PlayGM Privacy Policy
This is the privacy policy for PlayGM, a sports-management game for children. PlayGM is operated by PlayGM Inc, a Delaware corporation. If you are a parent reading this to decide whether your child should use PlayGM, the sections you most need are What we collect from your child, Your rights as a parent, and How to reach us. There is also a shorter version written for kids at {{PLACEHOLDER: URL of kid summary}}.
PlayGM is available only in the United States and is designed for children, including children under 13. We know that means children's privacy law applies to us — the Children's Online Privacy Protection Act, or COPPA, plus several state laws. This policy explains what we do and gives parents the specific rights those laws require.
1. Who we are
- Legal name: PlayGM Inc
- Contact: Stefan Martinovic
- Mailing address: PO Box 95, Armonk, New York 10504
- Phone: 914-294-5209
- Email: stefan@playgm.app
Box number confirmed by the owner on 12 September 2026: PO Box 95. Counsel still to confirm that a PO Box satisfies the 16 CFR 312.4(c)(1)(i) postal-address requirement.
2. What PlayGM is
PlayGM is a sports-management game. Players build rosters, run drafts, compete in head-to-head matchups, answer sports trivia, and ask an in-game assistant called Ask Scout questions about players, stats, and gameplay. Ask Scout only answers questions related to the game and to sports. It is a computer helper, not a person. It cannot discuss anything else.
PlayGM does not use real athletes' names, photos, likenesses, uniforms, team logos, or league marks. Player cards use generic monograms and a fixed 32-color palette that we do not associate with any real team.
There are no cash in-app purchases in PlayGM. There is no advertising in PlayGM. We do not use third-party advertising, analytics, attribution, or tracking software of any kind.
3. What we collect from your child
We collect only what we need to run the game.
| What we collect | Why we collect it | Where it goes |
|---|---|---|
| Display name (chosen with your approval) | Identifies the child in the app | Our database |
| Age track (a broad age band, not a birthdate) | Serves age-appropriate content | Our database |
| Gameplay records: drafts, rosters, scores, trivia answers | Runs the game | Our database |
| Questions typed to Ask Scout | Answered by the assistant, then discarded | Not stored — see § 4 |
| Card-scanner images (physical trading cards) | Recognizes the card | On-device only — see § 5 |
We do not collect: your child's real name, birthdate (only an age band), address, phone number, photograph (other than card scans, which never leave the device), voice recording, precise location, biometric identifier, contact list, or any advertising identifier.
We do not permit your child to type anything into PlayGM that would be seen by another player. Social interaction is limited to canned emoji and pre-written phrases we supply.
4. Ask Scout — what happens with what your child types
When your child asks Ask Scout a question, the question is sent to Google's Vertex AI service, which is our processor under a written data-processing agreement. Google returns an answer. We do not save the question your child typed. We keep only content-free records — the category of the question, the category of the response, timing, and whether our safety filters had to refuse — so we can prove our safety controls are working. We do not save Google's answer either, except in that content-free form.
We have configured Vertex AI so that Google does not retain, review, log, or train on the questions your child sends. This configuration is on file with Google as a written commitment, dated {{PLACEHOLDER: date of Google's abuse-monitoring exception approval}}.
Ask Scout will refuse any question that is not about the game or about sports. It cannot discuss mental health, self-harm, sexual content, or violence. If a child sends a message suggesting they may be in danger, Ask Scout will show crisis resources and we will notify the parent account.
5. The card scanner
PlayGM can scan a physical trading card and recognize it. The camera image and everything derived from it are processed entirely on your child's device. No image, video frame, or feature vector leaves the device. We collect no biometric identifier from any card scan. The device sends us only the identifier of the recognized card.
6. What we collect from the parent
At account creation and to maintain the account, we collect:
| What | Why |
|---|---|
| Your email address | Verifiable parental consent, account communications, rights requests |
| Payment information | To bill your subscription — processed by our payment provider, not stored by us |
| Answers you give during consent | To prove we obtained consent |
We use a household PIN so a parent can hand the device to a child without handing over the parent surface. The PIN is an access control. It is not proof of your identity and it does not substitute for consent — see § 12.
7. How we collect it
- From the child, directly — display name, age band, gameplay actions, trivia answers, questions to Ask Scout.
