We are committed to respecting and protecting your privacy and complying with any applicable law and regulation regarding your personal information. This Privacy Policy describes how we collect, use, disclose, and protect your personal information, including across our website https://staratlas.com/ (the “Website”), the Star Atlas game, and all other content and functionality accessible via our Website and the Star Atlas game other than the Star Atlas DAO (as defined below) (collectively, the “Services”), in each case operated by or on behalf of ATMTA, Inc. (“we,” “us,” “our”), a Delaware corporation.

For information regarding the collection, use, disclosure, and protection of your personal information with regard to content and functionality offered by the decentralized autonomous organization that governs the Star Atlas game and metaverse and which is accessible at the website https://govern.staratlas.com (the “Star Atlas DAO”), please refer to the Privacy Policy applicable to the Star Atlas DAO (located at https://govern.staratlas.com/privacy-policy).

Please read this Privacy Policy carefully. If you do not agree with this Privacy Policy in general or any part of it, you should not access the Website, use our Services, or otherwise provide your information to us.

Information We Collect

Information we collect falls into one of two categories: “automatically collected” information and “voluntarily provided” information.

“Automatically collected” information refers to any information automatically sent by your devices in the course of accessing our Services.

“Voluntarily provided” information refers to any information you knowingly and actively provide us when using or participating in any of our Services.

Automatically Collected Information

When you visit our Services, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, geolocation data, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the referring site, website elements clicked, and other details about your visit.

Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.

Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

When you visit our website or interact with our Services, we may automatically collect data about your device, such as:

• Device Type
• Operating System

Voluntarily Provided Information

We may ask for personal information — for example, when you register an account, make a purchase, request support for our Services, or when you otherwise contact us, including on Discord — which may include one or more of the following:

• Name
• Email address
• Discord username, if you interact with us there
• Digital Asset Wallet Address
• Other information necessary for Anti-Money Laundering (“AML”), Counter Financing of Terrorism (“CFT”), and Know Your Customer (“KYC”) compliance purposes
• Any other information you choose to provide, such as when you fill in a form, file a support ticket, provide screenshots, conduct a search, update or add information to your account, respond to surveys, participate in promotions, correspond with us, or use other features of our Services.

Third-Party Information

We may combine voluntarily provided and automatically collected personal information with information that is publicly available (such as on social media) or that you provide to third parties that they share with us. For example, we obtain your Digital Asset Transaction History, as it relates to Star Atlas tokens, from your wallet provider.

Collection and Use of Information

We may collect personal information from you when you do any of the following on our Services:

• Register for an account
• Use a mobile device, personal computer, or web browser to access our Services
• Contact us via email, social media, chat programs, or on any similar technologies
• When you mention us on social media

We may use information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

• to provide you with our Services
• to enable you to customize or personalize your experience of our Services
• to operate, improve, and develop our Services
• to contact and communicate with you
• to enable you to access and use our Services, associated interactive features, associated applications, and associated social media or chat platforms
• to comply with our legal obligations and resolve any disputes that we may have
• for security and fraud prevention, and to ensure that our sites and apps are safe, secure, and used in line with our Terms of Use

Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.

Although we will implement and maintain practices to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. Any information you transmit to us you do at your own risk.

You are responsible for selecting any password, to the extent one is required, and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, you are responsible for ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.

How Long We Keep Your Personal Information

We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this Privacy Policy. For example, if you have provided us with personal information as part of creating an account with us, we may retain this information for the duration your account exists on our system. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you.

Children’s Privacy

We do not aim any of our Services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database.

If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

Disclosure of Personal Information to Third Parties

We may disclose personal information to third parties in the following circumstances:

• with our parent, subsidiary, and/or affiliated entities;
• with service providers for the purpose of enabling them to provide our Services, including 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;
• advertising partners;
• our employees, contractors, and/or related entities;
• 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, or any obligations arising thereunder, or in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights or those of a third party;
• to prevent physical harm, financial loss, or fraud on our Services; and
• an entity that buys, or to which we transfer, all or substantially all of our assets and business.

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 contacting us using the details below.

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 may also have the right to contact a regulatory body or data protection authority in relation to your complaint. Please see the EU/UK Addendum for further detail.

Use of Cookies and Tracking Technologies

Our website, like most websites, uses cookies, pixels, and other tracking technologies (“Tracking Technologies”) to collect information about you and your activity across our site. A cookie, for example, is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. A pixel is a small portion of code that we use as part of our Services. We use pixels to learn whether you have clicked on certain web content. This helps us measure and improve our services and personalize your experience. Tracking Technologies help us to improve our Services including by conducting statistical analyses, estimating audience size and usage patterns, and identifying a user’s digital asset wallet address and wallet provider.

You may control the way in which your devices permit the use of cookies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of our Services to work incorrectly or you to be unable to access certain parts of our website.

Most browsers accept cookies automatically. However, you may be able to configure your browser settings to use our Services without some cookie functionality. You can delete cookies manually or set your browser to automatically delete cookies on a predetermined schedule. For example, in the Chrome menu bar, select: More → Settings → Privacy and security → Cookies and other site data → See all cookies and site data, where you can choose to allow or block all or certain cookies, and choose to clear cookies when you quit Chrome.

For more information on how to manage your browser settings, please see below:

• Cookie settings in Internet Explorer
• Cookie settings in Edge
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari

Business Transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy or an insolvency proceeding, 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 Privacy Policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.

