// LEGAL

PRIVACY NOTICE

Last modified: August 2026

Introduction

OffStars Studios ("Company", "we", "our", "ours" or "us") develops and operates the game Cliff Heroes and associated activities on its mobile app ("App"), as well as the website cliffheroes.com, its subdomains, and related features ("Website", collectively with the App referred to as the "Services").

We are dedicated to protecting your privacy rights and making our practices regarding your Personal Data (as defined below) more transparent. This Privacy Notice (the "Notice") explains how we collect, use, store, and disclose your Personal Data and your rights regarding it. The Notice applies whenever you visit our Website, use our App, or otherwise interact with the Services.

We strongly urge you to read this Notice and make sure that you fully understand and agree to it. If you do not agree to this Notice, please discontinue and avoid using our Services. You have the right to cease using our Services, pursuant to this Notice, at any time.

You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the full range of the best experience of using our Services.

This Notice is integrated into and forms part of the Company's Terms of Service.

Specifically, this Notice describes –

1. What Types of Personal Data Do We Collect?
2. Tracking Technologies
3. Why Do We Process Your Personal Data?
4. With Whom Do We Share Your Personal Data?
5. Marketing and Advertising
6. Your Rights
7. Transfer of Personal Data
8. How Do We Protect Your Personal Data?
9. Minors
10. Retention
11. Updates to this Notice
12. Contact Us

1. What Types of Personal Data Do We Collect?

We collect Personal Data about you, meaning any information which potentially allows your identification with reasonable means (for example, email address or name, collectively "Personal Data"). This section sets out the types of Personal Data we collect and process about you.

• Account information. If you choose to register an account with our Services, we collect your full name, email address, username, phone number and birthdate, as well as voluntary information, such as your profile picture. If you choose to log in, access or otherwise connect the Services through a social networking services (such as Facebook), we may collect your user ID or username associated with that social network service, as well as any information you make public using that social networking service or that the social networking service allows us to access.
• Payment information. When you decide to make a purchase through our Services, you will be required to provide us with your billing information (e.g., name, credit card details, billing address).
• Technical information. When you use our Services, we collect technical information about your device and your interaction with our Services. Such information may include: (i) device and other unique identifiers; (ii) geolocation; and (iii) device and operating system type and version.
• Usage information. When using our Services, we collect information about your usage, including but not limited to, purchase you made, gameplay and recording data and usage statistics.
• Communication information. When you send us an email or otherwise contact us through the Services support, we collect the Personal Data you provide us. This may include your name, email address, and any other information you choose to provide.

2. Tracking Technologies

When you visit or access our Services, we use cookies, pixels, beacons, local storage and similar technologies ("Tracking Technologies"). These allow us to automatically collect information about you, your device, and your online behavior, in order to enhance your navigation of our Services, improve the performance of our Services, perform analytics, customize your experience, and offer you, for example, tailored content and advertising that better corresponds with your interests.

You can review or change your cookie choices on this Website at any time with Cookie settings.

3. Why Do We Process Your Personal Data?

This section explains for what purposes we use your Personal Data, and outlines the legal bases that underlie our usage.

4. With Whom Do We Share Your Personal Data?

We do not share, sell or disclose your Personal Data for cross-context behavioral advertising.

To provide you with the Services, we may share your Personal Data as described below:

• Affiliated companies. We may share Personal Data internally with our affiliated companies and subsidiaries, for the purposes described in this Notice.
• Payment processors. We share your payment information with third party payment processors, for the purpose of facilitating your payment when using our Services.
• Service providers. We may share your data with third-party service providers who assist us with various tasks, including customer service, hosting, email delivery and marketing support.
• Governmental bodies and law enforcement entities. We may disclose any Personal Data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal procedures (including, but not limited to, subpoenas), to protect our or a third party's property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We may also be required to disclose an individual's Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
• Auditors and advisors. We may share your Personal Data with our external auditors, advisors, and professional service providers (e.g., lawyers, accountants, insurers) for ensuring our compliance with regulatory requirements and industry standards and to resolve disputes.

5. Marketing and Advertising

We may use your Personal Data, either ourselves or through our third-party subcontractors, for the purpose of providing you with promotional materials concerning the Services as well as products, services, websites, and applications that relate to: (i) our affiliated companies; or (ii) the Company's business partners and affiliates (collectively, "Marketing Affiliates"), which we believe may interest you.

You may, at any time, decline receiving further marketing offers from us or from our business partners and Marketing Affiliates by clicking on the "Unsubscribe" option available in our messages or by contacting us at: supportoffstars@gmail.com.

Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you operational and service-related updates and notifications.

6. Your Rights

Depending on the jurisdiction in which you reside, you may have certain rights under relevant applicable laws regarding the collection and processing of your Personal Data. To the extent these rights apply and concern you, you can contact us via the contact details available below and ask to exercise the following rights.

• Right of access to your Personal Data. You have the right to receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
• Right of data portability. You have the right to request us to move, copy and transfer your Personal Data from one IT environment to another, in a safe and secure way, without affecting its usability.
• Right of rectification. You have the right to request rectification of your Personal Data in our control in the event that you believe the Personal Data held by us is inaccurate, incomplete, or outdated.
• Right of deletion. You have the right to request that Company erases or deletes Personal Data held about you at any time.
• Right of restriction or objection to processing. You have the right to request that Company restricts or ceases to conduct certain Personal Data processes at any time.
• Right to withdraw your consent. To the extent we process your Personal Data on the basis of your consent, you have the right to withdraw your given consent at any time.
• Right to limit use and disclosure of your sensitive Personal Data. You have the right to request to limit the collection of your sensitive Personal Data, to that use which is necessary to perform our Services.
• Right not to be subject to automated decision making. You have the right not to be subject to a decision based solely on automated processing, including profiling which produces legal effects or similarly significantly effects to you.
• Right to opt-out of the sale or share of Personal Data. You have the right to submit a request to opt-out of the sale or share for behavioral advertising purposes of your Personal Data. After you opt-out, we may continue disclosing some Personal Data to our partners to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services are working correctly and securely, providing aggregate statistics and analytics and preventing fraud.
• Right to non-discrimination. You have the right to be free from discrimination for exercising your rights, including by being offered different pricing or products, or being provided with a different level or quality of services, based solely upon your request.

Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. You are welcome to contact us with any questions or requests using our contact details below. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.

Authorized Agent

You can use an authorized agent to make a request to exercise your rights under applicable laws on your behalf if:

• The authorized agent is a natural person or a business entity; and
• You sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request to exercise your right, please provide us with a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

The request must:

• Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Data or an authorized agent. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you; and
• Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.

We will use Personal Data provided in a verifiable consumer request only to verify the requestor's identity or authority to make the request.

Making a verifiable consumer request does not require you to create an account with us.

7. Transfer of Personal Data

We operate globally, and therefore any information that we collect, disclose or share, including your Personal Data, may be stored and processed in various jurisdictions around the world, including (but not limited to) the European Economic Area, the United Kingdom and the United States, for the purposes detailed in this Notice.

To the extent that the GDPR or the UK GDPR applies, we will only transfer or share your Personal Data with data recipients: (i) located in the EEA or in the UK; (ii) located in countries outside the EEA or the UK that have been recognized as providing an adequate level of data protection; or (iii) that have entered into legal agreements ensuring an adequate level of data protection.

8. How Do We Protect Your Personal Data?

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access to, use, or disclosure of your Personal Data. While we seek to protect your information and to keep it confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet, and that there is also some risk that others could find a way to circumvent our security systems. Such breaches can result in harms such as reputational damage, fraud, or identity theft. We therefore encourage you to exercise discretion regarding the Personal Data you choose to disclose. If you believe that your privacy has not been treated in accordance with this Notice, or that any person has attempted to abuse the Services or acted inappropriately, please contact us using our contact details below.

9. Minors

Our Services are intended solely for users who are at least eighteen (18) years of age or older and who can form legally binding contracts under applicable law. We do not knowingly collect or solicit Personal Data from anyone under the age of 18, and we reserve the right to request proof of age at any stage. By accessing, using or interacting with our Services, you confirm to us that you are not under the age of 18. If we learn that we have collected Personal Data from an individual under the age of 18 without verification or parental consent, we will delete that information upon discovery. If you believe that we may hold any information from or about an individual under the age of 18, please contact us using the contact details available below.

10. Retention

We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information collected and the purposes for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated information at the earliest reasonable time.

11. Updates to this Notice

We reserve the right to change this Notice at any time. The most current version will always be posted on our Services (as reflected in the "Last Modified" heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Notice.

12. Contact Us

If you have any questions, please contact us by email at: supportoffstars@gmail.com.

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