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Privacy Policy

Last updated: 23 April 2026

1. Introduction

This Privacy Policy explains how HoHoGuess ("Platform", "we", "our", or "us") collects, uses, stores, and protects your personal data when you use the HoHoGuess platform at hohoguess.com and its associated services. We are committed to protecting your personal data in accordance with applicable data protection laws and regulations. By using the Platform, you acknowledge that you have read and understood this Privacy Policy. Please read it carefully before using our services.

2. Data We Collect

We collect the following categories of personal data: (a) Registration data — when you create an account, we collect your email address, chosen username, display name, and avatar image if you upload one. (b) OAuth data — if you sign in via Google, we receive your Google account email address and profile name as provided by Google. We do not receive your Google password. (c) Profile data — optional information you choose to add, including a bio, preferred language setting, and avatar URL. (d) Usage data — records of your guessing activity, Peanuts and Popcorn wallet balances, transaction ledger entries, leaderboard scores, referral information, and daily login activity. (e) Technical and device data — IP address, browser type and version, operating system, and session cookies necessary for authentication and platform security. (f) Payment data — when you purchase Popcorn using HKD, our third-party payment processor Xsolla collects and processes your payment card or payment method details directly. We never see, store, or handle your card number, CVV, or other sensitive payment credentials. We receive from Xsolla only a transaction confirmation and the Popcorn amount to credit to your account.

3. How We Use Your Data

We use your personal data for the following purposes: (a) Account operation — to create and maintain your account, authenticate your identity, and enable access to Platform features. (b) Platform features — to facilitate guessing activity, manage your Peanuts and Popcorn balances, process transactions in our virtual economy, and operate leaderboards and gamification systems. (c) Customer support — to respond to your enquiries, process account-related requests, and resolve disputes. (d) Legal compliance — to meet obligations under applicable laws and regulations, and to respond to lawful requests from authorities. (e) Fraud prevention and security — to detect and prevent abusive behaviour, multi-accounting, and technical attacks on the Platform. (f) Service improvement — to analyse aggregated, anonymised usage patterns in order to improve platform features and user experience. We do not use your personal data for automated decision-making that produces legal or similarly significant effects.

4. Legal Basis for Processing

We process your personal data on the following bases: (a) Contractual necessity — processing required to deliver the services you have requested under our Terms of Service, including account creation, guessing activity, and virtual currency management. (b) Legitimate interests — processing necessary for fraud prevention, platform security, abuse detection, and internal analytics, where our interests are not overridden by your rights. (c) Legal obligation — processing required to comply with applicable laws or respond to lawful authority requests. (d) Consent — where we send optional marketing communications, we do so only with your consent, which you may withdraw at any time by contacting us at support@hohoguess.com.

5. Data Sharing and Third Parties

We share your personal data only with the following third parties and only to the extent necessary: (a) Supabase — our cloud infrastructure provider, which hosts our database and authentication system. Supabase processes your data on our behalf as a data processor under appropriate data processing terms. (b) Xsolla — our third-party payment processor for Popcorn top-ups. Xsolla independently collects and processes your payment information. Xsolla's processing is governed by Xsolla's own privacy policy. We share with Xsolla only your user account identifier and the Popcorn amount to be credited. (c) Google — if you use Google OAuth sign-in, Google processes your authentication as described in Google's own privacy policy. We receive only the data Google provides in the OAuth response. We do not sell, rent, or trade your personal data to any third party for commercial purposes. We do not share your data with advertisers.

6. Data Retention

We retain your personal data for as long as your account remains active. If you request deletion of your account, we will delete or anonymise your personal data within a reasonable period, subject to the following exceptions: (a) We may retain certain data where required by law, for example transaction records that must be kept for audit or compliance purposes. (b) Aggregated, anonymised statistical data from which you cannot be identified may be retained indefinitely for analytical purposes. To request account deletion, please contact us at support@hohoguess.com.

7. Your Rights

Under applicable data protection laws, you have the following rights in respect of your personal data: (a) Right of access — you may request a copy of the personal data we hold about you. We will respond within a reasonable period as required by law. A reasonable access fee may be charged. (b) Right of correction — if you believe data we hold about you is inaccurate, you may request correction. We will correct verifiable inaccuracies within a reasonable period. (c) Opt-out of direct marketing — if we ever use your data for direct marketing, you have the absolute right to require us to stop, free of charge, by notifying us in writing. To exercise any of these rights, please contact us at support@hohoguess.com. We will verify your identity before processing any access or correction request.

8. Cookies and Tracking

We use cookies and similar technologies for the following purposes: (a) Session cookies — strictly necessary cookies that authenticate your login session and maintain your account state. These cannot be disabled without preventing you from using the Platform. (b) Preference cookies — used to remember your language setting and other platform preferences. (c) Analytics — we may use privacy-respecting analytics to understand aggregate usage patterns. We do not use cross-site tracking or behavioural advertising cookies. You can manage or disable non-essential cookies in your browser settings, though doing so may affect Platform functionality.

9. Data Security

We take reasonable technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. These measures include: encryption of all data in transit using HTTPS/TLS; use of Supabase's security infrastructure including row-level security policies on our database; strict access controls limiting internal access to personal data to authorised personnel only; and regular security reviews. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If you believe your account has been compromised, please contact us immediately at support@hohoguess.com.

10. Users Under 18

The Platform is intended for users aged 18 and over. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that a user is under 18, we will promptly suspend the account and delete or anonymise their personal data. If you believe a user under 18 has registered on the Platform, please notify us at support@hohoguess.com.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices or applicable law. When we make material changes, we will update the "Last updated" date at the top of this page and, where appropriate, notify you via the Platform or by email. Your continued use of the Platform after the effective date of any revised Privacy Policy constitutes your acknowledgement of the changes. We encourage you to review this Policy periodically.

12. Contact and Complaints

If you have any questions about this Privacy Policy, wish to exercise your data protection rights, or have a complaint about how we handle your personal data, please contact us at: support@hohoguess.com. If you are not satisfied with our response, you have the right to lodge a complaint with the competent data protection authority.