaced by a valid one that most closely reflects its intent.
No waiver. Our failure to enforce any provision is not a waiver of our right to do so later.
Assignment. You may not assign or transfer these Terms. TapNation may assign these Terms to an affiliate or in connection with a merger, acquisition, or sale of assets, subject to applicable law and without reducing your rights under these Terms.
Force majeure. TapNation is not liable for any failure or delay caused by events beyond its reasonable control, including blockchain network failures, acts of authorities, internet or infrastructure outages, and other force majeure events as defined by applicable law.
Language. These Terms are drafted in English. [CONFIRM LEGAL DOCUMENT LANGUAGES AND WHICH VERSION PREVAILS — the App UI ships in EN, ES, PT-BR, FR, and TR (AR conditional); consumer law in some jurisdictions (including France) may require a local-language version of these Terms.]

21. Contact

If you have questions about these Terms or the Service, contact us at:

Email: [SUPPORT EMAIL]
Postal address: [TAP NATION LEGAL ENTITY NAME], [REGISTERED ADDRESS]
[ANY ADDITIONAL MANDATORY DISCLOSURES — e.g., French LCEN publisher information: publication director, hosting provider name and address, share capital, VAT number.]

Play Hub Privacy Policy

Last Updated: [DATE] | Effective Date: [DATE]

1. Who We Are and What This Policy Covers

This Privacy Policy explains how [TAP NATION LEGAL ENTITY NAME AND FORM, e.g., TAP NATION SAS], registered office at [REGISTERED ADDRESS] (“TapNation”, “we”, “us”, or “our”), collects, uses, and shares personal data when you use the Play Hub mobile application (the “App”), the companion web portal at [WEB PORTAL URL] (the “Web Portal”), and related support channels (together, the “Service”).

TapNation is the data controller for the processing described in this Policy. You can contact us about privacy matters at [PRIVACY EMAIL, e.g., privacy@tap-nation.io]. [IF A DATA PROTECTION OFFICER IS APPOINTED: Our Data Protection Officer can be reached at DPO CONTACT.]

TapNation’s individual games (the “Connected Games”) are separate applications covered by their own privacy policies [LINK TO GAMES PRIVACY POLICY]. However, as explained in Section 3.3, the Service receives certain activity data originating from Connected Games in order to operate the rewards program, and that processing is covered by this Policy.

This Policy applies whether you use the Service as a guest or with a registered account.

2. At a Glance

You can use the App without creating an account. A guest profile tied to your device is created automatically.
To calculate your rewards, we receive activity data from Connected Games (such as game sessions, ads viewed, and ad revenue attributable to your gameplay) through our attribution partner.
Your rewards are held in a blockchain-based account created for you when needed. Your public wallet address and reward transactions are recorded on a public blockchain and cannot be deleted (see Section 6).
We use device and network signals (such as emulator, VPN, and device-integrity checks) to prevent fraud, because rewards have real monetary value.
Cashing out requires a registered account and may require identity verification carried out by us and/or our payout partners.
We do not sell your personal data for money. [CONFIRM AND ALIGN WITH SECTION 11 REGARDING AD-RELATED “SHARING” UNDER US STATE LAWS.]

3. Personal Data We Collect

3.1 Data You Provide to Us

Account data: email address; sign-in identifiers when you use Google Sign-In or Apple Sign-In; username; avatar; account creation date.
Referral data: your referral code and link, and the connection between your account and the accounts of users you invite or who invited you.
Communications: messages, requests, and attachments you send to our support channels, and related contact details.

3.2 Data Collected Automatically

Device and technical data: device model and manufacturer, operating system and version, language and region settings, app version, and diagnostic and crash data.
Identifiers: device-scoped identifiers (such as the iOS Identifier for Vendor, IDFV), the mobile advertising identifier (Google Advertising ID / Apple IDFA, subject to your permission settings), our attribution partner’s identifier (Adjust ID), and internal user and account identifiers.
Network data: IP address and approximate location derived from it (country/region level), which we use to determine service availability, applicable law, and compliance with geographic restrictions.
Usage data: your interactions with the App and Web Portal, screens viewed, features used, and advertisements displayed or viewed within the App [IF THE APP SERVES ADS — confirm].
Fraud prevention signals: device integrity and environment signals, including indicators of emulators, virtual devices, rooted or jailbroken devices, VPN or proxy usage, and device fingerprinting signals, together with related activity patterns.

