Starplay User Data Policy
Date of Latest Revision: Dec 24 , 2025
This User Data Policy ("Policy" or "Notice") details our practices concerning the acquisition, utilization, disclosure, and safeguarding of your private data during your engagement with the "Starplay" software ("Software" or "Application"). Our commitment is to user data integrity and compliance with relevant data protection legislation (including GDPR and CCPA, where applicable).
Should you disagree with any provision of this Policy, you must cease using the Application at once. We reserve the right to modify this Policy periodically. The revised text will be posted on this page and become effective immediately upon its posting.
1. Entity Responsible for Data and Contact Details
Data Processing Entity: Torrit Soft
Official Address: Dimitar Evtimov Ivanov 57 Bratya Miladinovi, Entrance 9, Floor 2, Apartment 7, Burgas 8000, Bulgaria Burgas - 8000 Bulgaria (BG)
Privacy Inquiries: torritsoft@gmail.com
2. Applicability and User Requirements
This Policy governs the handling of your personal data when you obtain, enroll in, and interact with the Software and its associated functionalities (such as reward mechanisms or payout features).
The Software is not designed for use by individuals below the age of majority. If you are under 18 years old, please refrain from using the Software. We do not knowingly collect personal information from minors.
3. Data Acquisition Methods
3.1 Data Supplied Directly by You
User Profile and Enrollment Data: Electronic mail address, chosen display name, fundamental third-party sign-in data, and details pertaining to payment accounts.
Support Communications: Content shared when initiating contact with our support team or submitting tickets.
Integrity Check Data: To counteract deception and ensure accurate reward distribution, we may require supplementary verification prior to processing payouts (e.g., facial image capture via device camera, KYC details). When sensitive data like facial images is involved, we will secure your clear consent and use it strictly for anti-fraud and compliance checks, deleting it after the necessary retention period is met, as per this Policy.
3.2 Data Gathered Automatically
System and Activity Records: Device type, operating system build, unique hardware identifiers (e.g., Device ID), advertisement identifiers (GAID/AAID/IDFA), network IP address, localization settings (time zone, language), network specifics (carrier, speed), display parameters, system health (battery/storage), and browser details (user agent).
Interaction Metrics: Software launch frequency and session duration, triggered events, feature engagement, progress on activities/tasks, data on ad consumption (e.g., rewarded video completions), and performance/crash logs.
Geographical Data: Estimated location derived from the IP address; if precise location is needed, separate authorization will be requested.
3.3 Third-Party Attribution and Statistics
Advertising and attribution partners may provide installation source, ad interaction data, and campaign performance data for anti-fraud measures, billing reconciliation, and optimization.
4. Rationale for Data Processing
We process your data for the following legitimate reasons (legal bases vary by jurisdiction):
Service Delivery: Establishing and managing user accounts, enabling features, calculating and dispensing rewards, providing user assistance, resolving issues, and enhancing operational efficiency (Justification: Fulfilling contractual obligations or pursuing legitimate operational interests).
Engagement and Improvement: Sending service alerts (e.g., progress updates), recommending personalized content or activities, conducting statistical analysis, and performing multivariate testing (Justification: Legitimate interests or user consent, depending on local law).
Security and Integrity: Identifying, investigating, and preventing fraudulent behavior and misuse; enforcing our terms of service; and securing accounts and transactions (Justification: Legitimate interests and/or meeting legal mandates).
Regulatory Adherence: Conforming to statutory obligations (e.g., tax reporting, regulatory requests) (Justification: Legal obligations).
Sensitive Data Processing (e.g., facial data): Only when necessary and with your explicit consent, strictly for anti-fraud and payout verification, and deleted after the purpose is achieved (Justification: Consent).
5. Automated Processes
We utilize data for operational analytics, risk scoring, and advertising attribution. However, we will avoid making fully automated decisions that result in significant legal or similar consequences for you without prior notification and required consent.
If automated systems are used for anti-fraud checks, we guarantee the availability of human review and appeal mechanisms.
6. External Software Development Kits (SDKs) and Partners
The Software incorporates third-party SDKs to facilitate functions such as advertising revenue generation, installation tracking, technical diagnostics, and other necessary features. These external providers may operate as independent data controllers or processors, handling your data according to their own privacy policies. We maintain appropriate data protection agreements with these entities.
