Privacy Policy

Spotlight Interactive Entertainment Pte. Ltd.

PRIVACY POLICY

Effective Date: October 12, 2024

Spotlight Interactive Entertainment Pte. Ltd. . (“Spotlight,” “we,” “us,” “our”) respects the privacy of our online visitors. This Privacy Policy (“Privacy Policy”) has been adopted on a company-wide basis to guide how we collect, store, use, and disclose the information that you provide to us through our products and services, which include our websites (e.g., www.Skindeer.com ) and online offerings (collectively, the “Services”). This Privacy Policy does not apply to games, websites, products, or services provided by companies that we do not own or control or to individuals that we do not employ or manage.

HOW WE COLLECT PERSONAL INFORMATION

We may collect personal information from various sources, including:

From you. We may collect personal information and other information you provide directly to us or one of our third-party service providers when you use our Services, like creating your Skindeer account, processing transactions, and any other data that you choose to provide online or offline. If you choose to submit any personal information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.

From public or third-party sources. We may collect data from public sources including, but not limited to, social media and other websites that enable social sharing. Personal information may also be available from government agencies, public or third-party information sources, third party service providers, or business partners. We also may collect information from industry groups and associations, or combine information we have collected from multiple sources.

Automatically when you engage with us online. We collect data through our Services and automatically from devices that you use to connect to our Services.

Affiliate Program. We may collect information through our affiliate program. If you are a member of our affiliate program and choose to submit any personal information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.

WHAT PERSONAL INFORMATION WE COLLECT

We may collect different types of personal information when you interact with our Services, including:

Contact information provided by you or from your linked Steam account, such as your name, phone number, email address, and mailing address.

Biographical and demographic information, such as your age date of birth, age, and gender.

Biometric information that uniquely identifies you, such as your facial geometry, which is measured and collected from a driver’s license and/or passport photo. We collect this information through third-party service providers for fraud prevention purposes, and we do not share or sell your biometric information with any third parties.

Account information, such as your username and password, profile details you choose to provide, and feedback and reviews about our products and services or transactions with other users.

Financial information to fulfill your transactions, such as credit or debit card number, crypto wallets or other cryptocurrency-related details, and details of transactions you conduct through our website or through other channels.

Other personal information collected online or offline to help us better identify and offer Services or information that we believe may be of interest to you, or help us better understand your experience with our Services.

Internet usage information , such as details of your visits to our website and information collected through cookies and other tracking technologies including your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.

Location, such as the country from where you are accessing our Services.

Inferences drawn from any of the personal information described above through your use of the Services to create a profile about your preferences, behavior, characteristics, and attitudes. Note, such inferences are only used as described in the “How We Use Personal Information” section below.

We may collect data from any third party accounts you choose to link to our Services, like your Steam account.

HOW WE USE PERSONAL INFORMATION

We process personal information for the primary purpose of providing our Services and operating our business. Generally, we use personal information to:

Process transactions or purchases . We collect payment information to process your transactions and deliver our products and services. We use biometric information to verify your identity in connection with processing transactions and purchases.

Communicate with you. We use your information to respond to your inquiries from you. We may send you administrative communications regarding our Services, including alerts about new features or enhancements. We may also send you notices about special promotions or offers, invitations to participate in surveys about our products or services, and other marketing communications you agree to receive from us.

Security and fraud prevention. We may use personal information to monitor, detect, and prevent fraud and improper or illegal activity protect us, you, third parties, and the public in general.

Comply with law. We may use personal information to comply with applicable law, our legal and regulatory obligations, and participate in litigation or investigations.

We may use and share Non-Identifiable Data (e.g., non-personal, de-identified information that cannot be used to identify you) for any lawful business purpose without any obligation or accounting to you. When we do so, we will take reasonable measures to ensure that the Non-Identifiable Data is not personally identifiable and cannot later be used to identify you.

HOW WE DISCLOSE PERSONAL INFORMATION

We will only share or disclose your personal information for the purposes described below:

Within our family of companies. We share data with other companies in the Spotlight family, including our parent company and any other affiliates.

With your consent. We may share your personal information when we have your consent. You can revoke your consent at any time by providing notice to us at [e-mail]

Service providers. We may employ other companies and people to perform tasks on our behalf, and we may need to share your personal information with them to provide services to you. Examples of service providers include authentication and identification providers (including providers that may process biometric information), advertisers, e-commerce and platform providers, payment processors, authentication services, customer service and support providers, email, IT services, and web hosting companies.

Professional services. We may employ other companies and people that provide professional consultancies on our behalf, such as our auditors or accountants.

Protection of Spotlight. We may also disclose your personal information at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal process to establish, protect, or exercise our legal or other rights or to defend against a legal claim or as otherwise required or allowed by law. We may disclose your personal information in order to protect the rights, property, or safety of a user or any other person. We may disclose your personal information to investigate or prevent a violation by you of any contractual or other relationship with us or your illegal or harmful activity.

Business transfers. In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your personal information may be among the assets transferred. Any acquirer of our assets may continue to process your personal information as set forth in this Privacy Policy.

We take reasonable steps to ensure that any third parties that process your personal information do so in accordance with the representations in this Privacy Policy.

We do not sell your personal information to third parties to use for their own benefit. However, we may allow certain companies to place tracking technologies, like cookies, on our websites. Those companies receive information about your interaction(s) with our websites that are associated with your browser or device, and may use that data to serve you relevant ads on our websites or others. Except for this kind of sharing, we do not sell any of your information. For more information, please see the “Cookies and Other Tracking Technologies” section below. We may also disclose Non-Identifiable Data at our discretion.

