Last Updated: June 19, 2025

SolunaStar Syndicate, operated by SolunaStar Syndicate Limited (hereafter referred to as “SolunaStar Syndicate”, “we”, “us” and “our”) attaches great importance to your privacy. We create SolunaStar Syndicate Privacy Policy (hereinafter referred to as “this Policy”) in accordance with applicable laws and regulations to sets out why, how and what personal data we collect, use, store, entrust processing, share, transfer and publicly disclose about you when we provide you with our services (the “Service”); the data security protection measures we take; and the rights and methods we make available to you for your access, update, deletion and control of your personal data.

We process your personal data to enable you use our Service through solunastar.com (the “Site”) and other methods which related to our Service. Please read this Policy in combination with SolunaStar Syndicate Terms of Use carefully. If you have any question about this Policy, please contact us through [email protected], we will respond you in time.

By using our Services (as defined in our TERMSOF USE), you acknowledge and agree that you accept the practices, requirements, and/or policies as set out below, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA, YOU MAY NOT BE ABLE TO USE OUR SERVICES.

In order to facilitate your better understanding of our Service and this Policy, we highlight the following content for you.

- As to how to exercise your rights regarding the personal data, subject to applicable laws and regulations, we provide you with methods to exercise your rights to access, correct or modify, and delete your personal data; to withdraw your consent; and exercise any other rights provided by applicable laws and regulations. We will respond to your request timely to ensure that you have control over your personal data.

- Please note that we only provide the Service to those who are at or above the age of majority. You are not allowed to use the Service if you are a minor in your location. SolunaStar Syndicate also does not market to, or knowingly collect personal information from, minors under the age of majority on any sites of the company. If we become aware that we have collected personal information from a minor under the age of majority without verification of parental consent, we take steps to remove that information. In the event that personal data of a minor in your care is disclosed to SolunaStar Syndicate, you hereby consent to the processing of the minor’s personal data and accept and agree to be bound by this Policy on behalf of such minor.

- Please note that this Policy does not apply to data collected by any third party, including through any application or content that may link to or be accessible from or on our Site.

- We will process the personal data about you in accordance with this Policy and the scope of your consent. By accessing or using our Service, you signify that you have read, understand, and agree to our collection, storage, use, and disclosure of your personal data as described in this Policy and our Terms of Use.

- We may organize marketing activities from time to time. We may collect certain personal data from you with your prior consent if you participate in such activity.

1 Personal data we collect

Personal data is information, or a combination of pieces of information that could reasonably allow you to be identified. We collect personal data from a variety of sources, including from you directly, information we generate about you in the course of our relationship with you, and information we collect about you from other sources, including commercially available sources, such as public databases, and third-party services.

Why We Collect Data From You？

We collects data from you for the following purposes:

1. where it is necessary for the performance of our agreement with you to provide and deliver associated content and Services;

2. where it is necessary for compliance with legal obligations that we may be subjected to; and/or

3. where you have given consent to the same.

When Can We Collect Your Personal Information?

We may collect personal information directly from you when you:

1. visit or browse our websites;

2. register and/or use our Services;

3. link your other external accounts to register an account with us;

4. communicate with us (including but not limited to attending to you through our online customer service chats, letters, fax, calls (which may be recorded), emails etc.);

5. register or subscribe for a specific Product and/or Service;

6. participate in any of our surveys;

7. enter into or participate in any competitions, contests run/organized by SolunaStar Syndicate;

8. respond to any marketing materials we send out;

9. lodge a complaint with us;

10. provide feedback to us in any way; and/or

11. submit your personal data to us for any reason.

Other than personal information obtained from you directly (as detailed above), we may also obtain your personal information from third parties we deal with or are connected with you, and from such other sources where you have given your consent for the disclosure of information relating to you, and/or where otherwise lawfully permitted.

What Personal Information Will We Collect?

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use.

We may collect the following information about you:

The account/character information you want to recharge. You need to provide the information about your account/character which you want to recharge, such as your account number, your character id and so on. The specific type of information you need to provide is subject to the content actually displayed on the corresponding webpage.

Contact information. You need to provide your e-mail address to us in order to receive our feedback. When you contact us, if necessary, you may need to provide corresponding information as evidence to prove the problem you encountered and we will also collect chatting records between you and us.

Social Media Login Data. If you choose to register or use our Service by using a third-party social network account (e.g., Facebook, Google), you will provide us or allow to provide us with your possible information related to such account. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform. If you are using the Service only as a visitor, you are not required to provide the information described in this paragraph.

