Privacy policy

STARFORGE SYSTEMS | ONLINE PRIVACY POLICY

Last Update: September 17, 2024

Welcome to Starforge Systems!

This privacy policy will explain what data we collect online, why we collect it, and the choices we offer to you.

This privacy policy (“Policy”) describes the data practices of King Gaming Labs (“Starforge”, “Starforge Systems”, “we”, “our” or “us”), covering services under our control, including the website(s) we maintain (e.g., www.starforgesystems.com), the social media pages and servers we operate, as well as any other services where you might interact with us (collectively "Services").

This Policy is made available prior to your use of the Services. By using the Services, you acknowledge that you have had an opportunity to read this Policy and understand that we will process your data in the manners provided in this Policy. This Policy makes up a series of documents that govern the use of our Services, including but not limited to our Terms & Conditions (https://starforgesystems.com/policies/terms-of-service), Shipping Policy (https://starforgesystems.com/policies/shipping-policy), and Refund Policy (https://starforgesystems.com/policies/refund-policy). If you do not agree with our Policies or Terms, please do not use our Services.

Your privacy is not a tradeable asset to us. We don’t sell personal data, and we’re not in the business of data monetization or otherwise profiting off your data. However, certain modern operations, like troubleshooting, completing transactions, and improving our Services, do require some data from you and the third parties involved. To that extent, you’ll find the data we collect on our users is largely based on industry practices and secured by our highest standards.

I. OUR ROLES

Starforge Systems functions in both capacities of a Data Processor and a Data Controller, managing personal data, device data, and other data we may receive (collectively, your “Personal Data”) with respect to the nature of interaction with our Services.

A. DATA PROCESSOR

As a Data Processor, Starforge Systems processes Personal Data on behalf of third-party platforms (e.g., Community Platforms) following their specified instructions. This role is focused on supporting our Services and partnerships through data processing activities determined by these third parties, without making decisions regarding the objectives or methods of data use.

B. DATA CONTROLLER

When acting as a Data Controller, Starforge Systems determines the purposes and means of processing Personal Data. This applies to interactions directly with our Services, including decisions on data collection, use, security, and storage, in compliance with applicable privacy legislation.

Understanding our dual roles is important for you to know how and when you can exercise your privacy rights. As a Data Processor, your rights in relation to the data processed on behalf of third parties should be directed to the respective data controllers. As a Data Controller, Starforge Systems directly manages how Personal Data is used, allowing you to exercise your rights with us directly, such as requesting access to, correction, or deletion of your Personal Data.

II. DATA COLLECTION

We may collect Personal Data through the Services about your use and how you use them.

A. AGE REQUIREMENTS

Our Services are not intended for users under the age of 18, and we do not knowingly collect Personal Data from children. In some geographical areas, our Services may not be accessible to anyone under the age of 18, regardless of whether a parent or guardian has provided consent.

If you are under 18, we request that you do not submit data through any of our channels. If we later learn that we have inadvertently gathered Personal Data from a child under the age of 18, regardless of where that child resides, we will remove this data from our records as quickly as possible.

If you believe we have any Personal Data from or about a child under 18, please contact us at privacy@starforgesystems.com, and we will promptly take the necessary steps to remove all such data.

B. DATA CATEGORIES

The type of Personal Data we collect depends on how you use the Services. Generally, we have collected the following data over the past 12 months:

· Identifiers / Contact Data: Name, shipping address, email address, phone number, unique personal and device identifiers (e.g., mobile device ID, platform ID, gaming service ID, advertising ID like IDFA and Android ID), and IP address.

· Protected Characteristics: Age and gender.

· Commercial Data: Purchase and usage history, preferences, shipping preferences and history, as well as survey and poll responses related to our Services.

· Billing Data: Includes authorization numbers, card type, last four digits, billing address, transaction date and time. Full card information is not stored.

· Internet / Electronic Activity: Web and app browsing data relevant to the Services; interactions with our Services; details about the platforms utilized, including engagement data with content (e.g., likes, follows, comments), subscription data, community engagement data, and interactions with advertisements.