- From the parent, directly — email, payment information, consent responses.
- From the device automatically — a session token and diagnostic information necessary to make the app work.
- From no one else. We do not purchase or receive personal information about your child or you from any data broker or third-party source.
8. Who we share it with
We share your child's personal information only with service providers who are contractually bound to use it solely to provide services to us. These are our only recipients:
| Recipient | What they do | Data they receive |
|---|---|---|
| Supabase | Our database and authentication | All stored account and gameplay data |
| Vercel | Website and background jobs | Request logs, non-content operational data |
| Google Cloud (Vertex AI) | Runs Ask Scout | Your child's questions, in real time, not stored — see § 4 |
| Resend | Sends parent-facing email | Parent email addresses only |
| {{PLACEHOLDER: payment processor name — Stripe?}} | Bills your subscription | Parent payment information |
| {{PLACEHOLDER: Expo/EAS classification — in scope or out?}} | Delivers app updates | Build metadata; no child personal information |
Each is bound by a written contract requiring confidentiality, use restricted to our instructions, security controls, and deletion on our request. We maintain a current list of these providers and can share the specific contract terms with a parent on request.
We do not sell your child's personal information. We do not share it for targeted advertising. We do not use it to train any advertising model. Google does not use it to train any general-purpose model.
We may disclose personal information if compelled by law (subpoena, court order, valid preservation letter under 18 U.S.C. § 2703(f)) or where we have a good-faith reason to believe disclosure is necessary to prevent imminent physical harm to a child. If we ever receive a request to disclose your child's information for reasons other than these, we will not comply without your consent.
We would need your consent before adding any recipient outside the list above who is not solely providing services to us.
9. Your rights as a parent
You have the following rights over your child's personal information:
- Review what we have collected from your child.
- Delete what we have collected from your child.
- Refuse to allow us to collect more while keeping the account.
- Correct anything we have that is wrong.
- Consent to collection without consenting to disclosure to any recipient that is not integral to providing the service.
- Appeal any decision we make on any of the above.
We respond to every request. Details of turnaround and how to submit are in § 10.
You can exercise any of these rights by:
- Emailing stefan@playgm.app from any address (we will send the verification challenge to the address of record).
- Using the in-app parent surface under Settings → Privacy Requests.
- Using the web form at {{PLACEHOLDER: URL of web request form}}.
You do not need to create or log in to an account to submit a request.
10. How long we take, and how we handle it
We acknowledge every request within 5 business days.
We respond fully to review, correction, and refusal-of-collection requests within 30 days, and to deletion requests by starting an irreversible purge within 30 days. We may extend once by 45 days for genuinely complex requests, with written notice of the reason inside the initial period.
Before we act on a deletion, correction, or export request, we verify that the requester is the parent. Our verification standard is:
- Review, correction, refusal of collection: verified parent account session plus the household PIN.
- Suspend: verified parent account session only (this is reversible and protective).
- Delete: verified parent account session plus a fresh single-use code we email to the parent address on record. A 14-day recovery window follows before the purge becomes irreversible. Your child's access is suspended immediately when we verify a deletion request.
If we cannot verify a request, we will tell you and offer another verification path. If we deny a request, we will tell you in writing with the reason and tell you how to appeal.
For the technical steps and timing between when we start a purge and when the last trace is gone, see the Data Retention Policy at {{PLACEHOLDER: URL of retention policy}}.
11. Households with more than one adult
Any adult verified on the household may submit a review, correction, refusal of collection, or suspend request on their own.
A delete request has an extra safeguard because deletion is irreversible. It requires the adult who originally gave consent, or a second verified adult plus notice to the adult of record and expiry of the recovery window. If two verified adults on the household give us conflicting instructions on a delete request, we will hold the request and ask you to resolve the disagreement before we act. If a court order tells us how to proceed, we will follow it.
We notify every verified adult on the household when a delete or suspend request is submitted and when it completes.
If you delete the household account, every child record in the household is deleted with it. This is the most destructive action in PlayGM and we confirm it more than once.
12. If your child asks to stop
Your child can pause their own play at any time. Pausing does not delete anything and does not, on its own, notify you. If a pause continues for more than 30 days, we let you know the account has gone dormant.
Your child cannot delete their own account, cannot export their own data, and cannot change what we collect. Only a verified parent can do those things. This is deliberate: we want to make sure a decision that big is made by an adult.