Transaction information. We will collect transaction information, such as order number, purchase amount, purchase history, date of purchase, the content of the goods and/or services that you are purchasing and so on, in order to pursue our legitimate interests and to abide by our contractual obligation to help you use the Service.

Technical information. We collect certain information when you use the Service, such as your IP address, GAID, network type, carrier, operating system, system language and region.

User activity information. We collect your activity information during your use of the Service, such as your log in history, sharing history, browsing history.

Please note that: If you have provided us with personal data of third-party individuals, you are required to obtain the individual's prior consent and you represent and warrant that you had or have their consent or are otherwise entitled to provide their personal data to us. By providing us with personal data of third-party individual(s), you also warrant that the individual(s) is informed of and consents to the terms of this Policy.

2 How we use your personal data and the legal basis on which we use it

We may use your personal data for the following purposes:

Identification and authentication. We use your personal data to verify your identity, create a profile for you when you register, access and use our Service, identification,, due diligence or known your customer purposes;

Contractual obligations. We use your personal data to meet our contractual obligations to you under our Terms of Use or to take steps at your request prior to entering into such contract;

Service operations. We process your personal data to provide the Service (Including our marketing activities) that you request, such as complete your recharge request; process and verify your online transactions and payments on SolunaStar Syndicate;

Service improvements. We analyse usage information, including site analytics (including but not limited to data analytics, surveys, products and service development and/or profiling), to analyze how you use our Services, to recommend products and/or services relevant to your interest, to continually improve the user experience; to carry out data analysis for advertising, and to protect you from fraud, phishing or other misconduct.

Communications. Communications may include providing information about changes to the terms and conditions, updates regarding our Service, or responses to questions you pose;

Advertising and marketing. We may use your personal data to build a profile about you, to understand your preferences, and to help determine which marketing materials (for example, region- or sector-focused) would be of interest to you. Where required by law, we will obtain your consent before sending such marketing materials;

Exercising our rights. We may use your personal data to exercise our legal rights where it is necessary to do so, for example to detect, prevent, and respond to intellectual property infringement claims or violations of law;

Complying with our obligations. We may process your personal data to carry out fraud prevention checks or respond to legal processes or to comply with or as required by any applicable laws, governmental or regulatory requirements of any relevant jurisdiction, or where we have good faith to believe that such disclosure is necessary under any applicable law. This includes but not limited to in response to subpoenas and other legal demands, and where we believe that disclosing this information is necessary to identify, contact or bring legal action against individuals who may be endangering public safety or interfering with SolunaStar Syndicate services, or with our customers’ or others’ use of them;

Keep security. We may use your personal data for risk management and operation detection purposes, so as to ensure the security of your use of the Service;

Any other purposes which we notify you of at the time of obtaining your consent.

At any point of time, should you feel the need to opt-out future communications with SolunaStar Syndicate, options are given within to exclude those communicated messages to you.

We may process your personal data in connection with any of the purposes set out above on one or more of the following legal grounds:

- To perform our obligations under a contract with you. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.;

- To comply with our legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved, or to keep records of our compliance processes or tax records;

- To pursue our legitimate interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interest do not outweigh your interests and fundamental rights and freedoms. For example, we have a legitimate interest in promoting and marketing our services to existing and potential customers; or

- To protect Vital Interest. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

- Based on your consent to process your personal data in that manner. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.

3 Information we share (If Needed)

We will only share your personal data with third parties in the following circumstances:

- Merchant of Digital Product. When you purchase any gift codes, app/game credits, or vouchers (“Digital product”) on the Site, we will share your personal data with the merchant who provides the Digital Product. This is necessary to help you complete the transaction.

- Payment aggregator. We may share your personal data, such as order information, profile Information, with payment aggregator, in order to verify and facilitate the transaction. We will not collect your bank account, swift code, IFSC code, etc.

- Our affiliate companies, joint venture partners. We may share your personal data with them, in each case, we will require those affiliates to honor the terms of this Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

- Our Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

- Courts, law enforcement authorities, regulators, government officials or other competent authorities, or, as we deem necessary in our sole discretion. We may share with them where it is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim, including in order to protect the legitimate rights and interests of you and others.

- Service providers which we engage to process personal data for any of the purposes listed above on our behalf and in accordance with our instructions only, such as licensed payment service providers, cloud storage providers, Communication & Collaboration Tools, Data Analytics Services, Data Storage Service Providers, Finance & Accounting Tools, Performance Monitoring Tools, Social Networks. Ad Networks, Testing Tools, User Account Registration & Authentication Services, Website Hosting Service Providers, Products Engineering & Design Tools, Sales & Marketing Tools, etc; and/or

- Prospective sellers or buyers of any of our business or assets to which we might assign or novate any of our rights and obligations; in such case we may disclose your personal data to the prospective seller or buyer of such business or assets.

