Last Updated: May 10, 2023
I. INFORMATION WE COLLECT
A. Information About You That You Share With Us Directly
Depending on the Service, the personal information we collect will be relevant to providing that Service and include some or all of the following:
- your first and last name
- your username or alias
- your gender
- your age, birthday or age range
- your email address
- your profile photo and/or avatar
- your approximate location
- your contact details including phone number and address
- a password
- links to your profiles on various social networks and social network ID number
- information related to any purchases you make in our Services
- personal information you provide when you ask for help from our customer support team, including the content of that communication with our team
B. Information You Generate Using Our Services
When you use our Services, we will collect personal information about the ways in which you use and interact with our Services, such as when and for how long you utilize our Marketplace, and any purchases you make.
If you choose to use communication features in our Services to communicate or share information with other users, then we’ll collect information on what is communicated or shared. This includes:
- your participation in user forums and message boards;
- your public posts or comments on other users’ profiles;
- your non-public messages or invitations to other users made either directly on our websites or through in-application mechanisms;
- your chats with other users, whether by instant message, live chat, video, on this Platform, or on Discord; and/or
- your posted photos, drawings, or other user-generated content .
We may keep these communications, comments, photos, drawings, and other user-generated content on our servers to use them to protect the safety and well-being of our users; to protect our rights and property in connection with our Services; to conduct research; to operate, improve, personalize, and optimize our Services and our users’ experiences, including through the use of analytics; and to manage and deliver advertising. Where required by law, we will seek your consent for this.
C. Payment Information
If you purchase virtual assets or items on our website, our third-party payment processor will collect the billing and financial information it needs to process your charges. This may include your postal address, email address, and financial information. Where we use payment processors, they do not share your financial information, like credit card numbers, with us, but they may share non-financial information with us related to your purchases, like your name, billing address, and the items purchased. You are free to delete saved billing and financial information at any time.
D. Cookies and Other Automated Information Collection
We, our service providers, and our business partners use these cookies and other similar technologies to process information, including:
- IP address;
- the type of computer or mobile device you are using;
- platform type (like Apple iOS or Android);
- your operating system version;
- your mobile device’s identifiers, like your MAC Address, Apple Identifier For Advertising (IDFA), and/or Android Advertising ID (AAID);
- application performance and de-bugging information;
- your browser type and language;
- referring and exit pages, and URLs;
- the number of clicks on an app feature or web page;
- the amount of time spent on an app feature or web page;
- domain names;
- landing pages;
- your settings and preferences;
- pages viewed and the order of those pages; and/or
- what your current progress is in our Services and the date and time of activity.
II. PROCESSING AND USE OF YOUR PERSONAL INFORMATION
We only collect and use your personal information when we have a legitimate reason for doing so. Most commonly, we will use your personal data in the following circumstances:
- Provide our Services and create accounts in those Services
- Improve, optimize and personalize our Services and our users’ experiences
- Help you to connect with other people you know and other third-party platforms you use, including communicating with other users
- Communicate with you about the Services you are using or we think you will like, including Marketplace updates, new Services, pre-registrations and promotional marketing offers
- Customer service and managing user communications, including technical support
- Marketing, research, analytics and delivering contextual and behavioral advertising
- Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners
- Protect the safety and well-being of our users and others
- Where you provide sensitive or special category personal information to us
- Maintain our business operations, including any business transition, like a merger, acquisition by another company, or sale of all or part of our assets
- For security purposes and to prevent fraud or potentially illegal activities, and to enforce the applicable Terms of Service
- Cooperate with public authorities and law enforcement where lawfully permitted or required
- Protect our rights, including compliance with applicable legal obligations, resolving any disputes we may have, and to administer our agreements with third parties
III. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
We share your personal data with our third-party service providers, agents, subcontractors and other associated organizations, our group companies, and affiliates (as described below) in order to complete tasks and provide the Platform and services to you on our behalf. When using third party service providers, they are required to respect the security of your personal data and to treat it in accordance with the law.
We may disclose personal information to:
- a parent, subsidiary, or affiliate of the Company
- third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, professional advisors, and payment systems operators
- our employees, contractors, and/or related entities
- our existing or potential agents or business partners
- credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you
- courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights
- third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you
- third parties to collect and process data
- an entity that buys, or to which we transfer all or substantially all of our assets and business
IV. SECURITY OF YOUR PERSONAL INFORMATION
If you have an account registered directly with us, your profile information is protected by the password you use to access your account. It is important that you protect and maintain your account’s security and that you immediately tell us of any unauthorized use of your account. You are also required to employ multi-factor authentication provided via Google Authenticator or a similar service provider to strengthen the security of your account. If you forget the password to your account, the Services allow you to request that instructions be sent to you that explain how to reset your password. Where you access our Services through another account (for example, a social network) please keep that account information secure as well. We urge you to log out of your account and any social network account you have used to access our Services when you are finished using them.
While we take precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our Service. Any transmission is at your own risk.
V. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
How long we retain your personal information depends on why we collected it and how we use it, but we will not retain your personal information for longer than is necessary to provide you with the Services or satisfy our legal requirements.
We will retain personal information that is connected with your account and/or the Services you use from us for as long as you have an active account with us. We will take measures to delete this personal information if you delete your account. However, you acknowledge that we may retain some information after you have closed, or we have deleted, your account with us where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights.
VI. YOUR RIGHTS AND CONTROLLING YOUR PERSONAL INFORMATION
Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by opting out of the promotional communications or contacting us using the details below.
Access: You may request details of the personal information that we hold about you.
Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example providing user support), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.
Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
No fee usually required: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is manifestly unfounded or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Period for replying to a legitimate request: We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
VII. CHILDREN’S PRIVACY
The Platform is not directed to children under 18 (or any other age as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has uploaded personal information to our Platform without your consent, you may contact us at firstname.lastname@example.org. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account if applicable.
VIII. BUSINESS TRANSFERS
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.
IX. INTERNATIONAL TRANSFERS
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States, members of the European Union, or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
X. LIMITS OF OUR POLICY
Our Platform may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites and cannot accept responsibility or liability for their respective privacy practices.
XI. CHANGES TO THIS POLICY
If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.
If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.
XII. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information we have collected about them, and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information by visiting: https://www.oag.ca.gov/privacy/ccpa.
XIII. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at email@example.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.
XIV. YOUR RIGHTS AS A DATA SUBJECT (GDPR)
You have certain rights under applicable legislation, and in particular under Regulation EU 2016/679 (General Data Protection Regulation or ‘GDPR’). You can find out more about the GDPR and your rights by accessing the European Commission’s website.
XV. CONTACT US FOR QUESTIONS AND REPORTING VIOLATIONS
Straato is incorporated as Straato LLC at 55 Totten Drive, Bridgewater, NJ.