General Information and data processing with respect to EU/EEA/UK/Brazil residents 

  1. Controller 

With this Privacy Policy, we will explain which personal data will be collected and processed by us in the context of your participation in the Trove Content Creator Program.  We are: 

gamigo US Inc. 
3800 Quick Hill Road  
Austin, TX 78728 
USA 

If you’re a(n) EU/EEA/UK/Brazil resident, our data protection officer can be contacted at dataprotection-us-inc(at)gamigo.com.  

Our representative within the European Union is  

gamigo AG 
Behringstr. 16b 
22765 Hamburg 
Germany 

You can contact our EU representative by writing a letter to this address and by emailing EUrepresentative(at)gamigo.com.  

Unless explicitly defined otherwise, we use the term “personal information” or “personal data” – at times referred to herein as “Data“ – to refer to information as defined under the General Data Protection Regulation or such other applicable privacy laws. 

For further information on the processing of personal data by us when you use our website or for our game Trove in general, please also refer to our general Privacy Policy available here.  

  1. Why we collect your Data and how we use it 

We use your Data to communicate with you for the provision of the Trove Content Creator Program and to grant you access and information to content.   

We receive your personal data either when it is provided by you (e.g., when you input data into the registration mask) or when it is automatically collected or through third parties.  

For the specific data collection purposes please see Section II below.  

  1. Legal basis 

We collect and process personal data based on the following legal bases: 

  • Based on your consent according to Article 6 (1) (a) GDPR, i.e. where we seek your consent for the processing of data, we rely on such consent insofar given by you.  
  • Necessary for the performance of a contract or in order to take steps prior to entering into a contract according to Article 6 (1) (b) GDPR, i.e. the data is necessary so that we can fulfil our contractual obligations towards you, or we require the data in order to prepare the conclusion of a contract with you.  
  • Compliance with a legal obligation according to Article 6 (1) (c) GDPR, i.e. that a processing of the data is mandatory under law or other regulations. 
  • Processing is necessary for the purposes of the legitimate interests according to Article 6 (1) (f) GDPR, i.e. the processing is necessary for the purposes of legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or your fundamental rights and freedoms which require protection of personal data. 
  1. With whom we share your Data 

‍ 

We may share your personal data with the following third parties: 

  • The staff of our company; 
  • our hosting provider; 
  • other third parties as listed in Section II below; 
  • if applicable: public and private organizations, exclusively to meet our legal obligations. 

Please see Section II below on further information on third parties with whom your personal data will be shared.  

  1. International transfers 

Compliance with Art. 44 et seq. GDPR is ensured if data is transferred to a third country, i.e., before any personal data is transferred to third parties in a country outside the EU or the EEA (Norway, Iceland, Liechtenstein), we check whether these countries offer an adequate level of protection. This can be ensured by the fact that an adequacy decision by the EU Commission has been made or that third country transfers are permitted under other instruments regulated in Art. 46 et seq. GDPR (Standard Contractual Clauses). 

  1. Data subject rights 

You have the following rights with regard to the processing of your data by us to the extent according to each of the listed Articles of the General Data Protection Regulation: 

  • right of access according to Article 15 GDPR 
  • right to rectification according to Article 16 GDPR 
  • right to erasure (“right to be forgotten”) according to Article 17 GDPR 
  • right to restriction of processing according to Article 18 GDPR 
  • right to data portability according to Article 20 GDPR 
  • right to object according to Article 21 GDPR 
  • withdraw consent at any time (where we are relying on your consent to process your personal data, you may withdraw this consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.) 

Without prejudice to any other administrative or judicial remedy, you have the right to complain to a supervisory authority, in particular in the Member State of your habitual residence, your place of employment or the place of the alleged infringement if you believe that the processing of your personal data violates the GDPR. 

To exercise your rights, please let us know whether you are an EU/EEA/UK/Brazil resident and email us at dataprotection-us-inc(at)gamigo.com.  

  1. Data deletion and duration of storage 

We always store your personal data as briefly as possible and only as long as there is a specific purpose for this. Your personal data will be therefore deleted as soon as the purpose of the processing ceases to apply. Data may be stored longer than this if such storage is required by the European or national legislator in EU regulations, laws or other regulations to which the controller is subject. Data is also deleted if a retention period prescribed by the aforementioned standards expires, unless the continued storage of Data is necessary for the conclusion of a contract or the fulfilment of contractual obligations (e.g. for tax reasons). 

