Privacy Policy

Pritto Prisoner Privacy Policy

This Privacy Policy (this "Policy") explains how Initiate Incubator Management LLC (hereinafter, "we," "us," or "our") collects, uses, shares, and protects information when you use our product Pritto Prisoner and its related services (collectively, the "Service"), and your rights and choices about the collection and use of your information.

If you do not agree to the collection and use of your personal information in the way this Policy describes, please do not provide your information and do not use the relevant Service. Your use or continued use of the Service (including without limitation installing and/or use of our product, making in-app purchases, using our forum, etc.) constitutes your acceptance of this Policy.

If you are under 18 years old (or other age requiring parental consent as prescribed by the laws of your jurisdiction), you must have your parents' or guardians' permission to agree to this Policy and use the Service. Your acceptance of the Policy and/or use of the Service means that both you and your parent or guardian have agreed to the terms of this Policy.

This Policy is updated and effective on and from July 31, 2025.

1. Information We Collect or Have Access To

We may collect or have access to the following types of information:

A. Information You Provide:

This includes information you provide to us when you use our product or Service. For example, you may provide us with your email address, account information, nickname, profile photo, in-app purchase history, etc., when you inquire about or use our Service (such as user inquiries, support requests, community forum, after-sale services, etc.).

When you submit a support request, you need to log into our customer service website through your third-party account (such as Facebook or Google Account). In this process, we may collect your third-party account information (including your nickname and profile photo) from such third-party account providers. We also collect your Customer Service ID in the product and the information you provide to us in your support request so that we can help and respond to your request as soon as possible.

When you use our community forum, we may collect your email address (for registration and login) and your interactive information, such as your postings and comments on our forum, your nickname, and profile photo. You should be aware that your comments and other interactive information will be viewable to all visitors to our community forum, and you should comply with all applicable laws, regulations, and our forum terms when you post, comment, or provide other forum interactive information.

This also includes information you send us when you participate in certain activities on our website or use our Service in other ways. For example, when you use our Service (such as certain features on our website, etc.), you may provide us with your email address, social media account, instant messaging (IM) account, etc.

In certain circumstances, you may voluntarily provide us with information. For example, in order for us to contact you, complete our Service, or clarify certain steps for using our Service, you may send us your email address, etc.

We collect and use the above information to provide our Service to you, enable you to use various features of our Service, and maintain a healthy online environment.

B. Information We Collect Automatically:

Your Account Information: We collect your account information, such as your platform ID and Account Name if you use our Service via various platforms, and your nickname and user icon in our product or Service.

Your Behavioral Information: We collect information about your behavior within our product, such as login activity, usage attempts, progress, your saved preferences, history, interactions with other users, and the date and time of your activity.

Your Purchase Information: We collect your in-app purchase transaction records when you make purchases, such as your account information, the items purchased and the costs, and transaction order numbers on various platforms.

We collect and use the above information to enable you to use our product and Service. We also collect and use this information for operation statistics and analysis, fraud detection, customer service, complaint handling, and security analysis.

Your Device Information: We collect your device information when you use our product or Service, such as device name, model, device settings, device performance, operating system, system language, platform, and network type, etc.

Your Location Information: We collect your IP address and geographic (country, city) location information.

Cookies: When you use our website services, certain login operations on our website may use Cookies to remember your identity and help us identify you as a registered user, retain your preferences, and the information you previously provided to us. You can block/delete Cookies in your browser settings, but after blocking/deleting relevant Cookies, certain services on our website may not be able to function properly.

Certain Aggregated Information: When you use our website services, we may use certain third-party analysis tools to help us evaluate the traffic and usage trends of our website services. These third-party analysis tools collect information sent from your device or from our servers, such as the web pages you visit and other information that assists us in providing and improving our Service. We collect and use the above information in an aggregated way. Such information cannot be used to reasonably identify any specific individual.

We collect and use the above information to operate and provide our product or Service to you (including without limitation allowing you to connect to our servers, using this information to tailor our Service for you, and enabling us to diagnose problems and provide support to you).

2. How We Use Your Information

Please refer to Section 1 above for detailed descriptions of how we use your information at the end of each category of information we collect. We only collect and use your information as minimally required to achieve the purposes identified above.

Overall, we use the above information to:

Provide, operate, and improve our Service.
Monitor metrics such as total number of visitors, traffic, and demographic patterns.
Identify fraud and other inappropriate behaviors.

We will not rent or sell your information to third parties without your consent.

3. How We Share Your Information

Except as stipulated in this Privacy Policy and the Pritto Prisoner Terms of Service or as required by laws, regulations, or court orders, we will not share your personal information with third parties without your consent. If there are other situations where we share your personal information with a third party for use beyond the original authorized purpose, we will obtain your consent.

To provide better customized services and functions to you, we may share certain information with third parties, but only after pseudonymizing the information. We will contractually require such third parties to collect and use your personal information in accordance with applicable data and privacy laws and for the purpose stipulated in this Policy, and take appropriate security and management measures to protect the security of your personal information. However, please note that the actual processing of the pseudonymized information by such third parties is subject to their own privacy policy.

