Privacy Policy
Thank you for using Stash! We are committed to protecting your privacy. Within the Stash Privacy Policy (“ Policy”), Fractal Wagmi Inc. (dba Stash)( “we,” “our,” and “us”) describes how we collect, use, share and disclose personal data that we receive from you when you visit www.stash.gg and any other web pages and subdomains we create or host (the “Site”) and sources that link to this Policy or when you otherwise access any material features we make available to you within our Services (altogether “the Platform”). Where we need to collect Personal Data to deliver Services or allow Platform access, and you fail to provide that information when requested, we may not be able carryout the contract you intend to form with us. In this case, we may have to cancel a process, but we will notify you if this is the case at the time.
By continuing to access or use our Services after we post amended versions of this Policy, you confirm your understanding of the Privacy Policy, as amended. If you do not agree with this Privacy Policy, do not access or use our Services or interact with any other aspect of our business. Individuals under the age of 18 are not allowed to use our Site or the Services. Our Platform and Services are not directed at nor targeted to children under the age of thirteen (13). If you have not reached eighteen (18) or the age majority or cannot enter into legally binding agreements in your country, you may not use the Platform without adult supervision. If you believe that we have received information from a child or other person protected under such laws, please notify us immediately contacting us. We will take reasonable steps to remove that information from our databases. Please note capitalized terms not defined in this Policy have the meaning provided in the Stash Developer Terms and Conditions.
HOW PERSONAL DATA IS COLLECTED
DATA COLLECTION
Stash collects your Personal Data if you visit the Site or access the Platform, including by paying for Customer Content as a guest user or inputting payment details, signing up for a Stash User Account, registering for an account to use the Services as an Authorized User of a Customer that has a Platform Account or otherwise accessing the Services through a method that links to this Policy. When you form a relationship with Stash, we are generally, within the meaning of applicable laws, the “data controller” for Personal Data collected as described in this Policy. This Policy does not cover personal data that we process as a service provider or “processor” as defined under applicable laws, for a Customer that has licensed the Services.
The specific information collected about you depends on how the relationship with Stash is formed and how much information is reasonably necessary to provide the Platform or access to the Services. For clarity, we have grouped the sample of Personal Data we may collect, use, store and transfer as follows:
Contact and Identification Information:
First and last name
Email address
Phone number
Country of residence
Unique identifiers (e.g. advertising ID)
Verification Data:
Date of birth
Business name and Tax ID (for business entities)
Identity documents (e.g., passport, driver's license, government-issued ID) for payment processing purposes
Payment Data:
Payment method and hashed instrument number, security code and expiration date
Bank account details and data necessary for payment and invoicing (for Authorized Users)
Device Data:
Device ID, model, manufacturer
Browser type
Operating system version domain server
Location data and internet protocol (IP) address
Interaction Data:
Web pages visited/actions
Referring web page sources
Device/browser interaction statistics and clicks Request IDs
Cart selections
Order and purchase history
Transaction details
Other Voluntary Data:
Voluntarily provided information about your interests, demographic details (e.g. gender, lifestyle interests) such as in messages, inquiries and surveys and in interactions with advertising and marketing where you have expressed your interest and have provided us with your identity information
Third-Party Data:
Credit agency and law enforcement, etc.
Social media profile information such as username (per your settings with those services)
Third-party ID or log-in ID with profile information (per third-party settings)
Marketing Preferences and Consents:
Your preferences for receiving marketing communications from us and third parties
The consent or choices as to how information should be usedInferences:Inferences drawn about you and your likely preferences, characteristics, behavior, and attitudes from any information we collect about you.
Third-Party Services
The Platform may contain links to other third-party services that we do not control, including websites, mobile applications or online services operated by other entities. We are not responsible for their actions. We encourage you to read the privacy policies for those third-party services. When you are buying items such as virtual and digital goods the Customer Site or subject to their terms, you should check the privacy policies of Customers to understand how they may use your Personal Data. Also, we use third-party processors to collect payment information (such as a valid credit card number, type, expiration date or other financial information) to process payments, if applicable. It may be submitted directly to our third-party payment service provider or processing company (the “PSP”), which processes your payment. The use and storage of that information is governed by the PSP’s applicable terms of service and privacy policy (read relevant PSP’s Privacy Policy).
