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Starsand Island Privacy Policy

Effective Date: February 13,,2026

Starsand Island (the "Game") is primarily a single-player game. Online connectivity is limited to optional features such as platform authentication, updates, customer support and user-generated content.This Privacy Policy (the "Policy") explains when, how and why your personal data in connection with the game Starsand Island is processed, whether it is played on PC, or other approved platforms (the “Service”). Please read this Policy carefully as it is important for you to understand how we collect and use your data and how you can control it.
This Policy deals with where Seed Sparkle Lab is acting as a "Data Controller" under the data protection legislation, that is, where we are responsible for deciding what personal data we collect and how we use it. In some cases, our Affiliates may be considered data controllers.
"Personal Data" refers to any information that can be used to identify you either directly or, in combination with other data.
“Players” refer to players on any third-party platform, including, but not limited to, Steam, PlayStation, Xbox, Nintendo.
"Affiliates" refer to entities that directly or indirectly control, are controlled by or are under the common control of Seed Sparkle Lab.
We are committed to protecting and respecting the personal data of everyone we deal with—which is important to both us and you.
In this Policy, you will find information about what types of personal data we hold about you, how and why we collect it, how we use it, and how we keep it secure. You will also find here information about your rights and how you can exercise them.
If you reside or use our Game in a country or region specifically mentioned under the Section "Country/Region-Specific Terms" below, those terms and conditions under the relevant country/region shall specifically apply to you.
Please read this Policy carefully. For any inquiries regarding this Policy or your personal data, contact us by email at service@starsandisland.com

1. Parental and Guardian Consent
OUR SERVICES ARE NOT INTENDED FOR CHILDREN UNDER THE MINIMUM AGE, NOR DO WE KNOWINGLY COLLECT DATA FROM CHILDREN BELOW THIS AGE.
1.1.1You must be at least thirteen (13) years old to use the Game, unless a higher minimum age is required by the laws of your jurisdiction (“Minimum Age”).Without limitation:
1.1.1.1In the European Union, the Minimum Age is sixteen (16) years old, or such lower age (not below 13) as permitted under applicable national laws implementing the GDPR;
1.1.1.2In the Republic of Korea, the Minimum Age is fourteen (14) years old.
1.2 If you discover that a child under the Minimum Age has used our Game without proper supervision, representation or guardianship, please contact us at service@starsandisland.com]. Upon verification, we will promptly investigate and .take reasonable steps to promptly delete such Personal Data in accordance with applicable law.

2. What Data We Collect, How We Use It and The Legal Basis
We collect personal data to the minimum scope necessary for the provision of the Game. The personal data we collect may be provided by you or, in case of usage data, collected automatically when using our Services.
2.1 Game Data
When you play the Game, we may process your:
ŸIdentifiers: Steam, PlayStation, XBOX,Nintendo ID for players (but we do not store it); and
ŸInternet or other similar network activity: gameplay information for players( such as crash logs, error reports, and basic performance diagnostics; and
ŸOther: device, system, and hardware information necessary to perform compatibility checks and ensure the stability, security, and proper functioning of the Game.
The processing activity is necessary for the performance of the contract between you and us, in particular to enable the Game to function properly, maintain stability, detect and resolve technical issues, and ensure compatibility with your device and system environment.
2.2 Payment
ŸIf you purchase our products on third-party Shop(s) (such as the Steam Shop), we may receive limited transaction-related information made available to us by the platform, such as the transaction status, order or transaction identifiers, purchased product identifiers, purchase time, platform identifiers, and other information strictly necessary for order fulfillment, customer support, refunds, and fraud prevention. We do not receive or process your payment instrument details, such as credit card numbers, bank account information, or payment account credentials.
The processing is necessary for our legitimate interests in verifying purchases, providing access to the Game or where applicable, for the performance of the contract.
2.3 Customer support
When you contact us for customer support, we need to collect your personal data,such as:
ŸIdentifiers:email address(if applicable); and
ŸDevice and technical information: basic device or system information provided in the course of troubleshooting (where applicable);
ŸTransaction-related references: order or transaction identifiers, purchased product identifiers (where relevant);
ŸOther: any Personal Data you may provide to us when you contact us.
The processing activity is necessary for us to locate and resolve issues; that is, for the performance of the contract between you and us.
2.4 Marketing Communications
Where permitted by applicable law, we may use your contact information obtained in the context of customer support, such as your email address, to send you marketing or promotional communications related to our products, services, updates, events, or offers.
You may opt out of receiving marketing communications at any time by following the unsubscribe instructions included in such communications or by contacting us directly. Opting out of marketing communications will not affect the delivery of non-promotional messages necessary for customer support or service-related purposes.
your consent, or where permitted by applicable law, our legitimate interests in promoting our products and services, provided that you have the right to opt out at any time.
Our legitimate interests
We also process your personal data based on our legitimate interests as a commercial organization. Our legitimate interests include maintaining and administrating the services, providing the services to you, improving the content of our products and services, ensuring your account is adequately protected, and complying with any contractual, legal or regulatory obligations under any applicable laws.
Other legal bases
Beyond the aforementioned legal basis for processing, we may process your personal data when:
ŸProcessing is necessary for compliance with a legal obligation to which we are subject;
ŸProcessing is necessary to protect the vital interests of the data subject or of another natural person;
ŸProcessing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;
ŸProcessing is for scientific or historical research purposes or statistical purposes in accordance with applicable laws.
For the purposes set forth above, our Affiliates may be commissioned to process your data, provided that such Affiliates comply with the terms in this Policy.

3. To Whom We May Disclose or Transfer Your Data
3.1 We will not disclose or transfer your data to any third parties except as explicitly provided in this Policy. We will share your data with third parties only when:
(i) you (or your parent/legal guardian) have approved;
(ii) as required for administrative or judicial purposes, including any requirements of competent authorities, courts and regulatory bodies;
(iii) necessary to protect our legal rights in proceedings against you;
(iv) permitted under the terms of service;
(v) required to protect our, your, or public interests; or
(vi) pursuant to the agreements made by you with any other third parties.

3.2 We may share your data with our Affiliates, group members, and service providers who will only use your data in accordance with this Policy to facilitate the provision of our Services to you or for other purposes as indicated below.
(i) Affiliates
Seed Sparkle Lab is a global company and has Affiliates all over the world. In order to provide our Services, we will share your personal data with our Affiliates based on the respective legal basis and data processing agreements signed between us.
(ii) Sale or merger
A third party that acquires all or substantially all of us or our business. We will disclose data to a third party in the situation that we sell or buy any business or undergo a merger, in which case we will disclose your data to the prospective buyer of such business. We will also disclose data to a third party if we sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, personal data may be among the transferred assets. You will be notified via email, in-game notice and/or notice on our Website of any change in ownership or users of your personal data.
(iii) Third parties to support our Game
We may engage or partner with third parties to provide services. We share your information with these service providers hosting or operating our Services, rewards, vouchers and delivery of commercial goods (where applicable), cloud services, e-mail communications, security risk control, research, survey, marketing and information analysis services. We share your data only on a need-to-know basis with third parties so that they can perform the relevant functions and services, and we require such parties to take appropriate security measures to protect your data from unauthorized access or processing.

3.3 Except as otherwise provided in this Policy, we will not disclose any data collected from your use of our Services to the public. If public disclosure is required by applicable laws and regulations, we will inform you of the purpose of the disclosure and the type of data disclosed.

4. Data Storage and Retention
4.1 Most game-related data is processed locally on your device. Server-side storage is limited to what is strictly necessary for online features, customer support, and legal compliance.Our Game's servers are strategically located in various countries, including but not limited to the United States, Singapore and Germany. The servers applicable to you depend upon your location.
4.2 We will retain your data only while as needed to provide you with game services unless you request deletion of such data or the law requires otherwise. Retention purposes include:
(i) Achieve the purposes as set out in this Policy;
(ii) Meeting applicable laws and regulations, including any requirements to retain data for a certain period of time, taking into account the statute of limitations under applicable laws and regulations.
(iii) Serving our legitimate and lawful purposes, including for our business, and provision of Service; and/or
(iv) Defend against any actual, threatened or potential claims or disputes.
4.3 If you opt out from marketing, we will retain your data to ensure compliance with your marketing preferences.

