P A R T I C

Privacy Policy

SUPAC INNOVATION CORP.

This Privacy Policy explains how SUPAC Innovation Corp. collects, uses, discloses, retains and protects personal information when you use the Partic mobile application, related websites, account-deletion page, support channels and other related services (collectively, the "Service").

Effective date: August 25, 2026 Last updated: August 25, 2026 Version: 2.2

This Policy applies to Partic's current closed-loop virtual-coin model. Gold Coins and Silver Coins cannot be redeemed, withdrawn or exchanged for money or anything else of real-world value. Partic does not currently collect bank-account or payout information for Coin redemption.

At the effective date of this Policy, rewarded advertising is not active and Partic does not use an advertising software development kit ("advertising SDK") to collect or transmit advertising identifiers or ad-interaction data. Section 6 explains what will happen before rewarded advertising is enabled.

1. Who We Are

Partic is operated by SUPAC Innovation Corp., a corporation incorporated under the laws of British Columbia, Canada ("SUPAC", "Partic", "we", "us" or "our"). SUPAC is responsible for personal information under its control and has designated a Privacy Officer to answer questions and handle requests or complaints.

This Policy does not replace the privacy policies of third parties such as Google Play, the Apple App Store or external websites. Those parties process information under their own policies when you use their services.

2. Coin and Game Functionality Relevant to This Policy

Gold Coins may be obtained through an eligible app-store purchase, an authorized in-app transfer from another eligible User, an app-funded game prize or a promotional grant from SUPAC. Gold Coins may be used for designated game entry, transferred through the authorized Partic feature, or converted one way into Silver Coins.

Silver Coins may be obtained through a one-way conversion from Gold Coins, an initial or promotional grant, a referral or in-app activity where available, or an app-funded game prize. If rewarded advertising is introduced later, Silver Coins may also be awarded for voluntarily completing an eligible advertisement. Silver Coins cannot be transferred or converted into Gold Coins.

A game may be free or may require a disclosed amount of Gold Coins or Silver Coins. Entry Coins are deducted and consumed by Partic; they are not pooled for participants or transferred from losing Users to a winner. Any Coin prize is funded and issued by SUPAC under the Official Game Rules presented before entry.

Gold Coins and Silver Coins are closed-loop in-app credits. Neither type can be redeemed, withdrawn, sold or exchanged for money, cryptocurrency, gift cards, goods, services or another item of real-world value.

3. Information We Collect

The information collected depends on the features you use. We do not necessarily collect every item below from every User.

3.1 Account, identity and profile information

  • Email address, internal User identifier, password hash or third-party sign-in identifier, authentication status and Account status.
  • Display name, avatar or profile image, biography and other profile details you choose to provide.
  • Age-confirmation status and, where reasonably required for eligibility, legal compliance or feature availability, country or region information.
  • Account creation and sign-in dates, suspension or restriction status, deletion-request status and records used to verify Account ownership.

3.2 Game, room and User Content information

  • Games and rooms you create, join or are invited to; room codes; player lists; teams; matchmaking information; game settings; and the applicable rule version.
  • Entry currency and amount, entry status, start and completion times, game actions, answers, votes, eliminations, scores, ranks, badges, disconnects, results and prize information.
  • Display names, avatars or profile images, biographies, room names, game answers and other content you submit through supported Service fields, together with submission and moderation metadata.
  • Reports, blocks, moderation decisions, appeals and information reasonably needed to investigate cheating, harassment, collusion or other prohibited conduct.

3.3 Coin, purchase and transaction information

  • Gold Coin and Silver Coin balances, ledger entries and balance adjustments.
  • App-store transaction or order identifier, product identifier, amount, currency, purchase date, status, and refund or chargeback information supplied by the applicable Platform.
  • Gold-to-Silver conversion amount, rate, date and status.
  • Authorized Gold Coin transfer sender and recipient identifiers, amount, date, status, disclosed limit or fee, reversal or hold status and fraud-review information.
  • Game-entry deductions, app-funded prize awards, initial or promotional grants, referral rewards and related corrections or reversals.

