Effective date: 2025-12-19
App name: Xplay
Website: https://xplay.mn
Company / Data Controller: Filmx Play LLC, Mongolia
Contact: info@xplay.mn, +976-77776002
This Privacy Policy explains how Xplay (“we”, “us”) collects, uses, shares, and protects your personal data when you use the Xplay mobile application and related services (the “Service”).
By using the Service, you agree to the practices described in this Privacy Policy.
Depending on features you use, we may collect:
Account information: phone number, email address, username, password (encrypted/hashed), profile info (optional).
Customer support: messages you send us, attachments you provide, and contact details needed to help you.
Subscription information you provide: plan selection, purchase confirmations, and invoices/receipts (if applicable).
We do not store your full bank card details. Payments are processed by app stores or payment providers.
1.2 Data collected automatically
When you use the app, we may collect:
Device and app information: device model, operating system version, app version, language, time zone, unique device/app identifiers (where available), and basic device settings.
Log and usage data: IP address (approximate), timestamps, pages/screens viewed, features used, playback events (e.g., play/pause), error logs, and performance metrics.
Crash diagnostics: crash reports and technical data to fix issues and improve stability.
1.3 Content and viewing data
To deliver video playback and recommendations, we may process:
Watch history and interaction data: titles viewed, progress, search queries, favorites/watchlist, and interactions.
1.4 Optional permissions
If you enable these features, we may access:
Camera / Photos / Storage: only to upload a profile image or similar user-initiated actions.
Notifications: to send service updates, subscription reminders, or important account notices.
We do not collect precise GPS location unless explicitly stated in the app and enabled by you.
We use your data to:
Provide and operate the Service (account creation, login, playback, customer support).
Process subscriptions and provide access to paid content (if applicable).
Personalize content (e.g., continue watching, recommendations).
Maintain security, prevent fraud, and protect users and the Service.
Improve app performance, fix bugs, and develop new features.
Send important notices (service changes, security alerts, policy updates).
Comply with legal obligations and enforce our terms.
We process data based on one or more of the following:
Contract performance: to provide the Service you request.
Consent: for optional features like marketing notifications (where required) or certain permissions.
Legitimate interests: to secure the Service, prevent fraud, and improve performance.
Legal obligation: where laws require retention or disclosure.
We do not sell your personal data.
We may share limited data only with:
Service providers who help us operate the Service (e.g., hosting, CDN/video delivery, analytics, crash reporting, customer support tools). They can only use data under our instructions.
Payment providers / app stores (e.g., Apple App Store, Google Play, Huawei AppGallery) to process purchases and manage subscriptions.
Legal authorities if required by law, court order, or to protect rights and safety.
Third-party SDKs (example – edit this list):
Analytics: [e.g., Huawei Analytics / Firebase / other]
Crash reporting: [e.g., Huawei Crash / Sentry]
Push notifications: [e.g., Huawei Push Kit / Firebase Cloud Messaging]
Video/CDN: [e.g., BunnyCDN / Cloudflare / other]
If you do not use any of the above, remove them.
Your data may be processed on servers located in Mongolia and/or other countries where we or our service providers operate (for example, cloud hosting or CDN regions). We take reasonable steps to protect data during transfers using contractual and technical safeguards.
We keep personal data only as long as necessary for the purposes described:
Account data: kept while your account is active and for a reasonable period after deletion request as required for security, dispute handling, or legal compliance.
Logs and analytics: typically retained for [e.g., 30–180] days (or aggregated/anonymized sooner).
Payment and transaction records: retained as required by applicable tax/accounting laws.
You can request deletion (see Section 9).
We use reasonable administrative, technical, and physical safeguards to protect your data, such as:
Encryption in transit (HTTPS/TLS)
Access controls and least-privilege permissions
Monitoring and logging for security events
No system is 100% secure, but we work to protect your information.
Xplay is not intended for children under [13/16] (choose one). We do not knowingly collect personal data from children. If you believe a child has provided personal data, contact us at info@xplay.mn
and we will take appropriate steps to delete it.
Depending on your location, you may have rights to:
Access the personal data we hold about you
Correct inaccurate data
Delete your account and personal data
Object to or restrict certain processing
Withdraw consent (where processing is based on consent)
How to request: Email [info@xplay.mn with your account identifier (phone/email) and your request. We may need to verify your identity.
Marketing/notifications: You can disable notifications in your device settings or in the app (if provided).
Our website may use cookies or similar technologies for functionality and analytics. You can control cookies through your browser settings. (If your website does not use cookies, remove this section.)
The Service may contain links to third-party websites or services. We are not responsible for their privacy practices. Please review their policies.
We may update this Privacy Policy from time to time. We will post the updated version on this page and update the Effective date. If changes are significant, we may notify you in the app.
If you have questions or requests about privacy, contact:
Filmx Play LLC
Ulaanbaatar, Mongolia
Email: info@xplay.mn