Data Collection through Cookies and Tracking Technologies
Like most websites, we use cookies and similar tracking technologies to gather data that helps us analyze traffic patterns, identify popular features and generally improve your user experience. Specifically, we use “cookies”, alphanumeric identifiers that we transfer to your device through your web browser to enable our system to recognize you and your personalized settings, better understand how you interact with the Platform and optimize web traffic routing. We may also use pixel tags, web beacons, session logs, and similar technologies to understand how our users interact with our Platform and emails. To learn more, please read the Stash Cookie Statement.
HOW PERSONAL DATA IS COLLECTED
The types of information that we collect depend on how you use the Services and interact with us.
We collect personal information that you voluntarily provide to us when you create or modify your account for the Services, while you access and use the Platform or interact or correspond with us or with other users of the Services. Please be aware that any information you submit to these collaborative areas may be visible to other users of the Platform. To protect your privacy and that of others, we recommend using discretion when sharing personal details. We strive to maintain the confidentiality of all user data, but cannot guarantee the actions of other users regarding information you voluntarily disclose in public areas of the platform.
We also automatically collect certain technical data, like Device Data and Cookies and Tracking Data described below in the section on Cookies. We may also obtain information about you from other sources, including Public Source Data and Third-Party Plugin Data when linking your third-party accounts on websites, mobile applications and other online services operated by third parties, including mobile game accounts and social networks.
USE OF PERSONAL DATA
We use your Personal Data for various purposes related to providing and improving our services. We may use your information to create aggregated and anonymized data, which is not considered personal data under applicable laws, as it can not directly or indirectly reveal your identity. For example, we may aggregate your information to calculate the percentage of users accessing our Site or may create artificial intelligence models to prevent fraud in the Platform.
Stash uses Personal Data for the following purposes, including but not limited to:
Business Operations and Service Improvement
- Informing our business strategy, including marketing, service improvements and new product development
- Creating and maintaining accounts with third parties, including making the Services available to you as an Authorized User
- Creating and disclosing insights to Customers about your Sales Activity and use of the Services
- Maintaining the security of Personal Data and the Platform
- Detecting, investigating, and preventing fraud and other illegal or unwanted activities
- Ensuring business continuity
Transaction Processing and Account Management
- Facilitating and enabling online financial transactions and Sales Activity
- Providing, operating, maintaining and monitoring the performance of an account held by Customer or a Consumer
Customer Support and Communication
- Responding to your inquiries and requests
- Offering customer support or technical support and
- Sending periodic transactional emails and, with your consent, marketing communications (which you can opt out of at any time by selecting unsubscribe or accessing preference.)
Legal and Compliance
- Enforcing our agreements
- Complying with legal and regulatory obligations, such as calculating taxes on Sales Activity
- Handling legal claims and disputes
Automated Decision-Making
We may use some personal data in automated decision-making processes to screen accounts for risk, fraud or abuse concerns. Subject to applicable laws, you can object to profiling done for marketing purposes, contest or disputin decisions generated through automated means, seek information about the automated decision-making process, and request that we rectify any inaccuracies. When your requests creates restrictions are not possible for Stash to implement and fulfill a contract, we will advise you accordingly. You can then choose to exercise any other rights under this Policy.
HOW WE SHARE PERSONAL DATA
With Customers or Game Partners and Their Providers
We share Personal Data with our Customers, such as game developers and others that use Stash-powered webshops and checkout features and integrations, to, for example, complete a transaction to purchased virtual or digital goods that will be available for use on Customer Site. Data sharing with Customers includes transfers to their vendor service providers and other third parties acting under Customers direction.
With Our Vendors and Service Providers
We share information with providers who process Personal Data on behalf of Stash to deliver our Services and operate the Platform. Generally, vendors will process your Personal Data to deliver the solutions they agree to offer us and carry out their work function. For example, we use service providers for data hosting, application development, advisory services, disaster recovery, customer support, payment facilitation and processing by PSPs, and monitoring compliance with applicable laws and Card Network rules. A subset of vendors include: i) marketing and advertising providers so we can both market our products to you, even across third-party websites, for instance, when you consider signing up for our Services; and ii) third-party analytics providers who may deploy cookies, pixels, and similar technologies to analyze traffic to the Services and understand the performance of advertisements about our business.