3.3 Activity Data Received from Connected Games

To operate the rewards program, we receive activity data attributable to you from Connected Games through our attribution partner (Adjust). This includes: install and session events for Connected Games; advertising impression events (such as rewarded and interstitial video views); advertising revenue events attributable to your gameplay; and other in-game events used for reward calculation. This data is linked to your Service profile through the identifiers described in Section 3.2.

3.4 Rewards and Transaction Data

Rewards data: your reward balance, milestone progress, leaderboard points and rankings, claims, and reward history.
Blockchain account data: the public wallet address created for you, and records of reward transactions associated with that address (see Section 6).
Cash-out data: cash-out requests, selected payout method, status, and transaction references. [CONFIRM WHAT PAYOUT DATA (e.g., partial bank details, gift card delivery email) IS STORED BY TAPNATION VS. HELD ONLY BY PAYOUT PARTNERS.]

3.5 Data Received from Third Parties

Sign-in providers: basic profile information from Google or Apple when you use their sign-in services, as permitted by your settings with them.
Identity verification and payout partners: confirmation of the outcome of identity verification (e.g., verified / not verified) and payout status. [CONFIRM: full KYC documentation is expected to be collected and held by the relevant partners acting under their own terms; describe the actual data flow once providers are finalized.]
Fraud prevention services: risk signals from third-party anti-fraud providers [LIST, IF ANY].

4. How We Use Personal Data and Our Legal Bases

Under the EU/UK General Data Protection Regulation (“GDPR”), we rely on the following legal bases for the purposes below:

Providing the Service (performance of a contract): creating and operating guest profiles and registered accounts; creating and operating your blockchain-based rewards account; measuring and attributing your activity to calculate rewards; operating milestones, leaderboards, and the referral program; crediting rewards; processing cash-out requests; providing support.
Security and fraud prevention (legitimate interests): detecting and preventing fraud, abuse, multi-accounting, ad fraud, and manipulation of the rewards program; enforcing our Terms of Service; securing the Service. Given that rewards have real monetary value, we have a strong legitimate interest in these measures.
Service availability and compliance (legal obligation / legitimate interests): enforcing geographic restrictions; sanctions screening where applicable; retaining transaction records; responding to lawful requests from authorities; tax and accounting obligations.
Analytics and improvement (legitimate interests / consent where required): understanding how the Service is used, diagnosing problems, and improving features. Where local law requires consent for the storage of or access to information on your device (e.g., ePrivacy rules) or for cross-app tracking (e.g., Apple’s App Tracking Transparency), we rely on your consent.
Communications: service and transactional communications (contract / legitimate interests); marketing and promotional communications, where applicable, only with your consent, which you can withdraw at any time [CONFIRM WHETHER MARKETING COMMUNICATIONS ARE PLANNED FOR V1].

Where we rely on legitimate interests, we have assessed that our interests are not overridden by your rights and freedoms. You can object to processing based on legitimate interests as described in Section 10.

5. Leaderboards and Information Visible to Others

If you participate in the weekly leaderboard, your username, avatar, rank, and points are visible to other users of the Service. Please choose a username and avatar accordingly; do not use your full real name if you do not want it displayed publicly.

6. Blockchain Data: Important Information

The Service uses blockchain infrastructure to hold and transfer rewards. A blockchain-based account (wallet) is created for you when needed, through our infrastructure provider [WALLET INFRASTRUCTURE PROVIDER, e.g., Sequence (Horizon Blockchain Games Inc.)], and reward transactions are recorded on the [Arbitrum] public blockchain [list any additional networks].

Public blockchains are decentralized, publicly accessible, and immutable: once recorded, transactions cannot be modified or deleted by TapNation or anyone else. The on-chain data associated with you consists of your public wallet address and transaction records (amounts, timestamps, and counterpart addresses). We do not record your name, email address, or other directly identifying information on the blockchain.

A public wallet address is pseudonymous, but it may constitute personal data where it can be linked to you. Because on-chain data cannot be erased, your rights to erasure and rectification (Section 10) cannot be applied to data already recorded on a public blockchain. What we can do is delete the off-chain links between your identity and your wallet address held in our systems, subject to legal retention obligations. By using the Service, you acknowledge this characteristic of blockchain technology.

