Privacy Policy

1. Introduction

Welcome to Panya, operated by Surged Pte Ltd. ("we," "us," or "our"), located at Singapore. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and website (collectively, the "Service"). Please read this policy carefully. If you disagree with its terms, please discontinue use of the Service.

2. Information We Collect

2.1 Information You Provide Directly

• Name and email address when you register an account
• Profile information such as a display name and profile photo
• Content you create, upload, or share within the app (e.g., amulet collection details)
• Communications you send us (e.g., support requests)

2.2 Information from Third-Party Sign-In Services

When you choose to sign in using Google, Facebook, or Apple, we receive certain information from those platforms with your consent, which may include:

• Your name and email address — used to create and identify your Panya account
• Your profile picture — used to populate your in-app profile
• A unique identifier issued by Google or Facebook — used to link your social account to your Panya account

We do not receive or store your Google, Facebook, or Apple password. The information we receive is governed by the respective platform's privacy policy in addition to this policy. You can revoke our access at any time via your Google account settings (myaccount.google.com/permissions), Facebook settings (facebook.com/settings), or Apple ID settings (appleid.apple.com).

2.3 Information Collected Automatically

• Device information (device type, operating system, unique device identifiers)
• Log data (IP address, browser type, pages visited, time and date of visit, time spent on pages)
• Usage data (features used, actions taken within the app)
• Cookies and similar tracking technologies (see Section 7)

3. How We Use Your Information

We use the information we collect to:

• Create and manage your account
• Provide, operate, and improve the Service
• Personalize your experience
• Send transactional and administrative communications (e.g., account confirmation, security alerts)
• Send promotional communications, where you have opted in
• Analyze usage trends to improve features and content
• Detect, prevent, and address technical issues, fraud, and abuse
• Comply with legal obligations

4. Legal Basis for Processing (EEA / UK Users)

If you are located in the European Economic Area or United Kingdom, our legal bases for processing your personal data are:

• Contract: processing necessary to provide the Service you requested
• Legitimate interests: improving and securing the Service, fraud prevention, and direct marketing (where balanced against your rights)
• Consent: where you have given explicit consent (e.g., marketing emails, third-party sign-in)
• Legal obligation: compliance with applicable law

5. Sharing of Information

We do not sell your personal data. We may share your information with:

• Service providers: third parties that perform services on our behalf (hosting, analytics, email delivery, payment processing) under confidentiality obligations
• Google, Meta (Facebook), and Apple: only to the extent necessary to facilitate authentication when you choose to use those sign-in options
• Business transfers: in connection with a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction
• Law enforcement / legal process: when required by applicable law or to protect the rights, property, or safety of Panya, our users, or others

6. Data Retention

We retain your personal data for as long as your account is active or as needed to provide the Service. You may request deletion of your account and associated data at any time by contacting us at info@panya.asia. We will delete or anonymize your data within 30 days, except where we are required to retain it for legal, regulatory, or legitimate business purposes.

7. Cookies and Tracking Technologies

We use cookies and similar technologies to recognize your browser or device, understand how you use our Service, and improve your experience. Types of cookies we use:

• Essential cookies: required for the Service to function (e.g., session management)
• Analytics cookies: help us understand usage patterns (e.g., Google Analytics)
• Preference cookies: remember your settings and preferences

You can control cookies through your browser settings. Disabling certain cookies may affect the functionality of the Service.

8. Security

We implement administrative, technical, and physical security measures designed to protect your personal data against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

9. Children's Privacy

The Service is not directed to children under the age of 13 (or 16 in the EEA). We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it promptly.

10. Your Rights

Depending on your location, you may have the right to:

• Access the personal data we hold about you
• Correct inaccurate or incomplete data
• Request deletion of your data ("right to be forgotten")
• Restrict or object to certain processing activities
• Data portability (receive your data in a structured, machine-readable format)
• Withdraw consent at any time, without affecting the lawfulness of processing before withdrawal
• Lodge a complaint with your local data protection authority

To exercise any of these rights, please contact us at info@panya.asia. Please also note that revoking our access via your Google or Facebook account settings will disable that sign-in method for your Panya account.

11. International Data Transfers

Your information may be transferred to and processed in countries other than your own, including Singapore, where our servers are located. We will take appropriate safeguards to ensure that your personal data remains protected in accordance with this Privacy Policy and applicable law.

12. Third-Party Links

The Service may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties and encourage you to review their privacy policies.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new policy on this page with an updated "Last updated" date and, where appropriate, by sending you an in-app notification or email. Your continued use of the Service after the effective date constitutes acceptance of the revised policy.

14. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at: