Last Updated: October 25th, 2022
- Information We Collect
Site Use Information
Plug in Information
Information You Provide to Us
Social Networking Activities
Information on the Blockchain
- Opting Out of Communications and Advertisements
- Using Personal Information
- Disclosing Information to Third Parties
- Links to Other Websites
- Child Privacy
- Notice to California Residents
Your California Privacy Rights
California Consumer Privacy Act
- Notice to European Residents
- Access from Outside the United States
Information We Collect
To receive certain benefits of using the Sites, you may be required to provide certain personally identifiable information belonging to you, including but not limited to your name (first and last name), email address, physical address, phone number, job titles, credit card information, or digital wallet information, and other employment and background information (“Personal Information”). If you do not wish for this Personal Information to be collected, you should not use the relevant function of the Sites. The following describes the types of Personal Information and other information we may collect about you, and how we use and maintain that information:
Site Use Information
Our web servers may collect information related to the device or browser you use to access or interact with our Sites, such as IP address, location information, unique device identifiers and other information about your device, browser types, browser language, and unique numbers or codes in cookies. This information may be aggregated to measure the number of visits, average time spent on the Sites, pages viewed, etc. We may use this information to measure the use of our Sites and to improve the content we offer; for security detection, protection and enforcement; for ad customization; for internal research, development and repairs; and for quality controls. We may disclose this identification and electronic network activity information or other data on an aggregated basis without the use of any information that personally identifies you to our affiliated companies, service providers, marketing partners, and government regulators or, when legally required, to law enforcement.
Plug in Information
We may collect information about plugins you might be using, including but not limited to those related to the management of cryptocurrency assets, such as digital wallet addresses, and any information provided by them. This commercial and sensitive financial information is collected both from you and from the third party providing the plug in service. It is used for providing the services to you; security detection, protection and enforcement; quality control; and auditing relating to your transactions and may be disclosed to our affiliated companies, service providers, government regulator or, when legally required, to law enforcement.
Our Sites may collect your general location information (city/state information) when you interact with the Sites. If you provide consent, we may collect more precise location information. This information is used to improve the content we offer; for security detection, protection and enforcement; for ad customization; for internal research, development and repairs; and for quality controls. We may share disclose this geolocation information to our affiliated companies, service providers, marketing partners, and government regulators or, when legally required, to law enforcement.
Information You Provide to Us
Before you can utilize some portions of our Sites or game, we may require that you register with STG and provide us with your contact information and generate a password. This registration identity information, commercial information, and audio recordings may be used, for identification purposes, to communicate with you regarding your account with us, to provide services to you, for security detection, protection and enforcement, quality control and Site functionality, internal research and development, ad customization, compliance with law, and auditing relating to your transactions. It may be disclosed to our affiliated companies, service providers, government regulator or, when legally required, to law enforcement.
We will keep any information that you provide to us for no longer than is necessary in accordance with the purposes for which the information was originally collected.
Social Networking Activities
Our Sites include the ability for you and other users to link to social networking websites. As a result, we may receive information about you when you choose to post or otherwise share information about our Sites on these social networking websites. We may also receive information about you if others share information about you through their social networking websites. We may use such information about you in a variety of ways, including to administer the Sites and enhance your experience with the Sites, ad customization, internal research and development, and to communicate with you about the Sites and new offerings or activities associated with the Sites. We may disclose this information to our affiliated companies, service providers, government regulator or, when legally required, to law enforcement. We may keep all of this information for as long as it is required for the purpose it was originally collected.
We collect your sensitive financial information from you for the purposes of providing services to you, auditing your transactions, quality control, security detection, protection and enforcement and quality control. We may disclose it to service providers, government regulators and, when legally required, to law enforcement.
Information on the Blockchain
STG is a pioneer in using blockchain to support some of its games. Blockchain introduces radical transparency and immutability for data on it (which data could include Personal Information). It is important for you to understand how these characteristics may impact privacy.
- Transparency. Data on a blockchains is or may become public. In other words, if you are transacting on or otherwise interacting with a blockchain, your transaction, certain data, and your associated account is or may become publicly available for others to see.
- Immutability. Generally, the data written to any blockchain is immutable and cannot be erased or altered. This means that once your data is on a blockchain, it may not be possible to remove or change it. This is particularly important if you are transacting on a blockchain.
The transparency and immutability of the blockchain infrastructure may adversely impact your ability to exercise certain privacy rights. For instance, both we and our partners cannot change, correct or delete any information that is stored on a blockchain.
We collect this sensitive blockchain information from you for the purposes of providing services to you, auditing your transactions, quality control, security detection, protection and enforcement and quality control. We may disclose it to service providers, government regulators and, when legally required, to law enforcement.
In addition to information collected online, we collect certain information offline in connection with our employment/staffing and service providers and suppliers. This may include information such as resume information, professional qualifications, references, and sensitive anti-discriminatory information. We may receive this from the individual or a third party in connection with vendor and employment administration and management and may disclose it to benefits partners, service providers, professional advisors, and government regulators.
We do not collect biometric or video information.
Opting Out of Communications and Advertisements
If, having previously provided your consent for marketing, you no longer want to receive emails from STG, you may opt out by clicking the "unsubscribe" link at the bottom of marketing emails you receive or, if you have a registered account, you may log in to your account and make changes to your communication preferences. If you are having difficulty unsubscribing using the above methods, please contact us directly at the email or phone number listed below under "Contact". Please allow ample time for us to process your request. However, please note that even if you opt out from receiving marketing emails, we will send you service-related communications and may need to keep information we have collected about you for record-keeping, research and other purposes.
You can choose to opt out of certain advertisements. You may visit https://www.aboutads.info to learn more about digital advertising and how to opt-out of this advertising on websites by companies participating in the Digital Advertising Alliance (“DAA”) self-regulatory program. If you delete your cookies or use a different browser or mobile device, you may need to renew your opt-out choices exercised through the DAA tool.
Using Personal Information
We will process your Personal Information only where we have an appropriate legal basis to do so. This will generally be where (1) you have provided your consent (which can be withdrawn at any time), (2) where the processing is necessary for the performance of a contract to which you are a party (or to enter into such a contract at your request), (3) where we are required by law, (4) where processing is required to protect your vital interests or those of another person, or (5) where the processing is necessary for the purposes of our legitimate commercial interests, except where such interest are overridden by your rights and interests (as detailed below).
We may use the Personal Information you give us for purposes including the following (among other things), as is necessary for our legitimate commercial interests, or where you have given your consent to such use to the extent required by applicable law (such consent can be withdrawn at any time):
- to respond to your inquiries and to provide you with the information, products and services that you request from us;
- to verify that you qualify as an authorized user of our Sites;
- to send you communications about our own products and services that we think you may find of interest, provided you have not opted out of receiving such communications;
- where the processing is required in order to enforce or apply our Terms of Service and other agreements you have entered into with us; and
- to contact you as necessary.
We may also use the Personal Information we collect in either an identifiable or an anonymized form (independent of any personal identifiers) for purposes including the following (among other things), as is necessary for our legitimate commercial interests or with your consent where required by applicable law (such consent can be withdrawn at any time):
- to administer the Sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve the Sites and to customize the content you see on the Sites;
- as part of our efforts to keep the Sites safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
- to do internal research on our Sites visitors’ interests and behaviors to better understand and serve our members.
Disclosing Information to Third Parties
We will not rent, sell or otherwise disclose any Personal Information that we collect about you through our Sites, except as described above with respect to specific categories of information or in any of the following situations:
- You request or authorize the release of your Personal Information.
- You purchase an item in one of our blockchain-enabled games which uses a third party payment processor or partner.
- You request a Forte Account to allow purchases of digital assets beyond the applicable threshold or in the secondary market in any of our blockchain-enabled games. To set up such an account will require us to share your Personal Information with our partners.
- We may disclose Personal Information that we collect about you to our third-party contractors and payment processors who perform services for us in connection with the Sites, or to complete or confirm a transaction or series of transactions that you conduct with us. We may also disclose Personal Information to service providers or suppliers if the disclosure will enable that party to perform business, professional or technical support for us.
- We may provide your Personal Information to our affiliates, partners and sponsors, so as to provide access to benefits and communicate important information about them (with your consent where required).
- With your consent, we may also provide such Personal Information to other select third parties approved by STG as offering products or services relevant and useful to you. The use by and/or content of communications from any third party will be pre-approved by STG.
- We may disclose Personal Information about you with our professional advisers, or as part of a merger, acquisition or other sale or transfer of the assets or business of STG.
- We may disclose Personal Information about you to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce other agreements you may have with STG, or to protect our rights, property or safety or the rights, property or safety of our users or others (e.g., to a consumer reporting agency for fraud protection). We reserve the right to release information that we collect to law enforcement or other government officials, as we, in our sole and absolute discretion, deem necessary or appropriate. We may also share aggregated or anonymous information that cannot identify you with third parties. For example, we may disclose the number of visitors to our Sites or the number of people who have downloaded a particular document.
While we take steps to protect your Personal Information and keep it secure, you also play a role in protecting your information. You can help to maintain the security of your online transactions by not sharing your account information and password with anyone. You agree to accept responsibility for all activities that occur under your account or password. You agree to notify us immediately of any unauthorized use of your account or any other breach of security. We reserve the right to refuse service, terminate accounts, or remove or edit content at our sole discretion.
Links to Other Websites
If you are under the age of 18, please do not use or access the Sites in any way. It is not our intention to and we will not knowingly collect or use any Personal Information from any child under the age of 18. If we become aware that we have collected any Personal Information from children under the age of 18, we will promptly delete such information from our databases unless they are stored on a blockchain.