7. How We Share Personal Data

7.1 Service Providers (Processors)

We share personal data with providers that process it on our behalf and under our instructions, including:

Attribution and analytics: Adjust GmbH (mobile measurement and attribution) [ADD ANY OTHER ANALYTICS PROVIDERS];
Wallet infrastructure: [WALLET INFRASTRUCTURE PROVIDER, e.g., Sequence (Horizon Blockchain Games Inc.)] (creation and operation of blockchain-based rewards accounts);
Hosting and backend infrastructure: [CLOUD / HOSTING PROVIDERS];
Customer support and communications tools: [PROVIDERS];
Security and anti-fraud services: [PROVIDERS, IF ANY].

7.2 Advertising Partners

[IF THE APP SERVES ADS:] Where advertisements are displayed within the App, advertising networks and mediation partners [LIST, e.g., AppLovin and participating networks] may process your advertising identifier, IP address, and device data to serve and measure ads, acting as independent controllers or as described in their own policies. Your choices regarding advertising identifiers are described in Section 12.

7.3 Payout and Identity Verification Partners

When you cash out, your data is shared with the payout, gift card, and off-ramp providers involved in executing your request [LIST OF PROVIDERS — current primary candidate: Cryptorefills for gift cards; others TBD], and, where verification is required, with identity verification providers. These partners generally act as independent controllers for the verification and payout services they provide under their own terms and privacy policies.

7.4 TapNation Group and Connected Games

We share data within the TapNation group and between the Service and Connected Games to the extent necessary to operate the rewards ecosystem (for example, mapping your game activity to your Service profile) [CONFIRM GROUP STRUCTURE AND WHETHER ANY GROUP ENTITY OTHER THAN THE CONTROLLER IS INVOLVED].

7.5 Legal and Corporate

We may disclose personal data: to comply with applicable law or a valid legal request; to establish, exercise, or defend legal claims; to enforce our Terms of Service and protect the security of the Service; in connection with a merger, acquisition, restructuring, or sale of assets, subject to appropriate safeguards; and otherwise with your consent.

We do not sell personal data in exchange for money.

8. International Data Transfers

Some of the providers listed above are located outside the European Economic Area, including in the United States. Where personal data is transferred outside the EEA [or the UK, if applicable], we rely on safeguards recognized by applicable law, such as European Commission adequacy decisions (including, where applicable, the EU–US Data Privacy Framework) or the European Commission’s Standard Contractual Clauses, together with supplementary measures where needed. You can request information about the safeguards used, or a copy of them, by contacting [PRIVACY EMAIL].

Please note that data recorded on a public blockchain is, by its nature, replicated on nodes located worldwide (see Section 6).

9. Data Retention

We keep personal data only as long as necessary for the purposes described in this Policy, and then delete or anonymize it. Indicative retention periods:

Account and profile data: for the life of your account, then deleted or anonymized within [PERIOD, e.g., 90 days] of account deletion, except as needed below.
Rewards and cash-out transaction records: [PERIOD, e.g., 5–10 years — set per applicable accounting, tax, and financial record-keeping obligations].
Fraud prevention data: [PERIOD, e.g., up to 2 years, or longer for confirmed fraud cases / ban enforcement — confirm with counsel].
Support communications: [PERIOD, e.g., 3 years after the last interaction].
Attribution and analytics data: as configured with our attribution partner [PERIOD].
On-chain data: public blockchain records are permanent and cannot be deleted (see Section 6).

Inactive guest profiles may be deleted after [PERIOD] of inactivity [ALIGN WITH THE INACTIVITY POLICY IN THE TERMS OF SERVICE].

10. Your Rights (EEA / UK)

If you are in the European Economic Area or the United Kingdom, you have the right to: access your personal data; rectify inaccurate data; request erasure; request restriction of processing; receive your data in a portable format; object to processing based on legitimate interests (including profiling based on those interests); and withdraw consent at any time where processing is based on consent, without affecting prior processing.

To exercise your rights, contact us at [PRIVACY EMAIL]. We may need to verify your identity before responding, and we will respond within one month (extendable by two further months for complex requests, in which case we will inform you).

Please note the blockchain-related limitations described in Section 6: data already recorded on a public blockchain cannot be erased or rectified; in such cases we will implement the measures available to us, such as deleting the off-chain links between your identity and your wallet address, subject to legal retention obligations.

You also have the right to lodge a complaint with a supervisory authority, in particular in the EU member state of your residence or workplace. In France, the supervisory authority is the CNIL (Commission Nationale de l’Informatique et des Libertés, www.cnil.fr).