Android purchases are processed through Google Play Billing. If Partic is offered on iOS, purchases in that version are processed through Apple's In-App Purchase system. The applicable Platform processes full payment-card or payment-instrument details under its own privacy policy. Partic receives transaction confirmation and status information but does not receive or store full payment-card numbers or card security codes.

3.4 Referral and promotional information

If you participate in a referral or promotional program offered by Partic, we may collect the referral or promotion code, referring and referred User identifiers, qualification event and status, reward amount and date, campaign limits, and device or Account indicators used to prevent self-referrals, duplicate rewards and abuse.

3.5 Technical, analytics and security information

  • IP address, request time, device model, operating system, app version, language, browser information for related web pages, app-install or device identifiers, push-notification token and network information.
  • Crash, performance and diagnostic information, API activity, authentication events, security logs and records of feature interaction needed to operate, debug, measure and protect the Service.
  • Signals used to identify bots, modified clients, emulators, unauthorized multiple Accounts, suspicious transfers, collusion, chargeback abuse, manipulated rewards and other prohibited activity.

For the current functions described in this Policy, Partic does not intentionally collect precise GPS location, contact lists, biometric identifiers, government identity documents, bank-account information or payout credentials. If a future feature requires a materially different category of information, we will update this Policy and provide any required notice or consent before collection.

3.6 Support and privacy requests

We collect messages, attachments and other information you provide when contacting support, submitting a report or appeal, disputing a purchase or Coin transaction, reporting unauthorized access, making a privacy request or requesting Account deletion. We may link that information to relevant Account, game, User Content, transfer or security records when needed to respond.

3.7 Profile images and device permissions

When you choose a profile image or attachment, your device may present a system photo picker or permission prompt. Partic receives the file you select and related technical metadata needed to upload it. We do not intentionally access media you did not select. Device permissions can be reviewed or withdrawn through your operating-system settings, although the related feature may then stop working.

3.8 Information from other sources

We may receive transaction confirmation from Google Play or Apple; sign-in confirmation from an authentication provider you choose; technical information from service providers acting for us; and limited information from another User who invites you, identifies you as an authorized Gold Coin transfer recipient, uses your referral code or reports content or conduct involving you.

4. How We Use Information

  • Create, authenticate, maintain and protect Accounts.
  • Provide game rooms, invitations, matchmaking, scoring, profiles, badges and game history.
  • Maintain accurate Coin balances and process purchases, conversions, authorized transfers, entry deductions, rewards, prizes, refunds, chargebacks and corrections.
  • Administer referrals, promotions and other rewards where those features are available.
  • Display information to other Users as needed for the game, room, profile or transfer feature you use.
  • Detect, investigate and prevent fraud, cheating, collusion, harassment, unauthorized access, real-world Coin trading, multiple-Account abuse and other security or integrity risks.
  • Moderate User Content, operate reporting and blocking tools, respond to appeals and protect Users.
  • Provide support and respond to privacy, correction and Account-deletion requests.
  • Diagnose failures, analyze aggregate Service performance and improve reliability, accessibility, security and feature design.
  • Comply with legal, tax, accounting, consumer-protection, Platform and regulatory obligations, and establish or defend legal claims.

Automated rules may flag or temporarily hold a purchase, transfer, reward, prize or Account when technical or fraud signals indicate a risk. You may contact play@supac.ca to request human review of an enforcement action. We do not use solely automated processing to make a decision that produces legal or similarly significant effects unless permitted by law and subject to required safeguards.

Where a legal basis is required, we rely as applicable on consent, performance of our agreement with you, compliance with law, and legitimate interests such as Service security, fraud prevention, moderation, support and improvement, provided those interests are not overridden by your rights. You may withdraw consent for optional processing, subject to legal and operational limits.

5. How We Disclose Information

We do not sell or rent personal information. At the effective date, we do not disclose personal information for cross-context behavioural advertising and we do not use an advertising network.