· Device and Usage Data: Device type, software and hardware details, language settings, browser type and version, operating system, and data about how users use and interact with the Services (e.g., content viewed, pages visited, clicks, scrolls).

· Profile Inferences: Inferences made from your data and web activity to help create a personalized profile so we can identify goods and services that may be of interest.

· Audio / Visual Data: Account photos, images, and avatars, audio data via chat features and functionality.

· Sensitive Data: Contents of communications via chat features and functionality.

· Geolocation Data: Inferred geographic location data derived from your device or network.

· Professional or Employment-Related Data: For individuals applying through our Careers page, this includes employment history, resumes, and, where applicable, background check information.

III. INFORMATION SOURCES

The way we obtain Personal Data depends on how you use the Services. For example, we collect Personal Data:

· When you provide data directly to us, such as when you set up an account, sign-up for marketing, or contact us.

· From specific third parties, such as when you access our Services with third-party accounts.

· Automatically, including through cookies and similar tracking technologies.

A. FROM YOU

You provide us with Personal Data when you use the Services, such as when you:

· Create an account or use our Services;

· Purchase or redeem one of our products or Services;

· Contact us for support or other purposes;

· Subscribe to marketing and communications;

· Comment on our message boards, forums, chat rooms, feeds, sites, or other Services;

· Participate in events, giveaways, contests, promotions, or surveys;

· Participate in an activity where you provide your data;

Apply for a job with us; or
Partner with us in a shared business, promotion, or charity.

B. FROM THIRD PARTIES

We obtain your Personal Data when you access our services using third-party platform accounts, such as social networking service accounts or accounts with other relevant platforms. When you access our services in this way, the third-party platforms provide us with data about you. For example, depending on your use of, or activity on, the third-party platform, we may receive your username, friends list, or account data necessary to provide our services. The third-party platform may allow you to control what data is provided to us. We are not responsible for the terms, policies, disclosures, or actions of any third-party platforms.

We receive data from third parties to update the data that we collect about you. This may include data from public databases, platform manufacturers, analytics providers, and other business partners involved in providing our services. This data can include demographic information and data about your interests. We may collect publicly available data, including from social media, to protect our users, employees, facilities, and services, and to aid investigations. We also receive data from other individuals who use our services. This may include data about you if you are mentioned in comments on the services or if an individual sends us a direct message.

C. AUTOMATICALLY

1. From Your Device

When you use the Services, we automatically receive data about your experience. This includes device and usage data; gameplay data; log data; and location data.

· Device and usage data. We may collect device and usage data, such as your IP address, device type, operating system, browser type, and usage data.

· Log data. We may collect log data, including details of how you used our Services, device data, and any events that occur in relation to your use of our Services to help us improve our Services and diagnose and fix any issues that may arise.

· Location data. We may collect your location data through your device settings, if you grant us permission. This includes IP addresses, which can be used to provide location-based services, like relevant content or ads.

2. From Cookies and Similar Technologies

We may use cookies, web beacons, pixel tags, Flash cookies, Internet log files, software developments kits and similar tracking technologies to improve and maintain the functionality of our Services; enhance security and fraud prevention; and provide you with targeted advertising. Our system may not respond to Do Not Track (“DNT”) requests or headers from some or all browsers.

There are several types of cookies that may be used on our website:

Essential cookies. These cookies are necessary for the website to function properly and cannot be disabled. They are used to remember your preferences, login details, and other settings to provide you with a seamless browsing experience.
Performance cookies. These cookies are used to may collect data about how you use our website, such as which pages you visit most often. This data is used to improve the performance of our website and make it more user-friendly.
Functional cookies. These cookies are used to remember your preferences and settings, such as your language preference or your choice of theme. They help enhance your experience by providing personalized and relevant content.
Targeting cookies. These cookies are used to track your browsing habits to show you relevant ads based on your interests.
Unclassified cookies. These cookies are those that we are in the process of classifying, together with the providers of individual cookies.

We use cookies on our website to improve your browsing experience and to personalize the content and ads that are displayed to you. We may also use cookies to analyze how you use our website and to track your browsing behavior.