You can visit or use other third-party services through our website. Please note that any information you provide directly to third-party providers is not covered by this Policy. We are not responsible for the privacy or security practices of other third parties with whom you choose to share your personal data directly. We encourage you to review the privacy policies of any third party to whom you choose to share your personal data directly.

4 Where and how long do we keep your personal data

The personal data we collect may be transferred to and stored outside of the country you use our Service for the purposes specified in this Policy. For example, we store all of our data, including personal data on a server located in Singapore.

Any international transfers of your personal data will be made according to appropriate safeguards under the applicable laws and regulations. If you wish to enquire further about these safeguards used, please contact us using the details set out in section 8 of this Policy.

Your personal data will be retained only for as long as necessary for the purposes for which the information was collected and processed, except where necessary to meet our legal obligations or to establish, exercise or defend potential legal claims or to pursue our legitimate interests.

If you terminate your account with us, all personal data will be deleted except if it is required by legal process or any other legitimate reason as SolunaStar Syndicate deems necessary. If you choose to object to the processing of your personal data, we will delete your data within a reasonable period, except if it is required by law to retain the same.

5 Your rights

You have certain rights regarding the personal data we hold about you, subject to local law. These may include the following rights:

(a) access – confirm whether your personal data is processed by us, and if it is, to request a copy of your personal data and information relating to how it is processed;

(b) rectify – request any inaccuracies in the personal data we hold about you be corrected or any incomplete personal data we hold about you to be completed;

(c) erase – in certain circumstances, request that we erase your personal data from our records;

(d) restrict – in certain circumstances, request that your personal data is no longer processed by us;

(e) object – where we process your personal data on the basis of our legitimate interests, you have the right to object to this. However, we may continue to process your personal data if you have objected where we have compelling legitimate grounds to continue such processing or for the establishment, exercise or defence of legal claims;

(f) direct marketing - you have the right to ask us to stop processing your personal data for direct marketing purposes;

(g) portability / transfer – in certain circumstances, request to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to you or another third party you have chosen;

(h) withdraw your consent – where we are relying on your consent to process your data, then you can withdraw your consent at any time;

(i) automated decision making - in certain circumstances you have the right to request that you are not subject to automated processing of personal data, which produces a legal effect or similarly significantly affects you; and

(j) lodge a complaint – you have the right to lodge a complaint with your local data protection authority.

If you would like to discuss or exercise any rights you may have under law, please contact us at the contact details below.

To withdraw your consent or to exercise any of the rights above, if they are applicable, you should use our contact details set out in section 8 below.

6 Security

We are concerned about safeguarding the confidentiality of your personal data. We employ administrative, physical and electronic measures designed to protect your personal data from unauthorized access and use. Please be aware that no security measures that we take to protect your personal data are absolutely guaranteed to avoid unauthorized access or use of your personal data which is impenetrable.

noneOnce you have any security information,such as your User ID, Password, Security Device and/or Security Code, you should be careful to ensure that they are not compromised by making sure that you do not knowingly or accidentally share, provide or facilitate unauthorized use of it. Do not share these details with others, or allow access or use of them by others. Both of us together play an important role in protecting against online fraud.

If you click a link to a third-party site, you will be leaving SolunaStar Syndicate and we don’t control or endorse what is on third-party sites.

7 Sensitive Information

We ask that you not send us, and you not disclose, any sensitive personal data (e.g., information related to your e-wallet password, credit or debit card password, racial or ethnic origin, political opinions, religion or other beliefs, health, sexual orientation, criminal background or membership in past organizations, including trade union memberships) through SolunaStar Syndicate to us, unless such information is required by us for legal compliance checks.

8 Contacting Us

If you have any questions, complaints or comments about this Policy or our privacy practices, or to report any violations of this Policy, please contact us at: [email protected]. We will respond within a reasonable timeframe.

9 Changes to This Privacy Policy

We reserve the right to amend this Policy from time to time to reflect any changes to the way how we process your personal data or changing legal requirements without any prior notice to you. Any amendments will be made available and published on solunastar.com and will indicate the effective date. You may determine if any revision has taken place by referring to the date that this Policy was last updated. We recommend that you check this Policy periodically to review the latest version. The most current version of this Policy will govern our use of your information. Please check back frequently to see any updates or changes. This Policy was last effective on the date provided at the top of this page.