  • Other Users: Depending on the feature, other participants may see your display name, avatar or profile image, room participation, team, game actions, answers, votes, scores, results, User Content visible in that feature and relevant status information.
  • Gold Coin transfer counterparties: The sender and recipient may see the other party's display name or User identifier, transfer amount, date and status. We do not show the other party's email address, purchase history, payment information or full balance unless that person independently chose to share it.
  • App stores and payment Platforms: Google Play or Apple processes the purchase and may receive or provide transaction, product, device, refund and fraud-prevention information needed to complete and administer it.
  • Service providers: Providers of hosting and database infrastructure, authentication, security, content delivery, analytics and crash diagnostics, push notifications, email, customer support, moderation and other technical functions may process information on our behalf only for the services they provide and subject to appropriate contractual, confidentiality and security restrictions.
  • Legal, safety and integrity purposes: We may disclose information where required or authorized by law, legal process or regulatory request, or where reasonably necessary to protect Users, investigate fraud or abuse, enforce our rights, or address a threat to safety or Service integrity.
  • Corporate transactions: Information may be disclosed to professional advisers and transferred as part of a proposed or completed financing, merger, acquisition, reorganization, insolvency or sale of all or part of the business, subject to applicable confidentiality and privacy safeguards.

Current advertising providers: None. You may contact the Privacy Officer for current information about the categories of service providers involved in processing and, where applicable law requires, the organizations to which your personal information has been disclosed. Google and Apple maintain their own privacy notices at the links below.

6. Rewarded Ads, Referrals, Promotions and Game Prizes

Rewarded advertising is not active in the current version of Partic, and Partic does not currently disclose personal information to an advertising network.

Before rewarded advertising is enabled, we will update this Policy and the applicable Platform privacy disclosures to identify the advertising provider, link to its privacy notice, describe the information it processes and the purposes, explain whether tracking or personalized advertising is used, and describe available consent and opt-out controls. Where required, we will obtain consent before an advertising identifier is accessed or information is disclosed.

If rewarded advertising is introduced, viewing an advertisement will be voluntary. Partic will display the Silver Coin reward and material limit before you choose to participate. Declining an advertisement will not by itself restrict or penalize your Account, although an individual game or feature may still require Coins as disclosed before access.

If a referral or promotional program is offered, the qualifying action, reward amount, campaign period and material Account, device, person or geographic limits will be shown in the applicable program rules. Self-referrals, fictitious or duplicate Accounts and coordinated abuse are prohibited.

Coins obtained from referrals, promotions, activities, transfers, purchases, conversions or app-funded game prizes remain closed-loop in-app credits and cannot be converted into anything of real-world value.

7. Data Security

We use administrative, technical and organizational safeguards that are reasonable in light of the sensitivity and volume of information, foreseeable risks and available technology. Depending on the system, safeguards include authenticated access, encryption in transit, password hashing or secure third-party authentication, role-based or need-to-know access controls, logging, backup controls, service-provider restrictions and incident-response procedures.

No electronic transmission or storage system is completely secure. You are responsible for using a strong and unique password, protecting your device and credentials, confirming the intended recipient before an authorized Gold Coin transfer, and notifying us promptly at play@supac.ca if you suspect unauthorized activity.

8. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy and as permitted or required by law. The period for a particular record depends on the nature and sensitivity of the information, why it was collected, whether the Account or related feature remains active, the risk of harm from unauthorized use or disclosure, applicable legal and Platform obligations, and whether the information can be deleted or anonymized without impairing another User's legitimate record.

  • Account and profile information is generally kept while the Account is active and then for the time reasonably needed to verify and complete deletion, secure the Service and address an unresolved matter.
  • Game, room and shared-result records are kept while needed to provide histories, preserve other participants' records, resolve disputes, investigate cheating or abuse, and maintain Service integrity. Records may be anonymized when continued identification is unnecessary.
  • Coin ledgers, purchases, conversions, entry deductions, prizes, transfers, refunds and chargebacks are kept for the periods required or reasonably necessary for transaction integrity, tax and accounting obligations, Platform reconciliation, fraud prevention, legal claims and regulatory requirements.
  • User Content is kept while needed to deliver the relevant feature. Reported or restricted User Content and related metadata may be kept longer while a moderation, safety, legal or repeat-abuse issue remains relevant.
  • Referral, promotional and reward records are kept while needed to administer the program, apply limits, prevent duplicate rewards and investigate abuse.
  • Support, privacy, complaint and appeal records are kept while the request is open and afterward for the time reasonably needed to document the response, resolve a dispute, meet legal obligations or prevent repeated abuse.
  • Routine technical, authentication, diagnostic and security logs are kept for the operational or security period for which they are useful. Particular logs may be preserved longer for an investigation, legal claim or security incident.
  • Deleted information may remain in encrypted or access-restricted backups until overwritten through the ordinary backup cycle. Backups are not used for ordinary business purposes after a valid deletion request is completed.