5 .International Data Transfer
In order to provide you with the Services and operate our global business,we may transfer your personal data to our Affiliates, third party service providers and partners that operate around the world, which are located in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.We ensure to take appropriate safeguards to keep your personal data protected in accordance with this Privacy Policy such as incorporating standard contractual clauses, before any cross-border transfer of your data takes place.
6 .Data Sharing and Third-Party Disclosures
We only disclose your personal data to third parties when necessary and in compliance with the principles of purpose limitation, data minimization, and accountability:
(i) We may share your data with our Affiliates in other jurisdictions solely for the purpose of providing the Service to you. We implement rigorous internal control measures in place to strictly limit data access to designated personnel only,and all such Affiliates may only use your personal data in accordance with this Privacy Policy.
(ii) To provide Service to you, we may transfer your data internationally to third-parties that provide services in support of the Service, including providers of cloud services, analytics, strictly following international transfer mechanisms permitted under applicable laws and regulations. They are subject to contractual obligations to process such data only in accordance with our instructions and applicable data protection laws.
7.Automated Decision-Making and Profiling
We do not engage in automated decision-making or profiling that produces legal effects or similarly significant effects on players.
Where any limited automated processing is used in connection with the Game (for example, basic technical or security-related functions), such processing does not involve profiling and does not result in decisions that materially affect your rights or interests.
8.Your Rights and Choices
8.1 Under applicable laws and regulations, you may have the right to access, rectification, erasure, and certain other rights in relation to your personal data that we collect and process (hereinafter referred to as the "Request"). These rights will be subject to specific exclusions and exceptions under applicable laws.
(i) You have the right to be informed in a concise, transparent, intelligible and easily accessible form of the way in which your data is processed. You also have the right to obtain confirmation as to whether your data is being processed, and where that is the case, to access such information and obtain a copy thereof.
(ii) You have the right to request rectification of your data. You also have the right to have incomplete data completed, and have the data out of date updated.
(iii) You have the right to request us to erase some or all your personal data.
(iv) Where you have provided your consent, you may withdraw your consent. If you withdraw your consent, we may continue processing your data to the extent permitted by applicable laws.
(v) You have the right to request us to restrict the further processing of your personal data. In such cases, the respective data will be marked as restricted, and may only be processed by us for certain purposes.
(vi) You have the right to object, on grounds relating to your situation, to the processing of your personal data by us, and we may be required to no longer process some or all your personal data. You have the right to object to the processing of your personal data for direct marketing purposes.
(vii) You have the right not to be subject to a decision based solely on automated processing where the decision has a significant legal impact on you.
(viii) You have the right to receive a copy of your personal data which you have provided to us, in a structured, commonly used, and machine-readable format, and you have the right to request the transfer of that personal data to another entity without hindrance from us.
(ix) You can ask us to delete your personal data, which is an irreversible process as you will not be able to access your personal data upon deletion, and all data in relation to your ID or profile will be deleted or de-identified, subject to any statutory retention requirements under applicable laws and regulations.

You may also have other rights as described under the "Country/Region-Specific Terms" section below or otherwise under local laws.

8.2 Before fulfilling your Request, we will verify your identity. We will respond to your Request within legal timeframes. We may refuse your Request (for example, if your Request may infringe on the privacy of others, exceed the provisions of applicable laws, etc.), and when we refuse, we will inform you of the specific reasons. For unresolved concerns, you can hand over the complaint to the data protection regulatory authorities in your jurisdiction. We'll provide relevant complaint mechanism information upon request.

