Privacy Policy
Effective Date: March 10, 2023
Materia Labs PTE. LTD. understands and respects your desire to maintain your privacy. It is our
priority to maintain your privacy in all of your dealings with us, including through your use of the
Astro Space mobile gaming app (“App”). In this policy, “MateriaLabs” refers to Materia Labs PTE.
LTD. and its “Affiliates”, which shall mean subsidiaries, parent companies, joint ventures and
other corporate entities under common ownership. We may also refer to MateriaLabs as “we”
or “us”.
This Privacy Policy is designed to provide clarity about the information we collect, how we use it
to provide a better gaming experience as well as how you can exercise your privacy rights. This
Privacy Policy applies whenever you play our games or otherwise access any of our other
products, services, content, websites and/or the other domains provided by us, together referred
to as “Services.” If you have any questions regarding our privacy policy or MateriaLabsdata
protection practices, please contact us as described in the Section 11 (“Contact Us”).
By using the Services, you agree to the collection, disclosure, storage and use of your information
as outlined in this Privacy Policy. If you do not want us to collect, store, use or share your
information in the ways described in this Privacy Policy, you should not play our games or use
our Services. We may amend the Privacy Policy from time to time, and we encourage you to
consult the Privacy Policy regularly for changes.
1. Information We Collect and Process
MateriaLabs only collects and processes your information to the extent necessary to fulfil one or
more of its functions and activities, and will do so only by fair and reasonable means.
The legal basis for collecting and using the information depends on what the information is and
the context in which we collect it.
The personal information we may collect and process about you through the Services falls into
the following general categories:
1.1. Data you provide voluntarily
This Privacy Policy covers your personal information. Personal information is information or an
opinion, whether true or not, and whether recorded in a material form or not, about an identified
individual, or an individual who is reasonably identifiable. All personal information received in
connection with our business is subject to strict rules of confidentiality.
Common examples include your name, username, password, IP address, unique device identifiers,
gender, signature, address, telephone number, email, date of birth, bank account and digital
wallet details, billing and credit or debit card details, photos and videos of you, other
identification credentials and biographical details, and commentary or opinions about you.
1.2 Information we collect automatically
When you access our websites or play our games, we may also collect certain information
automatically from you and/or your device in order to efficiently fulfilling our contractual
obligations, better understand our users and be able to improve our services and your user
experience, such as:
your mobile device’s identifiers
details about the games and platforms you use
IP address , which only allows us to determine the geographic area and does not reveal
your precise location;
your device information (such as device type, device system language, network and
carrier data, operating system)
information regarding your use of and interaction with our Services (such as in-game
event, game version)
your country
application performance and de-bugging information
what your current progress is in our Services and the date and time of activity
your payment information in our Services
Like most online services, we and our partners may use cookies and similar technologies to
provide and personalize our services, analyze gaming usage, target advertisements and prevent
fraud. Cookies are small text files stored by browser(s) on your desktop computer or mobile
device. Most web browsers automatically accept cookies, but you can modify browser setting to
decline cookies if you wish so. In that case, some aspects of the service may then not function
properly.
1.3 Information we obtain from third party sources
When you use any of MateriaLabs Services via your social media account, such as Facebook or
Google (where our games may also be referred to as “applications”), you allow MateriaLabs to
access certain information from your profile on that site to efficiently fulfill our contractual
obligations. The information we receive from you will depend on your social media privacy
settings. You can control and find out more about these settings at the social network services
where you play our games. MateriaLabs may access and store some or all of the following basic
information, such as:
your user identification number (like your Facebook ID number), which may be linked to
publicly-available information like your name and profile photo
information about your activities on or through the connected third-party platform
any other information that you or the third-party platform share with us
We may collect information about you from third-party sources, such as advertising partners. We
may get your personal information, for example, if you clicked on an advertisement directing you
to one of our Services, we will be provided with information about which advertising network
and advertising campaign the install originated from.