We may disclose your information: (a) after obtaining your express consent, or (b) as required by applicable laws and regulations, or in response to valid requests by public authorities (such as a court or a government agency), or (c) if we determine in good faith belief that such action is necessary to: comply with a legal obligation, prevent or investigate possible wrongdoing in connection with the Service, protect and defend our legitimate rights, or for dispute resolution purposes.

4. How We Store Your Information

The information collected through the Service may be stored and processed in countries where we and our affiliates maintain teams and facilities. The information may be in a country or jurisdiction different from your own, which may not have the same data protection laws as your own country or jurisdiction. For example, your information may be processed on servers that may not be located where you live. But no matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy.

5. Deletion of Your Information

We will delete the information you provide to us after we have completed the relevant Service requiring such information, or will otherwise only keep such information to the minimum extent as required to provide and improve our Service to you. You can also contact us (see WHO WE ARE AND HOW TO CONTACT US below) to have your information deleted (but please note that deletion of certain of your information might affect your continued use of all or part of our Service).

6. Rights You Have Over Your Information

If your personal information is collected from you and where applicable data and privacy laws apply, you will have the right to request access, rectification, erasure, processing restriction, and portability of your personal data, and the right to lodge a complaint with a data protection supervisory authority pursuant to such laws.

To exercise your rights over your personal information, you may contact us using the contact details under WHO WE ARE AND HOW TO CONTACT US below. To protect the security of your account and your personal information, we may ask you to provide certain additional information to verify your identity before we respond to your requests.

7. Children's Privacy

We do not knowingly collect, use, or share information from children under the age of 13 (or other age threshold required by local laws) without parental consent as required by law. In the event that we learn that we have collected personal information from a child under age 13 (or other age threshold required by local laws) without parental consent, we will delete that information as quickly as possible. Parents or guardians may review, modify, or delete the child's personal information, or withdraw consent, by contacting us using the contact information provided at the end of this Policy.

8. Other Websites and Services

We are not responsible for the practices employed by any websites or services linked to or from our Service, including the information or content contained within them. Please remember that when you use a link to access our Service or to go from our Service to another website or service, our Privacy Policy does not apply to those third-party websites or services.

Your Browse and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party's own rules and policies. In addition, you agree that we are not responsible and do not have control over any third-party websites or services or their data and privacy practices.

9. California Requirements

The California Consumer Privacy Act (CCPA) requires specific disclosures for California residents. To the extent CCPA applies, this section contains these specific disclosures.

We may collect the following categories of personal information, as described in the CCPA:

Identifiers (such as email address, account information);
Commercial information (such as in-app purchase transaction records);
Geo-location information (geographic (country, city) location information may be derived from your IP address);
Other personal information as defined under California law (such as your account information, your nickname and user icon in our product or Service, your device information, your email address when using our forum service, your Facebook or Google account information when submitting support requests); and
Inferences drawn from any of these categories (for example, a profile reflecting your preferences based on your virtual item purchase history or behavior).

For details about the personal information we collect, please see INFORMATION WE COLLECT OR HAVE ACCESS TO in Section 1 above.

We collect your personal information for the following purposes:

To enable you to use our Service and provide you with better Service (for example, allowing you to use our product with your account, nickname and icon, allowing you to log in and use our forum, allowing you to submit support requests and responding to such requests, maintaining a healthy online environment, conducting analysis of security, etc.).

For details about the purposes of the personal information we collect, please see INFORMATION WE COLLECT OR HAVE ACCESS TO in Section 1 above.

How we may share your personal information with third parties: We do not rent or sell the personal information we collect.

Other than to act in accordance with the immediately following paragraph, to share with a third-party (but only after pseudonymizing) to provide better customized Service, and to share with our affiliates for necessary Service support, we do not share your information with third parties without your consent.

The CCPA provides you with the right to access, modify, and delete your personal information, as well as the right to request information about how we collect and use your personal information. We do not sell your personal information. We will not discriminate against you for exercising your privacy rights under the CCPA. If you have questions or requests related to your rights under the CCPA, you can contact us.

California Privacy Rights for Minor Users

Since January 1, 2015, California Business and Professions Code Section 22581 permits you, if you are a California resident under the age of 18, to view, correct, or delete personal information provided by you or publicly posted by you, by sending us an email asking us to delete such content at privacy@initiate.fund.

We will be happy to review, update, or remove information and/or content as appropriate. Residual copies of information and/or content that have been deleted from your account may remain in our backup systems for a limited period of time permitted by applicable laws. We may retain your information to resolve disputes, enforce our user agreement, or comply with legal requirements; in this case, your personal information will be blocked from use for any other purpose.

10. Who We Are and How to Contact Us

For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Initiate Incubator Management LLC. Its registered address is 1185 Centinela Ave. Suite 100 Santa Monica, CA 90404.

If you have any questions about this Privacy Policy or if you want to request deletion or modification of any personal information you have provided to us, please contact us at privacy@initiate.fund.

11. Changes to Our Privacy Policy

We may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you notice of modifications or updates if required by applicable laws. Your continued use of (or request to use) the Service after any modification to this Privacy Policy will constitute your acceptance of such modification.

Last updated: July 31, 2025