We may use cookies when you:

Visit our Websites;
Engage in our Services; or
Interact with our Online Content.

Our third-party partners may also collect this data when you use other websites or applications that integrate with our Services. We collect this data in accordance with applicable laws and regulations, and it is used solely for the purposes described in our Privacy Policy.

IV. DATA PROCESSING

We use Personal Data collected from our Services to provide, maintain, and improve our Services, to develop new Services and offerings, and to protect us and our users.

A. PURPOSES

1. Business Purposes

Starforge Systems uses Personal Data to support and enhance the delivery of our Services. This includes:

· Responding to user inquiries, fulfilling service requests, and maintaining open communication.

· Personalizing user experiences, such as remembering privacy preferences and profile settings.

· Providing technical support and addressing service-related issues.

· Analyzing service usage to inform the development of new products and improve existing Services.

· Conducting internal reviews, marketing studies, and demographic analyses to guide business decisions.

· Ensuring the security and integrity of our Services by preventing fraud, policy violations, and managing risk exposure.

· Interacting with third-party platforms on the user's behalf, as authorized through the Services.

· Engaging in processing activities as explicitly agreed upon by users or as notified at the point of data collection.

· Complying with applicable legal requirements and enforcing our Terms of Service.

2. Commercial Purposes

For commercial endeavors, we use Personal Data to:

· Deliver personalized content, promotions, and advertisements to users across various platforms and channels, including email, text messages, and social media, either directly or through our partners.

· Inform users about new Services, updates, and promotional offers.

· Administer promotional events such as rewards programs, surveys, and contests in collaboration with us or our partners.

· Leverage Personal Data in aggregated or anonymized forms for targeted marketing strategies and audience analysis to identify and reach similar user groups.

B. LEGAL BASIS

For users in jurisdictions requiring a clear legal basis for data processing:

· We process data to fulfill our contractual obligations and provide requested Services.

· Information processing is carried out in compliance with legal obligations.

· We pursue legitimate interests or those of our partners to enhance our offerings, understand user preferences, perform marketing activities (where consent is not required), support our operations, and enforce our policies.

· To protect the vital interests of users or others where necessary.

· With explicit user consent for specific processing activities, including marketing communications and integration with third-party services.

V. DATA SHARING

Starforge Systems shares Personal Data under specific circumstances to support our Services, comply with legal requirements, and enhance user experience.

A. GENERALLY

We share your information for the following reasons:

· With Consent. We share information with companies, organizations, or individuals outside of Starforge Systems when we have your explicit consent.

· For Service Provisioning. Trusted partners and affiliates process information on our behalf, based on our instructions and in line with our privacy practices, to support our service delivery and operations.

· Legal and Safety Reasons. Information is disclosed to meet legal requirements, protect our rights, and ensure the safety of our users and the public. This includes responding to legal processes or addressing fraud and security issues.

· Business Transfers. In events like mergers or asset sales, your information may be part of the transferred assets. We will notify you in such cases.

· Analytical and Advertising Needs. We partner with third parties for analytics and targeted advertising, sharing aggregated or non-personally identifiable information to improve our Services and offer relevant advertisements.

· Public Forums and Community Engagement. Participation in open communities may lead to public sharing of any information disclosed by you either over public platforms (like Discord) or at community events.

· Collaborative Efforts. Information may be shared with third parties for collaborative services or promotions, with clear communication at the time of collection for your informed decision.

You have control over your Personal Data, including choices about how we share your Personal Data with third parties for advertising and analytics. For more details, see Section IX. YOUR CONTROLS.

B. CATEGORIES OF THIRD PARTIES

We disclose your Personal Data for business purposes to the following categories of third parties:

· Authorized Representatives. Individuals or entities authorized by you to act on your behalf, including but not limited to, legal advisors, agents, or other representatives managing transactions, disputes, or legal matters.

· Affiliates. This category includes companies within the Starforge Systems family, such as subsidiaries, parent companies, or other entities under common control, sharing resources to provide and improve Services.

· Service Providers. External organizations that provide essential services on our behalf, including but not limited to, web hosting, data analytics, payment processing, customer support, email distribution, and marketing efforts.

