Privacy Policy

Welcome to Starfish Technology Limited ("Starfish," "we," "us," or "our"). Safeguarding your privacy and ensuring the security of your information are core principles we take seriously. By using our Services, you acknowledge and agree to abide by this Privacy Policy. Your use of our Services constitutes consent to the processing, collection, use, and disclosure of your information and data as described herein. If you do not agree with this Privacy Policy, please refrain from using our Services. For parents or legal guardians permitting their child(ren) to use the Services, you are accepting this Privacy Policy on behalf of your child. If you have any questions concerning this Privacy Policy, please reach out to us by email at:[email protected].

1. IMPORTANT NOTICE FOR INDIVIDUALS UNDER 18

Starfish values the privacy of children. Our Services are designed for users aged 18 and above. If you are under 18, please refrain from using our Services. We are committed to adhering to relevant laws and regulations concerning minors, including the Children's Online Privacy Protection Act (COPPA) in the United States. Specifically, Starfish does not knowingly request or gather personal information from individuals under 18. In the event that we unintentionally collect personal information from a minor, we will promptly delete it. If you believe we may have collected information from a minor, please contact us at [email protected].

2. INFORMATION WE COLLECT WHEN YOU USE OUR SITE AND OUR SERVICES

2.1 Personal Information you provide directly in the Game:The personal information that you provide while playing a Game may be collected by us:

· Contact information,such as your name, username, phone number, email address and physical address.

· Your date of birth.

· Identification documents,such as passport or driving license.

· Payment information,such as the form of payment you use, payment method details (such as credit or debit card number).

· Your precise location and the contacts saved on your device,when you agree, through your device settings, to allow the Game to access this information.

· Any photos that you upload to your profile.

· Chat, comments and opinionsthat you send through any in-app messaging features, or when you submit requests for in-app technical support.

· In-app searchesthat you carry out within the Game.

· Transaction and purchase information,such as any cash top-ups that you make and the frequency with which you top-up your account in the Game.

2.2 Personal Information that is passively collected when you play a Game:

· Phone contactsthat you have stored on the mobile device from which you access a Game.

· Approximate Location Data,including your general geographic location based on your IP address.

· Gameplay content,including recordings of your gameplay and performance records.

· User IDthat you are automatically assigned in connection with your access to a Game.

· Device IDs,such as IDFA and Android ID.

· Usage Data,including the time you launched the Game, the pages and content viewed, any adverts that you viewed and clicked on, the objects and links you clicked on and interacted with, and scrolling information.

· Diagnostics Data,including any crash logs and usage and performance statistics.

2.3 How we use this information:We use personal information we collect to:

· Register and verify your identity:We utilize your personal information to enable registration for and access to Games, as well as to update your profile details.

· Confirm eligibility for Game access:We use your personal information to verify that you meet the legal requirements for accessing and playing a Game, or utilizing specific features and functionalities of a Game, based on your country or state regulations.

· Help you find other players on Games,such as people whose details are saved in your phone contacts.

· Process your payments and purchases,such as updating your account to reflect any purchases that you make in a Game.

· Provide features and functionalities of the Game,such as in-app messaging, chat, gameplay performance records and profile customization features.

· Monitor the performance of and improve our Services:we utilize your personal information to assess the performance of our Services, address any issues, and enhance the features and functionalities of our offerings. Additionally, we use your personal information to experiment with and create new products and services.

· Engage with you and address concerns:We utilize your personal information to communicate important updates and information regarding our Services. Additionally, we use this information to respond to any inquiries, comments, or complaints you may have.

· Send you service related communications,such as purchase confirmations.

· Enhance the safety and integrity of our Services:Your personal information is employed to identify and deter fraudulent, abusive, or harmful activities. Additionally, we use this data to diagnose and resolve technical issues, conduct security investigations and risk assessments, and bolster our security protocols.

· Legal and regulatory requirements and proceedings:we use your personal information in connection with legal and regulatory proceedings and requirements, including the defense of legal claims, compliance with corporate reporting obligations, and compliance with applicable laws.

· Enforce our rights:we may use your personal information to monitor, investigate, prevent and/or mitigate violations of our terms of use as well as enforce our agreements with third parties and business partners.

· For any other lawful or authorized purpose, or for purposes to which you have provided consent.

3. SHARING OF PERSONAL INFORMATION COLLECTED FROM YOU

3.1 Starfish may share personal information with third parties to facilitate the provision of our Services. We may disclose personal information to our affiliated entities and trusted third-party service providers to deliver the Services to you. These third-party service providers are contractually bound to use your personal information solely for the purpose of providing the specific services they are engaged to perform. The types of service providers we may share your information with include:

· Marketing and Attribution Partners– Our marketing service providers assist us with campaign support, attribution, and analytics to identify and track user referrals across different Games.