Third Party Websites and Links

Our Services may link to or interact with third party sites or services, such as your wallet provider, or chat platforms, such as Discord, that are not operated by us. Our inclusion of such links or use of such services or platforms does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on our Services. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy. 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. This Privacy Policy does not apply to any of your activities after you leave our Services.

User-Generated Content

Please note that we do not control who will have access to the information that you choose to make available to others and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the features permitting creation of User-Generated Content (“UGC”) or what others do with information you share with them on such platforms. We are not responsible for the accuracy, use, or misuse of any UGC that you disclose or receive from third parties through social media or discussions on our Services.

California Privacy Rights Addendum

Under the California Consumer Privacy Act (“CCPA”), California residents are afforded certain rights about Personal Information (as the term is defined under the CCPA) that we collect, use, and share about them, which we have described in more detail below. For the purposes of this section, Personal Information does not include information exempted from the scope of the CCPA.

In the preceding 12 months, we collected, disclosed, and sold the following Personal Information of California consumers.

As a California resident, you may have the rights listed below in relation to the Personal Information we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Information: You can request information about how we have collected and used your Personal Information during the past 12 months, including the categories of personal information that we have collected; the sources of such personal information; the business or commercial purposes for which we have collected such personal information; the categories of personal information that we have sold or disclosed; and the categories of third parties to whom we have sold or disclosed the personal information.
• Access: You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Deletion: You can request that we delete the Personal Information that we have collected from you.
• Opt Out: You have the right to opt out of the sale of your Personal Information to third parties. To opt out of the sale of your Personal Information, please click the “Do Not Sell My Personal Information” link or submit a request using one of the methods outlined below.

We will not discriminate against you for exercising any of your rights under CCPA. 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.

To exercise any of your rights, you may contact us via email at contact@staratlas.com or by calling us toll-free at 885-568-6382. If you wish to request that we not sell your Personal Information, please click the “Do Not Sell My Personal Information” link. We may need to collect information from you to verify your identity, such as your email address, government issued ID, or date of birth, before providing a substantive response to a request. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

Your browser settings may allow you to transmit a “Do Not Track” signal when you visit various websites. Our mobile application is currently not designed to respond to “Do Not Track” signals. Our website is designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

EU/UK Addendum

We process your personal information in order to perform our contract with you, such as:

• register and maintain your account with us
• provide you with our Services, other content, and website functionality
• to enable you to access and use our Services, associated applications, and associated social media platforms

We obtain your consent to process your personal information for the following reasons:

• sign you up for marketing communications
• personalize our Services for you
• if you opted into marketing, to communicate with you about products, services, marketing, promotions, events, and other news and information we think will be of interest to you

In order to be responsive to you, to provide effective services to you, and to maintain our business relationship, as a matter of our legitimate interests, we will use your personal information to:

• to contact and communicate with you

We may also use your personal information to comply with our legal obligations (such as compliance obligations) and resolve any disputes that we may have. We may also process your personal information for security and fraud prevention, and to ensure that our sites and apps are safe, secure, and used in line with our Terms of Use.

The personal information that we collect from you will be transferred to and stored at/processed in countries outside the European Economic Area (“EEA”) and the United Kingdom (“UK”). Your personal information is also processed by staff operating outside the EEA and the UK who work for us or one of our third party service providers or partners. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy.

For any transfers of data outside the EEA or the UK, the data transfer will be under the European Commission’s model contracts for the transfer of personal information to third countries (i.e., the standard contractual clauses) (the “Model Clauses”), or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals’ rights and freedoms for their personal information. Please contact us at contact@staratlas.com should you wish to examine a copy of the Model Clauses.

If you are located in the EEA or the UK, you have certain rights in relation to your personal information:

• Access: You have the right to access personal information we hold about you, how we use it, and who we share it with.
• Portability: You have the right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
• Correction: You have the right to correct any of your personal information we hold that is inaccurate.
• Erasure: In certain circumstances, you have the right to delete the personal information we hold about you.
• Restriction of processing to storage only: You have the right to require us to stop processing the personal information we hold about you, other than for storage purposes, in certain circumstances.
• Objection: You have the right to object to our processing of your personal information.
• Objection to marketing: You can object to marketing at any time by opting out using the unsubscribe/ opt-out function displayed in our communications to you.
• Withdrawal of consent: Where we rely on consent to process your personal information, you have the right to withdraw this consent at any time by emailing us at contact@staratlas.com.

Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests, or where we are required by law to retain your personal information.

To exercise any of these rights, you can email us at contact@staratlas.com. We will respond to requests to exercise these rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances).

If you have complaints about how we process your personal information, please contact us at contact@staratlas.com and we will respond to your request as soon as possible.

If you think we have infringed data protection laws, you can file a claim with the data protection supervisory authority in the EEA country in which you live or work or where you think we have infringed data protection laws, or with the UK Information Commissioner’s Office, as applicable to you.

Changes to This Policy

At our discretion, we may change our Privacy Policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this Privacy Policy, we will post the changes here at the same link by which you are accessing this Privacy Policy with the last revised date. Updates to our Privacy Policy will apply only to information collected after the date of the change.

Please check the website regularly for notices of changes to our Privacy 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.

Contact Us

Should you have any questions about our privacy practices or this Privacy Policy, please email us at contact@staratlas.com or call us toll-free at 885-568-6382.