Privacy Policy
Your privacy matters to us.
Last Updated on: December 12, 2023
Starflow GmbH ("Starflow", "us", " our" or "we") are dedicated to protecting the privacy rights of our users ("users" or "you"). This Privacy Policy (the " Policy") describes the ways we collect, store, use, and secure the information that you provide or we collect in connection with any Starflow applications provided on any platform (collectively, the "Services"). This Privacy Policy also describes the rights you have. By accessing and/or using our Services, you are expressing that you have read and fully understand the information you shared with us and the rights you have. Please do NOT use or access the Services if you do not agree or have any concerns with this Policy. If you have any questions, concerns or requests about this Policy, you can contact us through the methods described at the end of this Policy.
The Legal Basis of Collecting and Processing the Information
Starflow collects and processes the information users provide in accordance with one of the legal bases set out under General Data Protection Regulation (GDPR) and other applicable laws, regulations, codes and principals. The legal bases which we rely upon are described below:
- Consent: The users have given consent for one or more specific purposes and authorized Starflow to collect and process the information.
- Contractual Necessity: When the data collecting and processing is necessary for the performance of a contract between users and Starflow, or in order to take steps prior to entering the contract.
- Legal Obligation: When the data collecting and processing is necessary for fulfilling a legal obligation to which the Starflow is subject, such as the prevention of crime or fraud.
- Vital Interests: When the data collecting and processing is necessary for protecting the vital interests of the users or of another person.
- Public task: When the data collecting and processing is necessary for performing a task carried out in the public interest or as contained under the official authority given to Starflow.
- Legitimate Interests: When the data collecting and processing is necessary for the purpose of the legitimate interests pursued by Starflow or by a third party, except when such interests are overridden by the interests or fundamental rights and freedoms of the users which require protection of personal data, especially where the data subject is a child.
The Purpose of Collecting the Information
The purpose of collecting the Information are described below:
- to create accounts and allow users to access our application
- to understand users’ preferences so as to enhance users’ experiences and enjoyment by using our Services;
- to make an announcement of promotions, rewards, upcoming events, and other news about our Services;
- to send the related information, including confirmations, invoices, technical notices, updates, push notifications, security alerts, support and administrative messages to the users;
- to operate and improve our Services;
- to resolve disputes;
- to collect fees from users;
- to conduct research, big data analytics and create reports for internal use;
- manage the technical and customer support in order to assist you in solving your technical issues in relation for example to the management of your account or the use of the Services and/or your customer issues in relation to fee claims
The Information We Collect
We collect the following kinds of data when you use the Application:
- your contact data such as your name, email address, and password when you create your account;
- your lifestyle habits such as your frequency of exercise when you fill out the setup questionnaire on the Application onboarding;
- your transaction data such as banking data and billing information when you purchase virtual credits in the Application in order to get access to the Services;
- the content, communications, and other information that you provide to Us when you use the Services including when you sign up for your account, create or share content, and message or communicate with Us and others when you use the chat and/or the support service.
Disclosure of Your information
Starflow does not share, exchange or sell your personal information except as approved by you or as described below:
- With your consent, for example, when you authorize or agree to share your information with other third parties for their own marketing purposes subject to their separate privacy policies. If you no longer wish to allow us to do so, please contact us through the methods described at the end of this Policy. However, you may not be able to access or use some features of our Services. If you no longer wish to receive such communications or ads from third parties, please contact that third party directly.
- Starflow may engage or assign trusted third parties to perform services on behalf of us, including but not limited to analyzing data, sending personalized ads and providing customer support. Starflow will share your personal information with these third parties, but only to the extent necessary to perform such services.
- We may disclose your information as permitted by law, such as to comply with legal process (including subpoenas), or when we believe necessary or appropriate to respond to claims; investigate fraud, respond to a government request, enforce or apply our rights; protect the rights, property, or safety of us or our users, or others. This includes exchanging information with other companies and organizations for fraud protection.
- Starflow may share your information in connection with any merger, sale of assets, reorganization, or a financing or acquisition of all or a portion of our business to another company. You will be notified via email and/or notice on our Sites of any change in ownership or users of your personal information.
- We may share aggregate or anonymous information (sensitive data such as health, motion and fitness information are excluded) about you with advertisers, publishers, business partners, sponsors, and other third parties. If you no longer wish to allow us to do so, please contact us through the methods described at the end of this Policy.