2. Purposes of Collecting, Processing and/or Disclosing:
You consent to the disclosure of your personal information to any of our related entities. You
consent to our collection of your personal information and disclosing it to third parties where
necessary and for the purposes for which it was collected.
This may include:
- providing our services;
- verifying your game activities and issuing AST or DMT tokens on the basis of this verified
data;
- where we collect or disclose information that is or relates to the Internet Protocol Address
used to connect your device to the internet, for the purpose of fraud detection and
management of the integrity of the Astro Space game system and other services. This may
include detecting when users are cheating the Astro Space game system, and for handling
accounts we suspect are stolen or have otherwise been compromised. This information
helps us verify whether the account or associated assets belong to a particular user;
- where information is or relates to system version information of your device, or the make
and model of your device, for the purpose of our compatibility assessments with our
software versions and other aspects of our services;
- creating leaderboards of players, comprising all players or players meeting particular
criteria;
- operating the Astro Space Marketplace;
- investigating disputes between players;
- using your personal information to provide you with information that you have requested
from us, although we do not create a link between your user ID and your user email;
- communicate with you, including to inform you of updates to the App, Astro Space
website, our Terms of Use and/or this Privacy Policy;
- authenticating your financial account information or processing the transfer of digital
assets;
- authenticating your credit or debit card information;
- using your personal information for marketing purposes to provide or offer services to
you. This includes, but is not limited to, keeping you up to date with our latest news,
events, special offers and promotion of our brand or other similar products that we think
that you may be interested in. This includes both our direct marketing to you or another
third party whom you have authorized us to disclose your personal information to;
- notifying you about any changes to our products, website, App and/or other software
and/or mobile applications, brand or services offered;
- seeking your opinion and feedback on any of our services, including for the purposes of
product improvement and customization, website/software improvement and
personalization and other general services;
- for consumer engagement and/or customer service purposes, including but not limited
to identifying the effectiveness of advertising, allowing you to participate on website viral
features such as sharing website content and other community features (for example,
blogs);
- analyzing the usage of, and improve our services;
- for other general services such as website/software security, maintenance, identification
of fraud or errors, internal accounting and administration, and for any other purpose that
we are required or permitted to do by law; and
- managing our relationships with you and our other customers.
Certain of your personal data may be shared with other players of the App as part of the normal
operation of our services. Additionally, we may, from time to time, expand or withdraw our
business which may involve the transfer of certain of our divisions or assets to other parties, and
the data we store and use, where relevant, may be transferred to such third parties. From time
to time we may also transfer the data we store and use to locations outside Singapore, some of
which may have different data protection laws to Singapore.
In addition we may utilize overseas IT services (including software, platforms and infrastructure),
such as data storage facilities or other IT infrastructure. In such cases, we may own or control
such overseas infrastructure or we may have entered into contractual arrangements with third
party service providers to assist us with providing our services to you.
As we utilize cross border IT services and platforms which can be accessed from various countries
via an internet connection, it is not always practicable to know where your information may be
held.
3. How We Collect Information about You
When you play one of our games, MateriaLabs collects and stores certain personal information
and non-personal information that you provide directly or through third party sources that is
offering our game(s); In addition, your web browser or client software may transmit certain
geographic information or information regarding your computer (capabilities, game data
processing, etc.) to MateriaLabs. Certain information regarding your game play, such as a
timestamp of your last game played and your game progressions, will be collected from you
and/or automatically generated based upon your use of our game services.
As is true with most websites, we gather certain information automatically and store it in log files.
This information may include a unique identifier such as your Internet Protocol (IP) address and
non-personal information such as your browser type, Internet Service Provider (ISP),
referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may
combine this automatically collected log information with other information we collect about
you.
MateriaLabs and our partners, may use tracking technologies such as cookies, beacons, tags and
scripts. These technologies are used in analyzing trends, administering the websites, tracking
users’ movements around the websites, and to gather demographic information about our user
base as a whole. We may receive reports based on the use of these technologies by these
companies on an individual as well as aggregated basis.
