1. INTRODUCTION
Welcome to the website of Endgame Studio Ltd. ("Company", "we", "our", "us"), BIN: 250440900256.
We are committed to protecting your personal data and respecting your privacy.
This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you interact with our website, applications published on Google Play or AppStore, or any other digital services (collectively referred to as the "Services").
This Policy applies to all personal data collected and processed through any of our digital platforms, including but not limited to:
Website: Access to informational pages, online forms, and account management portals.
Applications: Use of our integrated digital solutions designed for personalized user experiences and secure data management.
We are fully compliant with the Law of the Republic of Kazakhstan "About personal data and their protection", ensuring transparency, accountability, and security in handling your personal data. By accessing or using our Services, you acknowledge and agree to this Privacy Policy.
Our commitment includes:
- Safeguarding your data through robust technical and organizational measures.
- Providing clarity on your rights regarding personal data and how to exercise them.
- Ensuring that any processing of your data is lawful, fair, and transparent.
If you do not agree with the terms of this Privacy Policy, please refrain from accessing or using our Services.
Should you have any questions or require clarification, you may contact us using the details provided in the "Contact Us" section.
2. DEFINITIONS
Personal Data: Any information relating to an identified or identifiable natural person.
Processing: Any operation performed on personal data, such as collection, storage, use, disclosure, and deletion.
Data Subject: An individual whose personal data is processed.
Controller: The entity that determines the purposes and means of processing personal data.
Processor: The entity that processes personal data on behalf of the controller.
Data transfer: Any provision, disclosure, sending, access or other transfer of personal data to a third party or to another jurisdiction, including cases of cross-border movement, carried out in accordance with applicable data protection laws.
3. DATA COLLECTION
We collect and process personal data to provide and improve our Services, comply with legal requirements, and meet our legitimate business interests. This includes information you provide directly, data collected automatically, and information obtained from third parties. Below, we outline the types of data we collect and the methods used:
Categories of Personal Data We Collect
Identification Data: Name, email address, phone number, postal address, and other identifiers necessary to provide our Services.
Technical Data: IP address, browser type, device information, operating system details, and other diagnostic data.
Usage Data: Information on how you interact with our Services, including pages visited, time spent, navigation paths, and actions taken.
Communication Data: Messages sent through contact forms, email, or other communication channels.
AI Conversation Data: Messages, prompts, requests and other content that you submit when interacting with AI-powered features of our Services, together with relevant AI-generated responses and information relating to such interactions.
Payment Data (if applicable): Billing address, payment method details, and transaction history.
Location Data: Precise or approximate location data collected via GPS or other geolocation services, where applicable.
Behavioral Data: Information gathered from cookies, web beacons, and similar technologies to understand user preferences and improve user experience.
How We Collect Data
Direct Input: When you provide information during account registration, form submissions, or customer support inquiries.
AI Interactions: We collect information that you submit when communicating with AI-powered features within our Services. Such information may include the content of your messages or prompts, relevant AI-generated responses, safety signals and moderation outcomes associated with those interactions.
Automated Technologies: Through cookies, server logs, tracking pixels, and analytics tools when you use our website or applications. We automatically collect and store certain types of information about your use of Our Services, including information about your interaction with products, content, and services available through Our Services. Like many websites, we use "cookies" and other unique identifiers, and we obtain certain types of information when your web browser or device accesses Our Services and other content served by or on behalf of on other websites.
Third Parties: From affiliates, service providers, or publicly available sources, including social media platforms, to enhance our understanding of user needs.
Collection Through Digital Platforms
Website: We collect interaction and preference data when you browse or log in.
Applications: Detailed user activity logs, including file uploads, preferences, and custom settings.
Use of Cookies and Similar Technologies
We use cookies, pixel tags, and local storage to:
- Recognize returning users and personalize their experience.
- Analyze website performance and improve our Services.
- Deliver targeted advertisements and measure their effectiveness.
Special Categories of Data
We do not intentionally collect sensitive personal data, such as health information, unless explicitly required and with your consent.
AI conversations may nevertheless contain sensitive or confidential information that users choose to provide. Users should avoid submitting sensitive personal data or confidential information unless it is necessary for use of the Services. Where such information is encountered, we will process it only as permitted by applicable law and in accordance with this Policy.
4. LEGAL BASES FOR PROCESSING
We process your personal data based on the following legal grounds:
- Consent: consent is made on the basis of acceptance, expressed in registration on the site and the creation of an account.
- Contractual Necessity: To fulfill a contract with you or to take steps at your request before entering into a contract.
- Legal Obligation: To comply with a legal obligation.
- Legitimate Interests: For our legitimate interests, provided your rights and interests do not override those interests.
Where permitted by applicable law, our legitimate interests may include providing effective customer support, protecting the safety and integrity of the Services, preventing fraud and abuse, enforcing our Terms and Conditions, and developing, evaluating and improving AI models and related technologies operated by the Company. Where applicable law requires consent or another specific legal basis for a particular use of AI Conversation Data, including model training, we will rely on that basis before carrying out such processing.