If your child ever types something to Ask Scout that suggests they may be in danger, we do notify you. This is separate from a pause request.
13. What we keep and for how long
Full details are in the Data Retention Policy at {{PLACEHOLDER: URL of retention policy}}. Short version:
| What | How long |
|---|---|
| Gameplay records | While the account is active, plus 24 months of inactivity |
| Ask Scout content | Not stored |
| Parent contact information | While the account is active, plus 30 days |
| Consent evidence | 5 years, in minimized form (see § 14) |
| Audit and security logs | 12 months |
| Abandoned or incomplete consent records | Purged after 14 days |
| Export files we generate for you | 7 days from creation |
We do not retain your child's personal information indefinitely and we do not retain it for any purpose other than the ones stated in this policy.
14. How we protect consent evidence
We keep proof of your consent for 5 years so we can show it if a regulator asks. To keep that proof small, we store only what we need: the version of the direct notice you saw, the method by which you consented, timestamps of each step, the disclosure-consent split you chose, and a cryptographic hash of your email address — not your email itself. We do not store your child's name in the consent record. This is the shortest, smallest record that still lets us prove consent existed.
15. Security
We maintain a written information security program. In summary:
- Data in transit is encrypted with TLS.
- Data at rest in our database is encrypted.
- Administrative access requires multi-factor authentication and follows least privilege.
- Our release pipeline enforces the zero-third-party-SDK posture in automated checks; a build fails if any prohibited SDK or unexpected external destination is introduced.
- We rehearse deletion end-to-end, including restoration from backup with re-deletion.
- We limit what we collect and retain because the safest data is data we never held.
No system is perfectly secure. If we discover a breach of your or your child's personal information, we will notify you.
16. Backups
We keep operational backups so we can recover from a failure. When you ask us to delete your child's data, we purge production immediately after the recovery window, and backups age out on their normal rotation of {{PLACEHOLDER: number}} days. If we ever restore from a backup, we re-delete records that had been previously deleted, using a persistent deletion log. Restored backups do not resurrect deleted records.
Counsel review: treatment of backups in a deletion obligation is unrebutted rather than blessed by the FTC. The published re-deletion commitment above is the industry-best practice. Counsel to confirm it is the correct posture before publication.
17. Government and legal requests
We may be required by law to preserve or produce information — for example, a subpoena, a court order, a preservation letter under 18 U.S.C. § 2703(f), or a report we are legally required to make to the National Center for Missing and Exploited Children under 18 U.S.C. § 2258A. If we are required to preserve information you have asked us to delete, we will tell you the request is on hold and give you a general reason, unless a court order or statute prevents us from telling you. In those cases the request stays on hold and we route it to counsel for individual review.
18. Changes to this policy
If we make a change that expands what we collect from your child, what we do with it, or who we share it with, we will get your renewed consent before applying the change to your child. Other changes we will post here, update the "last updated" date, and describe on the parent surface. Prior versions of this policy remain available at {{PLACEHOLDER: URL of policy archive}}, and each record we hold is tagged with the policy version in effect when it was collected.
19. How to reach us
For any privacy question or to exercise any right in § 9:
- Email: stefan@playgm.app
- Mail: PlayGM Inc, Attn: Stefan Martinovic, PO Box 95, Armonk, NY 10504
- Phone: 914-294-5209
- In app: Settings → Privacy Requests
- Web: {{PLACEHOLDER: URL of web request form}}
Please give us a working reply email or address; we cannot answer a request we cannot reach.
20. Interpretation
Where this policy and a required disclosure under COPPA differ, COPPA controls. Where a state law we are subject to gives you a greater right, that state's law controls for you.
Placeholders in this document
- Effective date and last-updated date (§ header, § 18)
- URL of the kid-readable summary (§ intro)
- Counsel confirmation that a PO Box satisfies the postal-address requirement (§ 1, § 19; box number supplied by the owner 12 September 2026)
- Google abuse-monitoring exception approval date (§ 4)
- Payment processor name (§ 8)
- Expo/EAS scope determination (§ 8)
- URL of the web request form (§ 9, § 19)
- URL of the retention policy (§ 10, § 13)
- Backup rotation duration in days (§ 16)
- URL of the policy archive (§ 18)