Users can control the use of cookies at the individual browser level. If you reject cookies, you
may still use our websites, but your ability to use some features or areas of our websites may be
limited.
4. How We Use the Information We Collect
In general, we collect, store and use your information to provide you with a safe, smooth,
efficient, and customized gaming and entertainment experience. The personal information you
provide MateriaLabs will allow us to provide and deliver products and services you request, such
as create in-game accounts; alert you of new products or services, features, or enhancements;
improve our Services and keep them secure, such as handle/route your customer service or
technical support questions or issues; and/or notify you of upgrade opportunities, contests,
promotions, or special events and offers. MateriaLabs may enhance or merge the personal
information collected with data from third parties in order to update your contact information,
perform market analysis, or improve our products or services. We may use your personal
information for internal marketing, profiling, or demographic purposes, so we can adapt our
products and services to better suit your needs. We do this to better understand and serve our
customers. If we use your information for purposes beyond the above-mentioned purposes in
material aspects, we will ask for your consent.
5. Sharing of Your Information
MateriaLabs will share your personal information with third parties only in the ways that are
described in this Privacy Policy. We do not sell your personal information to third parties. We
may, however, share non-personally identifiable, aggregated, and/or public information with
third parties. Additionally, we may share your game play data, customer service and/or unique
identifiers specific to your device with third parties for the purpose of personalizing, adjusting
and improving our Services. We direct all such third party service providers to maintain the
confidentiality of the information disclosed to them and not to use your information for any
purpose other than to provide services on MateriaLabs’ behalf.
We do not actively share personal information with third party advertisers for their direct
marketing purposes unless you give us your consent.
In the event that MateriaLabs undergoes a business transition (including proposed transactions),
like a merger, acquisition by another company, or sale of all or part of its assets, we may disclose
or transfer all of your information, to the successor organization in the transition.
Your information, and the contents of all of your online communications (including without
limitation chat text, voice communications, IP addresses and your personal information) may be
accessed and monitored as necessary to provide the Services and may be disclosed: (i) when we
have a good faith belief that we are required to disclose the information in response to legal
process (for example, a court order, search warrant or subpoena); (ii) to satisfy any applicable
laws or regulations (iii) where we believe that the Service is being used in the commission of a
crime, including to report such criminal activity or to exchange information with other companies
and organizations for the purposes of fraud protection and credit risk reduction; (iv) when we
have a good faith belief that there is an emergency that poses a threat to the health and/or safety
of you, another person or the public generally; and (v) in order to protect the rights or property
of MateriaLabs.
6. How to Exercise Your Rights
You may access, amend and delete information provided by you when using our Services, or
contact us at operation@astro-space.xyz. The scope and the way in which you access, amend or
delete your personal information depend on the service you use. For iOS users, you can request
the deletion of your account from within the app.
You may opt-out of receiving promotional communications, such as marketing emails we send
you, at any time. If you wish to do so, please e-mail us at operation@astro-space.xyz. You can
turn off push notifications by visiting the “options” or “settings” page within the relevant games.
You can opt-out of interest-based advertising on mobile applications by checking the privacy
settings of your Android or iOS device and selecting “limit ad tracking” (Apple iOS) or “opt-out of
interest based ads” (Android). For personalized in-game offers opt-out, you can use the options
provided in the game settings.
If for any reason you are concerned with the way we are using your personal information, or
would like to correct or request that we delete such personal information, please contact
MateriaLabs using the information in the “Contact Us” section below. We will respond to your
request as promptly as possible.
In some cases, we may not be able to delete your personal information and will retain and use
our information as long as necessary to comply with our legal obligations, resolve disputes,
and/or enforce our agreements.
7. Data Deletion
We will delete or de-identify your personal data as reasonably possible in the following cases:
When we have no ongoing legitimate business need to process your personal information;
When we stop operating our Service;
When you request your data to be deleted;
When a platform, such as Meta requires the deletion of your Open Platform Data at their
discretion, either to protect you or as part of their compliance review;
When required by applicable law or regulation.