If we use personal information to make a decision that directly affects you, we will retain the information used for at least one year after the decision, as required by British Columbia's Personal Information Protection Act, unless a longer period is required or permitted. On request, we will tell you the retention period or criteria that apply to a particular category of your information.

9. Account Deletion and Privacy Rights

9.1 Account deletion

You may request deletion of your Partic Account and associated personal information through any of the following paths:

Deleting the app from your device does not delete the Account. We may take reasonable steps to verify identity and Account ownership. We aim to complete an eligible verified deletion request within 30 days unless additional time or retention is required for a reason described in this Policy or by law; if so, we will explain the reason where legally permitted.

When an Account is deleted:

  • Personal Account and profile information is deleted or anonymized and active authentication tokens are revoked, subject to required retention.
  • Remaining Gold Coins and Silver Coins are cancelled and cannot be used, transferred or restored. Deletion does not create a right to a cash payment or Coin redemption. Any refund required by law or granted under Platform rules is handled only as a reversal of an eligible original purchase to the original purchaser.
  • Pending authorized Gold Coin transfers are cancelled where technically and legally possible. Completed purchases, transfers, game results and prizes are not reversed solely because an Account is deleted.
  • Shared game, User Content, transfer and match records may be retained in anonymized or limited form where necessary to preserve another User's record, investigate misconduct, resolve a dispute or comply with law.
  • Purchase, refund, chargeback, Coin-ledger, transfer, tax, accounting, fraud-prevention, moderation, security and legal records may be retained under Section 8 and restricted from unrelated use.

9.2 Access, correction and other rights

Subject to applicable law and reasonable identity verification, you may ask us to confirm whether we hold personal information about you, provide access to that information and an account of its use or disclosure, correct inaccurate information, withdraw consent for optional processing, request deletion, or exercise other rights such as objection, restriction or portability where available. You may also ask for human review of an automated flag or enforcement action.

We will not discriminate against you for making a privacy request. Some requests may be limited where disclosure would reveal another person's information, interfere with an investigation, violate privilege or law, or where retention is required. We will explain a refusal or limitation where legally permitted.

Send requests or complaints to play@supac.ca. If you are not satisfied with our response, you may contact the Office of the Information and Privacy Commissioner for British Columbia or another privacy authority available where you live.

OIPC British Columbia: https://www.oipc.bc.ca/

10. Children and Age Requirements

Partic is intended only for people who are at least 18 years old, or the age of majority where they live if that age is higher. The Service is not directed to children, and we do not knowingly allow an under-age person to create an Account or use purchase, transfer or prize functions.

If we learn that an under-age person has provided personal information, we will investigate and restrict or delete the Account and information as required. A parent, guardian or other person may report a concern to play@supac.ca.

11. International Processing

SUPAC operates from British Columbia, Canada. Depending on the service-provider configuration, personal information may be processed or stored in Canada, the United States or other countries in which a provider or its subprocessors operate. Information processed outside your province or country may be subject to the laws and lawful-access requirements of that jurisdiction.

We require service providers to use information only for authorized purposes and to apply safeguards appropriate to its sensitivity. Where applicable law requires a cross-border transfer mechanism, we use contractual protections or another legally recognized safeguard. You may contact the Privacy Officer for available current information about material processing locations and safeguards.

12. Changes to This Policy

We may update this Policy when the Service, Coin functionality, games, providers, laws or data practices change. We will post the updated Policy, change the effective date and provide notice in the app, by email or through another reasonable method when a change materially affects how personal information is collected, used or disclosed. Where consent is required for a new purpose, we will obtain it before the new processing begins.

13. Contact

End of Privacy Policy