AppLovin MAX (AppLovin)
https://www.applovin.com/privacy/
Google AdMob (Google)
https://policies.google.com/privacy
Additional: Google Ads technologies and advertising
https://policies.google.com/technologies/ads
Adjoe
https://www.adjoe.io/privacy-policy/
Liftoff
https://liftoff.io/privacy-policy/
BIGO (BIGO Technology / Bigo Live)
https://www.bigo.sg/privacy-policy
These SDKs may collect advertising identifiers (GAID/IDFA), device information, IP address, location information (depending on permissions), app usage events, and ad interaction data. They use this data for ad delivery, anti-fraud, billing reconciliation, attribution, and product improvement.
7. Local Storage and Tracking Mechanisms
The Software may employ local device storage, SDK caching, mobile advertising identifiers, and comparable technologies to maintain session continuity, store user preferences, perform statistical measurements, and deliver advertisements.
You can manage ad tracking and notification permissions via your device's system settings.
8. Disclosure and Distribution of Data
We may share or disclose your information under the following circumstances:
Contracted Service Providers: Vendors who execute functions on our behalf, such as hosting, analytics, support, payment processing, and advertising attribution, processing data strictly for the agreed-upon services.
Legal Requirements: When mandated by law, law enforcement, or regulatory bodies, or when necessary to protect our rights, enforce our terms, and address security incidents.
Corporate Transactions: In the event of mergers, acquisitions, or asset transfers, your data may be transferred as a business asset.
User Authorization: Sharing data with third parties to enable specific features, contingent upon your explicit permission.
9. Global Data Movement
Your information may be processed and archived worldwide, potentially in regions with varying data protection standards. We commit to implementing suitable protective measures (such as the EU’s Standard Contractual Clauses, SCCs) to guarantee an equivalent level of security.
10. Data Holding Period
We maintain personal information only for the duration required to achieve the objectives detailed in this Policy, followed by deletion or anonymization.
User Account Data: Generally held as long as the account is active; deletion requests are processed within a reasonable timeframe.
Compliance Records: Retained for the necessary period to satisfy legal and fiscal requirements.
Sensitive Consent Data: Used solely for verification; generally removed within one month following successful verification, unless extended retention is legally required.
11. User Rights
Subject to applicable data protection legislation, you may possess the following entitlements:
Access: Request access to the personal records we process.
Correction: Demand the amendment of inaccurate or incomplete details.
Deletion: Ask for the removal of personal data under qualifying legal conditions.
Restriction/Objection: Request limitations on processing or object to processing based on our legitimate interests.
Portability: Request your data in a standardized, machine-readable format for transfer to another party.
Consent Withdrawal: Revoke consent for processing at any time (without affecting prior lawful processing).
Complaint: File a grievance with the relevant supervisory authority.
To exercise these rights, please contact us using the details under "Contact Details." Identity verification may be required for security purposes.
12. Advertising Preferences
You have the ability to restrict ad personalization or reset your advertising identifier via your device's system settings.
If the Software offers a Consent Management Platform (CMP) or privacy settings, you may adjust your preferences there.
13. Communications
We may send mandatory service-related notifications (e.g., security alerts, updates, reward status).
Marketing communications (e.g., push notifications) require consent or rely on lawful legitimate interests, with clear opt-out options provided.
14. Security Protocols
We deploy appropriate technical and organizational security safeguards, consistent with industry standards, to protect your data, including encryption, access controls, and staff training.
However, internet transmission and storage are not absolutely secure. In case of a security incident, we will take actions required by law and notify you and regulators where necessary.
15. Account Closure and Data Removal
You may initiate the closure of your account and the deletion of personal data via in-app settings or by contacting us. We will process your request within a reasonable timeframe. We may retain some data as necessary to comply with legal obligations or handle disputes.
16. Notice for California Residents (CCPA/CPRA)
We do not engage in the sale of your personal information. Certain advertising activities may constitute "sharing"; you can exercise your opt-out rights.
You have rights to access, delete, and correct personal information, and to limit the use of sensitive information.
17. Protection of Minors
The Software is not targeted at minors, and we do not knowingly collect their data.
18. Contact Us
If you have any questions, requests, or complaints regarding this Policy or privacy matters, please contact us at:
Email: torritsoft@gmail.com
Address: Dimitar Evtimov Ivanov 57 Bratya Miladinovi, Entrance 9, Floor 2, Apartment 7, Burgas 8000, Bulgaria Burgas - 8000 Bulgaria (BG)