· Advertising and Analytics Partners. Third-party advertisers and analytics providers that collect information to serve targeted advertising and to furnish Starforge Systems with analytical insights concerning service usage and user preferences.

· Legal and Regulatory Authorities. When required by law or to protect our rights and safety, Personal Data may be shared with law enforcement, regulatory agencies, or other governmental bodies.

We may disclose Personal Data to payment processors (i.e., Bread Financial, PayPal, Shopify, Google [GPay], or Plaid) to facilitate and secure your transactions. When purchasing a product, the following data is transferred to the selected payment processor: name, billing address, shipping address, email address, phone number, payment card details (e.g., credit or debit card number, expiration date, and security code), transaction details (e.g., purchased items, purchase amount, and transaction date).

Starforge Systems is committed to partnering with entities that uphold robust privacy practices. However, our Privacy Policy does not cover third-party services or products linked from our Services. We do not oversee the privacy policies or settings of third-party sites, including social networks. For further information, please see Section IX. YOUR CONTROLS for the relevant privacy policies for each third-party we work with.

C. PUBLIC INTERACTIONS

When participating in our services or engaging on platforms that host our services, be aware that certain information, such as your username and profile details, may become publicly visible. This visibility extends to your activities within social networks, including your username, profile, and associations, which may be displayed on our services. Additionally, posting personal data, images, or videos on our public platforms makes this information accessible to others. Public platforms offer no expectation of privacy, so we advise against sharing sensitive personal data in these areas.

You are responsible for any data or content you publicly post using our Services. We strongly urge you to exercise caution and consider the public nature of the information shared through these platforms.

VI. DATA STORAGE & RETENTION

We store and process your data in the United States. We'll keep your data for as long as necessary to provide you with the Services, fulfil our legal obligations, and/or exercise, defend or establish our rights.

A. STORAGE

When you access our Services, including when available on third-party platforms, your personal data is generally collected by us directly and processed in the United States. Personal data we may collect may be subsequently stored and processed for the purposes set out in this Privacy Policy in the United States or any other country in which we, our subsidiaries, or third-party agents operate. By consenting to the transfer of your personal data outside of your country of residence, you acknowledge that your personal data may be transferred to recipients in the United States and other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship.

B. RETENTION

We retain the data we collect in accordance with our Retention Policy, for as long as necessary to provide our Services, and we may retain that data beyond that period if necessary for legal, operational, or other legitimate reasons.

We retain your data while your account is active, as needed to provide you Services, or to administer our Services. If you wish to delete your account or request that we no longer use your personal data to provide Services to you, contact us at privacy@starforgesystems.com. If your account is inactive, we will maintain your account for the length of time for which we reasonably expect you to reengage with our Services. After such period, we will delete personal data, including your email address and log-in credentials, and you may no longer be able to access your account.

We may still retain some of your personal data in our files for a reasonable period of time to resolve disputes, enforce our terms and policies, administer our Services, comply with technical and legal requirements, and/or other constraints related to the security, integrity, and operation of our Services, after which we will take steps to delete or archive your personal data.

Where possible, we may also de-identify, anonymize, or aggregate the data we may collect, or may collect it in a way that does not directly identify you. We may use and share such data as necessary for our business purposes and as permitted by applicable law.

VII. DATA SECURITY

We take the security of your personal data seriously and take appropriate measures to protect it. We use a variety of physical, technical, and organizational measures to safeguard your personal data against accidental, unauthorized, or unlawful access, use, or disclosure. We also require our third-party service providers to take appropriate security measures to protect the confidentiality and security of your personal data.

Our data protection practices include multifactor authentication, database encryption, secure transport for API requests, and access controls. We regularly examine and refine our security practices to ensure that they are up to industry standard in compliance with applicable laws, regulations, and industry standards.

Despite our best efforts, no security measure is entirely foolproof. We cannot guarantee the security of your personal data, and we cannot be responsible for unauthorized access to or theft, alteration, or destruction of your personal data. You are responsible for keeping your login credentials and passwords confidential. If you believe your account has been compromised, please contact us at privacy@starforgesystems.com.