11. US State Privacy Rights

[INCLUDE THIS SECTION ONLY IF THE SERVICE IS OFFERED IN THE UNITED STATES; TAILOR WITH US COUNSEL.] If you reside in a US state with a comprehensive privacy law (such as California, Colorado, Connecticut, Texas, or Virginia), you may have the right to: know/access the personal information we process about you; delete it; correct it; obtain a portable copy; and opt out of the “sale” or “sharing” of personal information, of targeted advertising, and of certain profiling.

The categories of personal information we collect and the purposes for which we use them are described in Sections 3 and 4. We do not sell personal information for money. [DETERMINE WITH COUNSEL WHETHER THE USE OF ADVERTISING IDENTIFIERS WITH AD NETWORKS OR ATTRIBUTION PARTNERS CONSTITUTES A “SALE” OR “SHARING” UNDER CALIFORNIA LAW; IF SO, PROVIDE A “DO NOT SELL OR SHARE MY PERSONAL INFORMATION” MECHANISM HERE AND IN THE APP/WEB PORTAL.]

To exercise these rights, contact us at [PRIVACY EMAIL] [OR VIA WEB FORM / IN-APP MECHANISM]. You may authorize an agent to submit a request on your behalf. We will not discriminate against you for exercising your rights. If we deny your request, you may appeal by [APPEAL MECHANISM, WHERE REQUIRED BY STATE LAW].

12. Your Advertising and Tracking Choices

iOS: the App will request your permission under Apple’s App Tracking Transparency framework before tracking you across apps for the purposes that require it. You can change this at any time in your device settings (Settings > Privacy & Security > Tracking).
Android: you can reset or delete your advertising identifier and opt out of ads personalization in your device settings (Settings > Google > Ads).
Web Portal cookies: the Web Portal uses cookies and similar technologies [DESCRIBE OR LINK TO A COOKIE NOTICE; IMPLEMENT A CONSENT BANNER FOR NON-ESSENTIAL COOKIES WHERE REQUIRED].

Important: certain identifiers and attribution data are necessary to link your activity in Connected Games to your Service profile and to calculate your rewards. If attribution is unavailable for your device (for example, because of your tracking permission settings), some or all of your activity may not be attributable to your profile, which may limit your ability to receive rewards. [CONFIRM THE EXACT TECHNICAL BEHAVIOR (e.g., use of device-scoped identifiers vs. advertising identifiers) AND ADJUST THIS DISCLOSURE ACCORDINGLY.]

13. Children

The Service is intended for users aged 18 or over and is not directed to children. We do not knowingly collect personal data from anyone under 18 through the Service. If we become aware that we have collected personal data from a person under 18, we will delete the associated account and data. If you believe a minor is using the Service, please contact us at [PRIVACY EMAIL].

14. Security

We implement technical and organizational measures designed to protect personal data, including encryption of data in transit, secure storage of wallet session credentials on your device using platform security features (such as iOS Keychain and Android Keystore), access controls, server-side validation of activity data, and monitoring. No system is completely secure, and we cannot guarantee absolute security; please protect your device and account credentials.

15. Automated Decision-Making

Our anti-fraud systems may automatically flag, restrict, or suspend accounts, or withhold rewards, based on signals indicating fraud or breach of our Terms of Service (for example, emulator use, artificial ad activity, or manipulation of attribution data). Where such a decision produces legal or similarly significant effects for you, you have the right to obtain human review of the decision, to express your point of view, and to contest the decision, by contacting [SUPPORT EMAIL]. [CONFIRM THE INTERNAL REVIEW PROCESS SO THIS COMMITMENT IS OPERATIONALLY ACCURATE.]

16. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will notify you through the App and/or by email where available before the changes take effect, and we will update the “Last Updated” date above. Your continued use of the Service after the effective date constitutes acknowledgment of the updated Policy.

17. Contact Us

Privacy contact: [PRIVACY EMAIL]
Postal address: [TAP NATION LEGAL ENTITY NAME], [REGISTERED ADDRESS]
[IF A DPO IS APPOINTED: Data Protection Officer contact details.]
[IF THE CONTROLLER IS ESTABLISHED OUTSIDE THE EEA OR UK BUT OFFERS THE SERVICE THERE: EU/UK representative details — likely not applicable if the controller is the French entity.]