· Billing and payment providers– these service providers offer billing and financial administration, as well as payment support.

· Analytics providers– these service providers help generate statistics about our Site usage, game play and other data that helps us provide the best services to our customers.

3.2 Some personal information is shared with a third-party service provider to facilitate payment processing. This transmission of payment information is automated, and neither we nor any of our representatives or staff members have the ability to view, access, or store this payment information. For details on how your payment information is handled, please refer to the terms and conditions and privacy policy of our third-party service provider. If you choose to make payments using PayPal, your transactions will be governed by PayPal's terms of service and privacy policy.

3.3 Starfish may share your personal information with third parties under certain circumstances:

(i) To comply with legal requirements, including judicial proceedings, court orders, or legal processes served on Starfish;

(ii) To investigate potential crimes, such as fraud or identity theft;

(iii) In connection with the sale, purchase, merger, reorganization, liquidation, or dissolution of Starfish;

(iv) When necessary to protect the rights, property, or safety of Starfish or others;

(v) As required or permitted by law, including contractual obligations of Starfish; or

(vi) With your explicit consent beforehand.

4. MARKETING

Occasionally, we may reach out to you with important updates regarding our Services. Our primary method of communication is via email. To ensure the relevance of our messages, we may utilize the personal information we have collected about you. You have the option to modify your marketing preferences by clicking the unsubscribe link located at the bottom of our emails.

5. SECURING YOUR ACCOUNT

Your account security is dependent on safeguarding your password and mobile device. It is your responsibility to ensure the security of your password and mobile device. You are solely accountable for all activities conducted under your account. Do not disclose your password to anyone. We will never request your password or sensitive information via email, although we may prompt you to enter such details within the Game interface. Any email or communication asking for your password or sensitive account information via email should be treated as unauthorized and suspicious, and promptly reported to us at:[email protected].

If you share your password or mobile device with a third party for any reason, that party will have access to your account and personal information, and you may be liable for any actions taken using your password. If you suspect that someone else has gained access to your password, please change it immediately. If you believe unauthorized access has occurred, please report it immediately to [email protected].

6. THIRD PARTY DATA COLLECTION AND ONLINE ADVERTISING

We engage in interest-based advertising and work with third-party advertising companies to deliver targeted ads based on your browsing history. Third-party online advertising networks, social media companies, and other services are allowed to gather information about your use of our online services over time. This data is used to display ads on our Services, as well as on other websites or platforms you use, across various devices.

Typically, information for interest-based advertising is collected using tracking technologies like cookies, web beacons, embedded scripts, and similar tools. These technologies identify your device and gather details such as clickstream data, browser type, visit time, AdID, precise location, and other relevant information. We may share a unique account identifier (e.g., hashed email address or user ID) with our advertising partners to recognize you across different devices.

Both we and our third-party partners utilize this information to tailor online ads to your interests and provide related services like reporting, attribution, analytics, and market research. Additionally, we may use services from third parties, such as social media platforms, to deliver targeted ads to you and others on those platforms. This may involve providing a hashed version of your email address or other relevant information to the platform provider.

7. MANAGING AND KEEPING YOUR ACCOUNT DETAILS CURRENT

As part of your use of the Services, you are responsible for maintaining and updating, as applicable, your account information with current and complete information. You may edit and delete portions of your account information. After receiving any requested changes to your account information or personal information, we will make reasonable efforts to ensure that all of your personal information stored in databases we actively use to operate the Services will be updated, corrected, changed, or deleted as appropriate, as soon as reasonably practicable. However, we reserve the right to retain in our archival files any information we remove from or change in our active databases, subject to any obligations under any applicable law. Where permissible, we may retain such information to resolve disputes, troubleshoot problems, and enforce our Terms of Service. In addition, it may not be technologically possible to remove every record of the information you have previously provided us, as a copy may exist in a non-erasable form that will be difficult or impossible for us to locate.

8. POLICY CHANGES

As our business evolves regularly, this Privacy Policy may undergo updates periodically. If we make significant changes to this Privacy Policy, we will notify individuals through their registered email address, by prominently posting the updates on our Service, or through other suitable communication methods.

9. CONTACT US

If you have any questions or feedback regarding this Privacy Policy or how Starfish collects and manages information, please feel free to reach out to us via email at [email protected]. We welcome your inquiries and value your input.