Notice to California Residents
Your California Privacy Rights
Under California law, a California resident with whom we have an established relationship has the right to request certain information with respect to the types of Personal Information we have shared with third parties for the direct marketing purposes of those third parties, and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. California residents who have an established relationship with STG may tell us not to share their Personal Information with third parties for marketing purposes. To opt out, you may contact us at any time as described below in the Contact section.
California Consumer Privacy Act
This section provides additional details about the Personal Information STG collects about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.” Subject to certain limitations, the CCPA provides verified California consumers the following rights:
- to request and receive disclosure of our Information Collection Practices during the prior 12 months, including the categories of personal information we collect, the categories of sources of such information, our business purpose for collecting or sharing such information, and the categories of third parties with whom we share such information.
- to request and receive disclosure of our Information Sharing Practices during the prior 12 months, including a list of the categories of personal information sold with the category of third party recipients and a list of the categories of personal information that we disclosed for a business purpose.
- to request and receive a copy of the specific personal information we have collected about them during the prior 12 months.
- to request that we not sell personal information about them and
- to request that we delete (and direct our service providers to delete) their personal information subject to certain exceptions.
Beginning January 1, 2023, California consumers may also have the right to request that we not share information for cross-context or behavioral advertising purposes, that we restrict processing of sensitive information to the purpose for which it was initially collected, and that we correct information that is inaccurate.
For purposes of the CCPA personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.
The CCPA rights described above do not apply to information collected in the employment context about our current, former or prospective employees or contractors (who receive separate disclosures under the CCPA) or to information collected about California business contacts (employees, owners, directors, officers, or contractors of companies, sole proprietorships, and other entities collected in the context of conducting due diligence regarding, or providing or receiving a product or service to or from, such companies, sole proprietorships, or entities). California business contacts have the right to tell us not to sell their information; please see below for how to exercise this right.
For more details about the categories of Personal Information STG has collected, including the sources, used and disclosure of such information please see the “Information we Collect” and “Disclosing Information to Third Parties” sections above. We do not sell (as such term is defined in the CCPA) the Personal Information we collect (and will not sell it without providing a right to opt out).
California consumers may make a request pursuant to their rights under the CCPA by contacting Us at email@example.com. STG will verify your request using the information associated with you, including but not limited to your email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf. We will acknowledge receipt of your request within 10 days and will endeavor to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of our need for additional time. For requests that we not sell your information we will comply with your request within 15 business days. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.
You may make a request for disclosure of our Information Collection Practices, the specific information we collected about you, or our Information Sharing Practices up to twice within a 12-month period. You may make other requests at any time.
For requests for a copy of the personal information we have collected during the 12 months prior to your request we will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.
For requests for deletion of your information please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and to comply with legal obligations. If we receive such a request from you we will notify any service providers we have engaged to delete your information as well.
We will not discriminate against you as a result of your exercise of any of these rights. While STG will process these requests free of charge, should your request be repetitive or manifestly unfounded, STG reserves the right to charge you a reasonable administrative fee for compliance with your request.
Notice to European Residents
For individuals within the European Economic Area (EEA) and the United Kingdom (UK) only. “Personal Information” as used in this section means any information that enables us to identify you either, directly or indirectly. Where STG processes Personal Information about you, such information is controlled by STG, which is headquartered in the United States at 3031 Tisch Way 110 Plaza West - # 139, San Jose, CA 95128.
Subject to applicable law, in certain circumstances you may have the right to (a) request access to any Personal Information we hold about you and related information, (b) obtain without undue delay the rectification of any inaccurate Personal Information, (c) request that your Personal Information is deleted provided the Personal Information is not required for our compliance with a legal obligation under EU, Member State or UK law or for the establishment, exercise or defense of a legal claim, (d) prevent, object to, or restrict processing of your Personal Information, except to the extent processing is required for the establishment, exercise or defense of legal claims; and (e) request transfer of your Personal Information directly to a third party where this is technically feasible. To make a request please email us at firstname.lastname@example.org and provide your name, address, telephone number, and relationship to our company. We will verify your identity before responding for your security.
We will generally ask for your consent in line with the applicable law before sending you direct marketing communications related to third party products and services. You can choose to stop receiving direct marketing communications from us at any time by following the “Unsubscribe” link at the bottom of any promotional email.
Please note that you are not generally obliged to provide us with any Personal Information. However, if you choose not to provide us with Personal Information we may be unable to offer our Services to you.
Access from Outside the United States
If you access the Sites from outside of the United States, information that we collect about you may be transferred and stored on servers inside so called "third countries" where laws regarding data protection may be less stringent than the laws in your country (such as the United States). Where your Personal Information is transferred to such third countries, we will ensure that an appropriate safeguard has been implemented to ensure a continued level of protection of Personal Information. For more information, or to obtain a copy of the relevant safeguards, please contact us using the details below under "Contact".