The Rights You Have
- Right to access: You have a right to know what information we hold about you. You can contact us and let us know what information you would like to receive. Before we provide you with any requested information, we reserve the right to ask for reasonable evidence to verify your identity. We will make commercially reasonable efforts to respond to any request for a right of access. The regular processing time might take up to 1 month.
- Right to rectification: You have a right to request us to rectify the information we hold about you. We will make commercially reasonable efforts to keep the accuracy and completion of information that we hold about you. If you realize that any of the information we hold about you is incorrect or incomplete, please contact us and let us know. We will soon respond and rectify the information.
- Right to erasure: Under some circumstances you may have a right to request us to delete the information that we hold about you. You can contact us and let us know what information you would like to delete. You can also ask us to deactivate the account you have previously created. Before we deactivate your account, we reserve the right to ask for reasonable evidence to verify your identity. We will make commercially reasonable efforts to respond to any request and delete the information. To process your request, you must delete our games from your mobile devices and clear our cookies from any device where you have played our games in a web browser.
- Right to restriction of processing: Under some circumstances you may have a right to request a restriction of the processing of the information we hold about you, such as when you are disputing the accuracy or the lawfulness of the information.
- Right to data portability: Under some circumstances you may have a right to request us to provide the information which we have received from you previously, so you can transfer this to another data controller.
- Right to object: You have a right to object to the processing of information we hold about you which is processed on the grounds of legitimate interests.
- Right to opt out of marketing: If you have elected to receive direct marketing communications from us, you have a right to withdraw your consent at any time. You can contact us and let us know you would like to opt-out of receiving promotional emails or notifications from us. We will make commercially reasonable efforts to respond to your request. However, if you choose to opt out of marketing and prevent receiving targeted advertising, you may not be able to access or use some features of our Services. In addition, it may take a few days for us to update our records before any opt out is effective.
In this Policy we have clearly explained (1) what information we collect and process; (2) the purpose of information collection and procession; (3) the legal basis we do so; (4) what and how we are going to use the information you provide; and (5) the rights you have. You have the right to withdraw the consent or to restrict our use of your information at any time in the ways described in this Privacy Policy. However, if you keep accessing and/or using our Services, it is deemed that we have your authority to collect the personal data about you and process it as otherwise described in this Policy. If you do not wish us to collect any personal data about you, you shall contact us and stop using our Services right away.
Security
- Security: Starflow takes reasonable security and technical measures to protect your information from unauthorized access or against loss, misuse or alteration by third parties. Although we make good faith efforts to store the information collected on the Services in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information online and offline, as the internet environment is not secure by its nature and the security risks is constantly evolving. As such you should always take good care when sharing your information online.
Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers" from illegally obtaining access to this information. Starflow does not warrant or hold responsible for preventing your information from loss, misuse, or alteration by third parties.
Data Retention
Starflow will retain your information for as long as your account is active, remained, or as needed to provide you services, or longer period required by applicable law. If you wish to remove your account or request that we no longer collect or use your information to provide you services, please contact us at iflow777888@gmail.com or through the methods described at the end of this Policy. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Our Policy Regarding Children
You must be over a certain age to play and use our Services, depending on where you live and which law applies. We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to use our Services. If you are under 13, please do NOT access, use or provide any information about yourself to us, including but not limited to your name, address, telephone number, email address or any identifiable data.
Once we learn or be aware that we have collected personal data about a child under 13, we reserve full discretion to temporarily suspend or permanently delete the account and all the information that has already been given by or regarding the aforesaid child. If you believe that we might have any information from or about a child under the age of 13, please contact us at iflow777888@gmail.com.
The Right to Refuse to Sell Personal Information
We do not sell your personal information.
Limits of this Policy
Please note that the scope of this Policy is limited to information collected or received by Starflow through your use of our Services. Starflow is not responsible for the actions of third party persons or companies, the content of their sites, the use of information you provide to them, or any products or services they may offer. Any link to any third party site does not constitute our sponsorship of, or affiliation with, those persons or companies. These other sites may place their own cookies or other files on your computer or device, collect data or solicit personal information from you. We strongly recommend you read their privacy statements as we are not responsible for their privacy practices.
Changes to the Policy
Starflow reserves the right to amend this Policy from time to time and we will post the updated Policy on this page. We will also make reasonable efforts to notify you when we release the latest version of our Policy so you may have the opportunity to review the revised Policy before you choose to continue using our Services.
Contact Us
If you have any questions, concerns or requests about this Policy, you can contact us through the methods described below:
1. via email to iflow777888@gmail.com; or
2. via mail at:
- Name: Starflow GmbH.
- Address: Alter Postplatz 2, Stans, 6370.