Business Transfers and Affiliates
If Stash is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different privacy policy. We may also share your Personal Data with Stash affiliates for purposes consistent with this Policy.
Law Enforcement and Other Legal Requirements
Under certain circumstances, Stash may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Stash may disclose your Personal Data in the good faith belief that such action is necessary to: i) comply with a legal obligation; ii) protect and defend the rights or property of Stash; iii) prevent or investigate possible wrongdoing in connection with the Platform; iv) protect the personal safety of the public or any user of the Services; or v) protect against legal liability.
With Others With Your Consent or At Your Direction
We may share your information for any other purposes disclosed to you at the time we collect your information or pursuant to your consent. If you link your Service account to a third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service. When you direct us to, we will share Personal Data that is needed for these other companies to provide the services that you have requested.
LAWFUL BASIS OF PROCESSING
Under applicable laws, Stash must have a lawful basis for processing (i.e. a valid reason to use) your Personal Data.
- We will process Personal Data if required to enter into or perform a contract with you. For example, we will process Payment Data in order to complete Sales Activity and bill Customers for the Services.
- Stash may disclose or otherwise allow access to any Personal Data to comply with laws, regulations and other binding legal obligations. For example, we may cooperate with law enforcement authorities in investigating and prosecuting activities that are illegal, violate our rules or may be harmful to other visitors, and tax laws require us to retain records of payments made through our Services.
- We may rely on Stash’s legitimate interests or those of a third party if these legitimate interests are not overridden by your rights and interests as a data subject under applicable laws. For example, our Customers have a legitimate interest in gaining business intelligence through our Services. These insights allow Customers to optimize their sales and marketing strategies and ultimately analyze behavior leading to Sales Activity. Also, we have a legitimate interest in, for instance: i) enhancing the Services and providing comprehensive and timely information to benefit our Customers' business intelligence needs; ii) customizing the dashboards and reporting for our Customers for streamlined account management; iii) supporting payment processing for Sales Activity with minimal fraud rates; iv) assuring the security and integrity of the Platform; and v) subject, to your preferences, sending marketing communications to promote our Services to existing Customers and prospects.
- We use information about you where you have given us consent to do so for a specific purpose not listed above. If you have consented to our use of your Personal Data for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place.
PRIVACY RIGHTS AND CHOICES
Depending on your jurisdiction, your privacy rights may include the right to: i) ask for a copy of the personal information we hold about you; ii) erase, block, correct or restrict the Personal Data we hold about you or challenge ways in which Stash uses your personal information; iii) request that we provide certain personal information in a commonly used electronic format or transfer it to another data controller; iii) withdraw consent, where our processing is based on your consent; and iv) object to the processing of Personal Data. Before we process your request, we may seek specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a safeguard to ensure that personal data is not disclosed to any person who has no right to receive it.
To manage any information Stash receives about you from a third-party platform (e.g. a PSP), you will need to follow the instructions for the relevant sites (s) for updating your information and changing your privacy settings. If you have given consent for your details to be shared with a third party and wish to withdraw this consent, please also contact the relevant third party in order to change your preferences.
In some cases, particularly if you are a resident of the EEA, the United Kingdom (UK), or Switzerland, or if you are a resident of some States, you may have additional rights beyond what is stated above. Please contact us to exercise any of your choices.
INTERNATIONAL DATA TRANSFER
We store Personal Data that we collect on Google Cloud servers in the United States. Accordingly, please note that if you do not live in the United States, we will transfer your information to and to countries (including the United States) that may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your Personal Data will at all times continue to be governed by this Privacy Policy, and, the standard contractual clauses if you are based in the EEA, the UK or Switzerland.
SECURITY AND DATA RETENTION
Stash maintains technical, physical, and administrative security measures designed to provide reasonable protection for personal data. We retain your Personal Data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. By law, we may have to keep basic information about Consumers and Authorized Users (including contact and identify information or financial) for up to seven years after they cease being users for tax and other regulatory purposes. In some circumstances we will anonymize your Personal Data for research or statistical purposes or to create new features and products, in which case we may use this information indefinitely without further notice to you.
CONTACT US
If you have any questions, comments, or suggestions about our privacy practices, this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy or under Data Protection Law, please contact Stash by email at privacy@stash.gg. We will address your concerns and attempt to resolve any privacy issues in a timely manner.