8.3 If you are one of our customers or have otherwise agreed to be contacted for marketing purposes, we may use your personal data to send you information about us and our Services. You can unsubscribe from receiving direct marketing at any time and details of how to unsubscribe will be included in any marketing communications we send you. You also have the option of "unsubscribing" from our mailing list at any time, thereby disabling any further such email or other communication from being sent to you by emailing [service@starsandisland.com].

9.Data Security and Protection
We will take appropriate technical and organizational measures to help protect and secure your data. We will endeavor to protect your data against unauthorized or unlawful processing, accidental loss, destruction, and damage through measures including:
(i) Data encryption;
(ii) establishing specialized systems and procedures, such as strictly limiting the scope of personnel with access to your data and requiring those who have such access to comply with relevant confidentiality obligations; and
(iii) forming a specialized department in charge of information security. In the event of incidents such as information leakage or data or security breach, we will take timely measures to handle such incidents, and we will notify you promptly in an appropriate manner in accordance with applicable laws and regulations.
We collect and process only data needed for Game services by default. Our privacy controls follow this principle - we neither share nor publish your data unless necessary.
While we are committed to protecting your data, no electronic data transmission or storage can be completely secure. If you do not accept these risks and conditions, please discontinue the Game use.

10.Updates to This Policy
We may update, change or modify this Policy from time to time,and such changes shall from a part of this Policy . You'll be notified through Service announcements or login notifications when you log in to or update the software. Updates are effective upon notification and apply to all data unless stated otherwise.
For significant changes affecting your rights, we will notify you and obtain your consent.

11. Contact Information
•For any complaints, suggestions or inquiries regarding this Policy or the collection, usage, storage, protection and other functions of your data, please contract us .
Email address: service@starsandisland.com
We will respond to your inquiry as soon as possible,within the timeframes required by applicable laws.


California Residents
If you are a California resident, you have certain rights regarding your personal data under the California Consumer Privacy Act (CCPA),as amended by the California Privacy Rights Act (CPRA), grants consumers residing in California certain rights with respect to their personal data. We are committed to respecting the following rights and complying with the applicable law.
As a California resident, you may have the right to:
1.Right to Know: Request information about the categories and specific pieces of personal data we have collected, used, or disclosed about you in the past 12 months, including the sources of that information, the purposes of processing, and the categories of third parties with whom your data has been shared.
2.Right to Delete: Request deletion of your personal data, subject to certain exceptions under this Privacy Policy or the law. Please note that deletion may affect your ability to access or use certain Game features.
3.Right to Opt-Out of Sale or Sharing for Business Purposes: You may opt out of the sale of your personal data or certain sharing of personal data for cross-context behavioral advertising. Our Game does not sell personal data and has not done so in the past 12 months. We may share personal data as described in “3. To Whom We May Disclose or Transfer Your Data” for legitimate business purposes only.
4.Right to Correct: Request correction of inaccurate personal data we hold about you.
5.Right to Limit Use of Sensitive Personal Information: You may request that we limit the processing of your sensitive personal information, including data such as racial or ethnic origin, religious beliefs, health data, precise geolocation, or other categories defined under CPRA.
6.Right to Non-Discrimination: You will not be discriminated against for exercising any of your rights under CCPA/CPRA.
For details about the types of personal data we collect, use, and disclose, and the sources of such data, please refer to “2. What Data We Collect, How We Use It and The Legal Basis”.

If you have any questions or require assistance, you may contact us at: service@starsandisland.com
Japanese Residents
If you reside in Japan, by using the Game or related services, you acknowledge and consent that we may process and transfer your personal information to third parties, including cross-border transfers to any country where we or our Affiliates maintain databases or provide services.
This transfer will be conducted solely for the purposes of providing and improving the Game and related services, performing customer support, and fulfilling legal obligations. We implement appropriate safeguards to protect your personal information during such transfers, including contractual, technical, and organizational measures.
You may withdraw your consent to such transfers at any time. Withdrawal of consent will not affect the lawfulness of processing conducted prior to the withdrawal, but it may limit your ability to access certain online features of the Game or related services. To exercise your withdrawal right or for any inquiries, please contact us at service@starsandisland.com.