If the data deletion is not possible, for example, because your personal information has been
stored on a backup server, then we will securely store your personal information and isolate it
from any further processing until deletion is possible.
We retain personal information we collect from you where we have an ongoing legitimate
business need to do so, when we operate our Service and when we ensure that your personal
data is subject to suitable safeguards. For example, to provide you with a Service you have
requested, or to comply with applicable legal, tax or accounting requirements. We will for
example periodically de-identify unused game accounts and we regularly review and delete
unnecessary data.
8. Age Limit
When we collect personal information, we do not know the age of our players. If a player has a
social media account and has logged into a game, we may obtain the age information from the
player through that. If we learn that we have collected personal data about a child under age 13,
we will take reasonable steps to delete such data as promptly as possible. If you are a minor
under 16 years old, please note that you are allowed to use our Services upon the prior consent
of your parents or legal guardian.
9. Privacy Policies of Linked Sites and Advertisers
Our websites and games may contain advertisements from companies other than MateriaLabs
that may link to their own websites. We are not responsible for the privacy practices or the
content of such websites. If you have any questions about how these other websites use your
information, you should review their policies and contact them directly.
10. Security of Your Information
We understand the importance of keeping your information safe and secure. MateriaLabs has
taken steps to assure that all information collected will remain secure and in its original form, i.e.
free from any alteration. As such, access to all personal information is strictly controlled. We
follow generally accepted standards to protect the personal information submitted to us, both
during transmission and once it is received.
In addition, we will take reasonable steps to assure that third parties to whom we transfer any
data will provide sufficient protection of personal information.
11. Contact Us
If you have any questions, comments or concerns regarding our Privacy Policy, or you would like
to request the deletion of your data, please feel free to e-mail us at operation@astro-space.xyz.
12. (For Residents of the EEA and the United Kingdom) GDPR Provisions
As we process personal information of data subjects inside the European Economic Area (“EEA”)
we are also bound by Regulation (EU) 2016/679, the General Data Protection Regulation
(“GDPR”).
The purpose of the following data protection information is to provide you with an
understandable, transparent and concise explanation of how we intend to process your personal
data in accordance with Articles 13 and 14 of the GDPR. However, should you require further
explanations relating to our data protection or wish to exercise any of your rights, please do not
hesitate to contact our Privacy Officer at operation@astro-space.xyz.
We recognize the below rights which you enjoy under the applicable data protection law with
respect to your personal data:
Right to be informed: You have the right to be informed about the collection and use of your
personal data. This information is set out in the terms of our Privacy Policy.
Right of access: You may request information from us at any time as to whether we have stored
your personal data and which personal data it has stored. We are required to provide this
information to you free of charge.
Right to rectification: If your personal data stored by us is inaccurate or incomplete, you have the
right to demand at any time that we correct the information.
Right to erasure: You have the right to demand that we erase your personal data if and to the
extent that the data is no longer needed for the purposes for which it was collected or if the data
is processed on the basis of your consent and you have opted to revoke your consent. In such
cases, we must cease processing your personal data and remove that data from our IT systems
and databases. You do not have a right to erasure if: (a) the data may not be deleted due to a
statutory obligation or must be processed due to a statutory obligation or (b) the processing of
data is necessary for the establishment, exercise or defense of legal claims.
Right to restriction of processing: You have the right to demand that we restrict the processing
of your personal data.
Right to object to processing: If your data is processed by us on the basis of Article 6(1)(f) GDPR,
you may object at any time to processing by us. You may assert any and all of the rights of data
subjects described above against us by addressing your specific requests by contacting our
Privacy Officer via operation@astro-space.xyz.
Right to lodge a complaint with a data protection supervisory authority: Pursuant to Article 77
GDPR, you have the right to lodge a complaint with a data protection supervisory authority if you
believe that the processing of your personal data infringes data protection law.