IN-GAME COMMUNICATIONS

We do not monitor and/or record your in-game communications in the Counter-Strike 2 game, (previously known as “Counter-Strike: Global Offensive” or “CSGO” and which may be known by other names in the future), including any communications related to transactions that take place on our websites. As a result, you acknowledge and agree that we are not responsible for or liable for such communications.

MARKETING COMMUNICATIONS

You have the right at any time to prevent us from contacting you for marketing purposes. You can opt-out of promotional communications by following the unsubscribe instructions provided in each promotional email that we send to you. We may continue to send you administrative emails; for example, periodic updates to our Privacy Policy or about your Skindeer account, even if you indicate that you no longer wish to receive promotional email from us.

RETENTION

We keep personal information as long as it is reasonably necessary for the purposes described in this Privacy Policy or otherwise in compliance with our or our service providers’ data retention policies. Certain information may be retained until the time limit for any legal challenges has expired or in order to comply with regulatory requirements regarding the retention of such personal information. Spotlight retains biometric information for up to three (3) years following your last interaction with us, subject to other legal obligations. Where applicable, if any personal information that we hold is no longer required for the purpose for which it was collected and no applicable law requires us to retain that information, we will take reasonable steps to de-identify or destroy the information.

YOUR PRIVACY RIGHTS

Depending on where you reside, you may have certain rights and choices regarding our processing of your personal information. These include:

The right to know the categories and/or specific pieces of personal information collected about you, including whether that personal information is sold or disclosed and with whom it was shared;

The right to access a copy of the personal information we retain about you;

The right to request deletion of your personal information;

The right to correct your personal information.

We will verify your identity in connection with any requests and take steps designed to ensure that only you or your authorized representative can exercise these rights. If you are an authorized agent making a request, we may require and request additional information to verify you are authorized to make the request up to and including proof of power of attorney.

There may be situations where we cannot grant your request. Where we deny your request, in whole or in part, we will take steps to inform you of the denial and provide an explanation of our actions and the reasons for the denial.

We will not restrict or deny you access to our products and services because of the choices you make in connection with your personal information, but please note, certain choices may affect our ability to deliver our Services. For example, if you ask us to delete your account, you will not be able to use our Services.

In some cases, we will ask for your consent to process your personal information. Where we rely on your consent to process your personal information, you may withdraw consent at any time. Please note, this withdrawal will not be retroactive.

You may exercise any of your rights in relation to your personal information by contacting us using the details provided in the “Contact Us” Section below.

COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use cookies, beacons, tags, scripts, and other tracking technologies (e.g., Google Analytics) with our Services to help us understand your preferences and improve our Services, like saving your account settings and for authentication. We may also use computer languages to gather the sorts of information described above and other details about your interactions with our Services.

Please note that if you adjust your web browser settings or opt-out of the use of certain cookies from us, some of the functions and features of our Services may not be available to you.

CONTENT THAT YOU PROVIDE

This Privacy Policy applies to how we collect and use your personal information. Please refer to our Spotlight Terms of Service (viewable at https://Skindeer.com/legal/terms-of-service ) for information about our policies and your rights of ownership relating to information, text, avatars from your linked Steam account, and other material or information provided by you, other users, Spotlight, or third parties (collectively, the “User Content”). You understand and acknowledge that User Content you provide when you use our products or services may allow a third party to personally identify or locate you.

CHILDREN’S PRIVACY

We do not knowingly collect or store personal information from children under the age of 16 or under the relevant age threshold in other jurisdictions where the child is located. If you are a parent or legal guardian of a child and believe we have unintentionally collected your child’s personal information, please can contact us at [e-mail]. If we learn we collected personal information from a child without the permission of their parent or legal guardian, we will endeavor to delete that information as soon as possible.

THIRD-PARTY LINKS

We may post links to third-party websites that are not owned or operated by us on our websites. Please be aware that we are not responsible or liable for any content, advertising, products, or other materials from such third-party websites or for any privacy or other practices of the third parties operating those websites.

SECURITY OF YOUR INFORMATION

We take reasonable steps to maintain the security of your personal information; however, no data transmission over the Internet can be guaranteed to be completely secure. Accordingly, we cannot ensure or warrant the security of any information that you transmit or provide to us, so you do so at your own risk.

CONTACT US

If you have a question about how we handle personal information, wish to exercise any of the choices you may have in your personal information, or lodge a complaint about our management of personal information (including if you believe that we have managed your personal information in breach of applicable privacy laws), you may contact us by email at [e-mail] or by sending a letter to:

Spotlight Interactive Entertainmet Pte. Ltd.10 ANSON ROAD,#28-18,INTERNATIONAL PLAZA,SINGAPORE.

In all communications to us, please include the email address used with your account (if applicable), the website address or the specific Spotlight Service to which you provided personal information, and a detailed explanation of your request. We will do our best to respond to all reasonable requests in a timely manner.

CHANGES TO THIS PRIVACY NOTICE

We may change, modify, add, or remove portions of this Privacy Policy at any time. Please refer back to this Privacy Policy periodically to review any updates. The revised version of the Privacy Policy will be effective immediately (as indicated by the “Last Updated” date above) but will not apply retroactively.