If we become aware of a data breach that affects your personal data, we will notify you as required by applicable law. We will also take appropriate measures to mitigate the impact of the breach and prevent future occurrences.

Please note that our Services may contain links to third-party websites or Services. We are not responsible for the security or privacy practices of those websites or Services, so we encourage you to review their privacy policies and terms of use before using or accessing them.

VIII. YOUR RIGHTS

We believe that respecting your privacy and providing you with control over your personal information is fundamental to our relationship with you. We understand that you have a right to make choices about how your information is used and shared.

Depending on your location, you may have certain rights over your Personal Data, including the right to:

Request access to or a copy of your Personal Data.
Request deletion of your Personal Data.
Request correction or modification of your Personal Data.
Be informed about the Personal Data we collect and/or process about you, the sources of Personal Data, and the third parties with whom information was shared or sold and for what purposes.
Withdraw consent, if processing is based on consent.
Opt-out of the sale or sharing of your Personal Data, to include targeted advertising and automated processing.
Opt-in/out of financial incentives.
Limit the use and disclosure of your sensitive Personal Data.

You can make an information rights request in relation to your Personal Data by contacting us at privacy@starforgesystems.com. We will respond to information requests within a month. We may take steps to verify your identity before we can respond to your request. To the extent these rights apply to you, they may be limited in some situations -- for example when we are under a legal requirement or have a compelling interest for processing your Personal Data, or when the Personal Data is protected by trade secret. If you have unresolved concerns, where applicable, you may also have the right to complain to a privacy authority. A list of privacy authorities is available at https://globalprivacyassembly.org/participation-in-the-assembly/list-of-accredited-members/.

To opt out of the sale or sharing of your data, please contact us at privacy@starforgesystems.com, and include “Do Not Sell or Share My Personal Data” in the subject line. To opt out of online personalized advertising more broadly, please see the opt-out options identified in the next Section IX. YOUR CONTROLS. We will not discriminate against you for exercising any of these rights.

You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you've authorized them to act on your behalf or must demonstrate they have power of attorney pursuant to applicable probate law. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent's identity.

IX. YOUR CONTROLS

A. MANAGING YOUR DATA WITH US

1. Starforge Accounts

If you sign up for our Services and create an account, we provide you with options to customize your privacy preferences within your account settings. By adjusting these settings, you can actively manage the level of access and visibility of your personal data, ensuring that your privacy aligns with your individual preferences.

2. Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested.

We may also send you non-promotional communications regarding us and our Services regarding our Services or updates to our Terms or this Privacy Policy.

3. Advertising

If you prefer not to receive marketing messages or sponsored content, please contact us at privacy@starforgesystems.com and we will ensure your preferences are updated accordingly.

4. Do Not Sell or Share My Personal Information (CCPA)

If you are a resident of California, you have the right under the California Consumer Privacy Act (CCPA) to opt out of the sale or sharing of your personal information. To exercise this right, please contact us at privacy@starforgesystems.com with your request.

B. MANAGING YOUR DATA WITH THIRD-PARTY PROVIDERS

Our Services integrate with various third-party accounts and platforms, including Community Platforms, Marketing Providers, and Payment Processors. You can customize your privacy settings within your account settings on these platforms to control the data that is shared with us. We encourage you to review the privacy policies and settings of these third-party accounts and platforms.

You can review their policies at the links below:

Community Platforms

· Discord: Discord Terms of Service (https://discord.com/terms); Discord Privacy Policy (https://discord.com/privacy)

· Impact: Impact Privacy Policy (https://impact.com/privacy-policy/); Impact Terms of Use (https://impact.com/terms-of-use/)

· Patreon: Patreon Terms of Use (https://www.patreon.com/policy/terms); Patreon Privacy Policy (https://www.patreon.com/policy/privacy)

· Instagram: Instagram Terms of Use (https://www.facebook.com/help/instagram/581066165581870); Instagram Data Policy (https://www.facebook.com/help/instagram/155833707900388)

