LIGHTNING FORGE GAMES PTY LTD – PRIVACY POLICY
Lightning Forge Games Pty Ltd (ABN 74 678 849 440) (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or collected by us, when providing our website and the game Gladiator Mayhem (Services) or when otherwise interacting with you.
The information we collect
Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.
The types of personal information we may collect about you include:
As a Gladiator Mayhem user, contributor or community member:
- Identity Data including your name, date of birth and images of you.
- Contact Data including your email, phone number and your Discord ID and/or X (Twitter) account details.
- Financial Data including your blockchain or digital asset wallet address or credentials.
- Marketing and Communications Data including your preferences in receiving marketing from us and our third parties, your communication preferences.
- Interactions Data including information you provide to us when you participate in any interactive features (such as surveys, feedback forms, contests, promotions, activities or events), details of products and services we have provided to you or that you have enquired about, our responses to you, support requests you submit to us, and our responses to those requests
- Technical and Usage Data when you access any software or websites we make available to you, details about your use of such platforms, which may include username and password details, your internet protocol (IP) address, your search queries or browsing behaviour (including through the use of cookies, tracking pixels, and other analytics tools).
- Additional Data including personal information that you provide to us through associated applications, associated social media platforms and/or accounts from which you permit us to collect information or any other personal information requested by us and/or provided by you or a third party.
When you visit our website:
- Identity Data including your name and date of birth.
- Contact Data including your email and phone number.
- Marketing and Communications Data including your preferences in receiving marketing from us and our third parties, your communication preferences.
- Technical and Usage Data when you access any software or websites we make available to you, details about your use of such platforms, which may include username and password details, your internet protocol (IP) address, your search queries or browsing behaviour (including through the use of cookies, tracking pixels, and other analytics tools).
Sensitive information: is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. We do not actively request sensitive information about you. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised by law.
How we collect personal information
We collect personal information in a variety of ways, including:
- when you provide it directly to us, including over the phone, over email, or online;
- when you complete a form, such as registering for any events or newsletters, or responding to surveys;
- when you use any software or website we operate and make available to you (including from any analytics and cookie providers or marketing providers. See the “Cookies” section below for more detail on the use of cookies); or
- from publicly available sources.
Why we collect, hold, use and disclose personal information
Personal information: We collect, hold, use and disclose your personal information for the following purposes:
As a Gladiator Mayhem user or contributor or community member:
- to enable you to access and use our website and game, including to provide you with a login;
- to contact and communicate with you about our Services, including in response to any support requests you lodge with us or other enquiries you make with us;
- to notify you of updates to our Services;
- for internal record keeping, administrative, invoicing and billing purposes;
- for analytics, market research and business development, including to operate and improve our Services and associated applications;
- to run promotions, competitions and/or offer additional benefits to you;
- for advertising and marketing, including to send you promotional information about our products and services and other information that we consider may be of interest to you; or
- to comply with our legal obligations or if otherwise required or authorised by law.
When you visit our website:
- to provide our website to you;
- to contact and communicate with you about any enquiries you make with us via our website; or
- to comply with our legal obligations or if otherwise required or authorised by law.
Our disclosures of personal information to third parties
Personal information: We will only disclose your personal information to third parties where it is necessary as part of our business, where we have your consent, or where permitted by law. This means that we may disclose personal information to:
- our employees, contractors and/or related entities;
- marketing or advertising providers;
- professional advisors, bankers, auditors, our insurers and insurance brokers;
- our existing or potential agents or business partners;
- sponsors or promoters of any promotions or competition we run;
- third party service providers including but not limited to IT service providers, data storage, data analysis, web-hosting, server providers, cryptocurrency wallet and hosting providers, digital asset wallet provider, digital asset trading exchange or platform;
- if we merge with, or are acquired by, another company, or sell all or a portion of our assets, your personal information may be disclosed to our advisers and any prospective purchaser’s advisers and may be among the assets transferred;
- 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 or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
- third parties to collect and process data, such as analytics providers and cookies; and
- any other third parties as required or permitted by law, such as where we receive a subpoena.
Privacy of Children
The Services are not intended for children under the age of 18. If we learn that a child under the age of 18 has provided us with personal information, we promptly delete it from our servers. If you are a parent or guardian and you become aware that your child has provided us with personal information, please contact us at the email address available at the end of this policy so that we can take the appropriate action.
Overseas disclosure
We store your personal information in Australia. Where we disclose your personal information to third parties, those third parties may store, transfer or access personal information outside of Australia. We will only disclose your personal information overseas in accordance with the Australian Privacy Principles.
Your rights and controlling your personal information
Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to work with you as a customer or supplier of our business.
Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.
Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.
Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. 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 in response to your complaint. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner.
Storage and security
We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.
User-Generated Content
We may enable you to post reviews, comments, photos, create custom features or additions and other user-generated content, while using our Services. Any content you choose to submit will be accessible by anyone, including third parties not associated with us. We have no control over how others may use or misuse information you make publicly available. We are not responsible for the privacy, security or accuracy of any user-generated content you choose to post or for the use or misuse of that information by any third parties.
Cookies and Analytics
We may use cookies, tracking pixels and similar technologies on our website and in our emails from time to time. Cookies are text files placed in your computer's browser to store your preferences. Tracking pixels are tiny, invisible images (typically the size of one pixel) embedded in web pages or emails. Cookies and tracking pixels, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie or collected by tracking pixels. Unlike cookies, tracking pixels do not store any information on your device, but instead send information to our servers when the pixel is loaded.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.
You can block tracking pixels by using ad-blocking or privacy-focused browser extensions. Some email providers allow you to block images by default, which can prevent tracking pixels in emails from loading.
However, if you use your browser settings to block all cookies (including essential cookies) and tracking pixels you may not be able to access all or parts of our website and you may not receive personalised content.
Google Analytics: We may use Google Analytics Advertising Features. We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together. These cookies and identifiers may collect Technical and Usage Data about you.
You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.
To find out how Google uses data when you use third party websites or applications, please see here.
Facebook/Meta Analytics: We may use tools provided by Meta, such as the Meta Pixel, advanced matching, and Conversions API. These allow us to measure ad performance and deliver ads that may be relevant to you on Meta platforms based on your activity on our website/app. You can control whether we can join data from third party partners with your Meta account for ads by adjusting your preferences within Meta's settings. You can disconnect this data from your Meta account by changing your settings for Off-Facebook activity. For more information, please see Meta's Privacy Policy here.
Links to other websites
Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.
Personal information from single sign-on accounts
If you connect your account with us using a single sign-on account such as Discord and X (Twitter), we will collect your personal information from the single sign-on provider. We will do this in accordance with the privacy settings you have chosen with that provider.
The personal information that we may receive includes your name, ID, user name, handle, profile picture, gender, age, language, list of friends or follows and any other personal information you choose to share.
We use the personal information we receive from the single sign-on provider to link a profile to our platform and to access our services.
If you agree, we may also use your personal information to give you updates on the social network which might interest you.
Use of Artificial Intelligence (AI)
Overview: We may use artificial intelligence and machine learning technologies, including AI Technologies provided by third parties (AI Technologies) in our business operations, game development, and the provision of our Services. We will only use AI Technologies when legally permitted and necessary for our business operations.
How we use AI Technologies: We may use AI Technologies for the following purposes:
- to develop and enhance our Services, including generating and modifying content and coding;
- to capture and analyse individual gameplay patterns, using this data to train in-game AI characters to mimic player behaviour;
- to improve and optimise our services and operations;
- to personalise your gaming experience;
- for quality assurance purposes; and
- to assist with customer support and queries.
Data Protection and Security: Where we use service providers who provide AI Technologies to us, we will take reasonable steps to ensure that such service providers handle your personal information according to privacy law, including by ensuring that we have contracts in place requiring the service provider to protect personal information.
We will not input your personal information into any platform provided by an AI Technology service provider which then trains its model based on that information. Our AI systems are designed to capture and learn from gameplay data without accessing or using customer or client personal information.
Your Rights and our Commitments: We will treat information generated or inferred by the AI Technologies about individuals as personal information and you maintain all rights over your personal information as outlined in this privacy policy, regardless of whether AI Technologies are used in processing. When using AI Technologies with your personal information:
- Transparency and control: we will inform you when AI Technologies are being used to make decisions that may significantly affect you. We will implement processes to verify the accuracy of AI-generated outputs and we will take reasonable steps to maintain human oversight and review of significant AI-generated decisions. Our staff are trained to understand the limitations of AI systems and verify outputs before they are relied upon; and
- Security: we implement appropriate technical and organisational measures to ensure that our use of AI Technologies maintains the security and integrity of your personal information. This includes regular testing and monitoring of AI outputs for accuracy and reliability; and
- Risk mitigation: We regularly assess and document the risks associated with our use of AI Technologies in processing personal information and implement appropriate mitigation measures. This includes ongoing monitoring of AI Technologies and regular reviews of their performance and impact.
Amendments
We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.
For any questions or notices, please contact us at:
Lightning Forge Games Pty Ltd (ABN 74 678 849 440)
Email: hello@lightningforge.games