5. PURPOSES OF PROCESSING
We use your personal data for the following purposes:
- To provide and maintain our services.
- To manage your account and provide customer support, including reviewing relevant AI conversations where reasonably necessary.
- To communicate with you, including responding to inquiries.
- To analyze usage and improve our website and services.
- To comply with legal obligations and protect our rights
- To protect the safety, security and integrity of our Services and users, including detecting prohibited or unlawful use and attempts to bypass safety systems.
- To enforce our Terms and Conditions, including warnings, restrictions, suspension, or termination for repeated or systematic prohibited use.
- To train, fine-tune, evaluate, test and improve AI models and safety systems operated by the Company using AI Conversation Data where permitted by applicable law.
- To use automated analysis and, where reasonably necessary, authorized human review of AI Conversation Data for support, safety, security and model-improvement purposes.
- To apply reasonable data-minimization, access-control and de-identification measures when using AI Conversation Data for model development, where practicable.
6. DATA SHARING AND INTERNATIONAL TRANSFERS
We are committed to ensuring that your personal data remains secure and is handled in accordance with this Privacy Policy and applicable data protection regulations.
Circumstances of International Transfers
Service Providers: We may engage third-party service providers located in different countries to perform tasks such as hosting, analytics, payment processing, or customer support.
Affiliates and Partners: Personal data may be shared with our global subsidiaries, affiliates, or trusted partners to support our business operations.
Legal Obligations: In certain cases, we may be required to transfer data to comply with legal or regulatory requirements in other jurisdictions.
AI and Model Development Providers: Where necessary for operating AI-powered features, safety systems, or model development workflows, AI Conversation Data may be processed by service providers that provide hosting, model inference, data labeling, evaluation, security or related technical services. Such providers may process the data only for the purposes and subject to the safeguards described in this Policy and applicable contractual arrangements.
Safeguards for Data Transfers
To ensure adequate protection of your personal data during international transfers, we implement the following safeguards:
Adequacy Decisions: Transfers to countries recognized by the European Commission as providing an adequate level of data protection.
Other Measures: Encryption, pseudonymization, and strict contractual obligations with third parties to guarantee data security.
Transparency on Data Locations
In the context of providing services, the Company may transfer personal data internationally, including to countries that do not provide adequate protection of personal data. Such transfer is carried out exclusively to the extent necessary for the functioning of the services.
Personal data of users may be processed and stored in the databases of partner services with which the Company cooperates on the basis of contractual relations. These partners ensure the necessary technical and organizational measures to protect information and comply with applicable privacy and data security standards.
7. DATA RETENTION
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.
AI Conversation Data may be retained for as long as reasonably necessary to provide AI-powered features, respond to customer support requests, investigate safety or security incidents, detect and prevent repeated abuse, enforce our Terms and Conditions, and train, evaluate, test or improve AI models and related safety systems operated by the Company, subject to applicable law and our internal retention practices.
Where an interaction has been identified as potentially involving prohibited or unlawful conduct or an attempt to circumvent our safety systems, we may retain relevant records for a reasonable period even if the associated conversation is no longer otherwise available to the user, where such retention is necessary for safety, abuse prevention, enforcement of our Terms, compliance with law, or the protection of our legal rights.
Where AI Conversation Data has been incorporated into a training or evaluation dataset, we will maintain retention and deletion practices appropriate to the relevant dataset and applicable legal requirements. Where reasonably practicable, we will use de-identification, pseudonymization or other data-minimization techniques before such data is used for model development.
8. DATA SUBJECT RIGHTS
Under Law of Republic of Kazakhstan "About personal data and their protection", you have the following rights:
- Right to Access: Obtain confirmation of whether your personal data is being processed and access your data.
- Right to Rectification: Request correction of inaccurate or incomplete data.
- Right to Erasure: Request deletion of your personal data under certain conditions.
- Right to Restriction: Request restriction of processing under certain circumstances.
- Right to Data Portability: Receive your personal data in a structured, commonly used format and transfer it to another controller.
- Right to Object: Object to processing based on legitimate interests or for direct marketing purposes.
- Right to Withdraw Consent: Withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
To exercise these rights, please contact us at e-mail address: contact@endgame.studio
9. DATA SECURITY
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction.
Access to AI Conversation Data for customer support, safety review, model evaluation or model-development purposes is limited to authorized personnel and service providers with a business need to access such information, subject to appropriate confidentiality, security and access-control measures.
10. COOKIES AND TRACKING TECHNOLOGIES
We use cookies and similar tracking technologies to enhance your experience on our website. For detailed information, please refer to our Cookie Policy.
11. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.
12. CONTACT US
If you have any questions or concerns about this Privacy Policy or our data processing practices, please contact us: contact@endgame.studio