· TikTok: TikTok Terms of Service (https://www.tiktok.com/legal/page/us/terms-of-service/en); TikTok Privacy Policy (https://www.tiktok.com/legal/page/us/privacy-policy/en)

· Twitch: Twitch Terms of Service (https://www.twitch.tv/p/en/legal/terms-of-service/); Twitch Privacy Notice (https://www.twitch.tv/p/en/legal/privacy-notice/)

· X / Twitter: X / Twitter Terms and Conditions (https://twitter.com/en/tos); X / Twitter Privacy Policy (https://twitter.com/en/privacy)

· YouTube: YouTube Terms of Service (https://www.youtube.com/t/terms); YouTube Community Guidelines (https://www.youtube.com/howyoutubeworks/policies/community-guidelines/)

Marketing Providers

· Google Analytics (Google LLC): Terms of Service (https://marketingplatform.google.com/about/analytics/terms/us/); Privacy Policy (https://policies.google.com/privacy); Google Analytics Opt-Out (https://tools.google.com/dlpage/gaoptout)

· Google Tag Manager (Google LLC): Terms of Service (https://marketingplatform.google.com/about/tag-manager/terms/); Privacy Policy (https://policies.google.com/privacy)

· Facebook Pixel (Meta Platforms, Inc.): Terms of Service (https://www.facebook.com/legal/terms); Privacy Policy (https://www.facebook.com/privacy/explanation); Facebook Pixel Ads Preferences (https://www.facebook.com/ads/preferences/)

· LinkedIn Insights (Microsoft Corporation): Terms of Service (https://www.linkedin.com/legal/user-agreement); Privacy Policy (https://www.linkedin.com/legal/privacy-policy)

· Klaviyo (Klaviyo Inc.): Terms of Service (https://www.klaviyo.com/legal/terms-of-service); Privacy Policy (https://www.klaviyo.com/legal/privacy-policy)

Payment Processors

· Bread Financial (Bread Financial): Terms of Service (https://www.breadfinancial.com/en/legal/terms-and-conditions.html); Privacy Policy (https://www.breadfinancial.com/en/privacy.html)

· PayPal (PayPal Holdings, Inc.): Terms of Service (https://www.paypal.com/us/webapps/mpp/ua/legalhub-full); Privacy Policy (https://www.paypal.com/us/legalhub/privacy-full)

· Shopify (Shopify Inc.): Terms of Service (https://www.shopify.com/legal/terms); Privacy Policy (https://www.shopify.com/legal/privacy/app-users)

· Stripe (Stripe, Inc.): Terms of Service (https://stripe.com/legal); Privacy Policy (https://stripe.com/privacy)

· Google GPay (Google LLC): Terms of Service (https://payments.google.com/payments/apis-secure/get_legal_document?ldo=0&ldt=us_tos); Privacy Policy (https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice)

C. COOKIE CONTROLS

You may stop or restrict the placement of cookies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

Please note you must separately opt out in each browser and on each device.

If you have any questions or concerns regarding your privacy choices or how we handle your personal data, please contact us at privacy@starforgesystems.com. You can also contact the support teams for each platform if you require further assistance managing your privacy settings.

X. GENERAL PROVISIONS

A. POLICY UPDATES

Our Privacy Policy may change from time to time. We will post any Policy changes on this page and within the settings of any mobile apps. Please check back periodically to view changes to our privacy policy. If there are material changes to this Policy, we will use reasonable efforts to notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification.

B. CONTACT US

If you have questions about this Policy or our privacy practices, please contact our Information Protection Team at privacy@starforgesystems.com.

C. CONTACT A DATA PROTECTION AUTHORITY (DPA)

If you have a concern about how we may collect and use data, please contact us. You also have the right to contact your local Data Protection Authority (“DPA”) if you prefer.

To contact your local DPA, refer to the links below:

· EEA - DPA Directory

· UK - Information Commissioner’s Office (ICO)

· Canada - Office of the Privacy Commissioner (OPC)

Where appropriate, your local DPA may also forward the matter to the Department of Commerce or FTC for consideration.

Last Updated: September 17, 2024