Specific data collection 

  1. Conclusion of the Trove Content Creator Program Agreement 

a. Extent of the data processing 

When we conclude an agreement for the participation in the Trove Content Creator Program with you, we will collect the relevant data (“provided information”) for this purpose, namely: 

  • first and last name 
  • location (country) 
  • email address and messages 
  • Discord username 
  • (social media) platforms you are active on 
  • the link to your main channel 
  • your artist name(s) 
  • the number of subscribers or followers on the respective platforms you are active on
  • the type of your produced content 
  • your Trove character name(s) 
  • your publicly expressed statements about Trove 

When registering for the Trove Content Creator Program, the data provided by you in the input mask is transmitted to us. In this case, the date and time of registration will also be stored. As part of the confirmation of the registration, the Trove team will contact each registered Content Creator individually via email to ask for their confirmation of their application via email using their email address as provided in the registration. 

b. Legal basis 

The legal basis for the processing of data for the participation in the Trove Content Creator Program with us is Art. 6 (1) (b) GDPR.  

We have entered into a contract for the processing of data on our behalf with a provider based in the US for the distribution of e-mails as well as for the storing of data in an online storage system. Standard Contractual Clauses of the EU Commission are used in the contractual relationship with the provider.  

c. Purpose of the data processing 

The data processing is performed for the execution of the Trove Content Creator Program.  

d. Duration of the storage 

The data will be stored with us for the duration of your participation in the Trove Content Creator Program. At the end of the program your provided information will be deleted. 

e. Possibility of objection and removal 

You can object to the processing of your data for the participation in the Trove Content Creator Program. In this case, however, we will be obligated to remove you from the Trove Content Creator Program, as we would no longer be permitted to process your data after your objection.. 

  1. Office 365 

a. Extent of the data processing 

Your provided information will be processed by Office 365 applications, which are located on servers which are operated on our behalf by Microsoft Corporation (“Microsoft”). There is no further use of the data by Microsoft. You can find out more about data collection and data processing by Microsoft under https://www.microsoft.com/en-us/trust-center/privacy.  

b. Legal basis 

The legal basis for the processing of your data is Art. 6 (1) (b) GDPR for the execution of the Trove Content Creator Program. 

With regard to any archiving obligations under commercial and tax laws, the legal basis is Art. 6 (1) (c) GDPR. 

We have entered into a contract for the processing of data on our behalf with Microsoft. Standard Contractual Clauses of the EU Commission are used in the contractual relation with the provider. 

c. Purpose of the data processing 

The data processing is carried out for the implementation of the Trove Content Creator Program as well as for tax and accounting purposes.  

d. Duration of the storage 

The data will be stored with us for the duration of your participation in the Trove Content Creator Program. At the end of the program your provided information will be deleted unless there is any further statutory reason requiring us to continue to store the data. 

e. Possibility of objection and removal 

 You can object to the processing of your data for the participation in the Trove Content Creator Program. In this case, however, we will be obligated to remove you from the Trove Content Creator Program, as we would no longer be permitted to process your data after your objection. 

  1. Confluence & JIRA 

a. Extent of the data processing 

We use the Atlassian, Inc. services Confluence and JIRA to process your provided information for internal communication and internal documentation and for the additional exchange of information between you and the Trove team. The company Atlassian, Inc. is registered in the United States of America. To learn more about how privacy is handled by Atlassian, Inc. you can go to https://www.atlassian.com/legal/privacy-policy#what-this-policy-covers.  

b. Legal basis 

The legal basis for the processing of your data is Art. 6 (1) (b) GDPR. 

With regard to any archiving obligations under commercial and tax laws, the legal basis is Art. 6 (1) (c) GDPR. We have entered into a contract for the processing of data on our behalf with Atlassian, Inc. Standard Contractual Clauses of the EU Commission have been used in the contractual relationship with Atlassian, Inc.  

c. Purpose of the data processing 

The data processing is carried out for the implementation of the Trove Content Creator Program as well as for tax and accounting purposes.  

d. Duration of the storage 

The data will be stored with us for the duration of your participation in the Trove Content Creator Program. At the end of the program your provided information will be deleted unless there is any further statutory reason requiring us to continue to store the data. 

e. Possibility of objection and removal 

You can object to the processing of your data for the participation in the Trove Content Creator Program. In this case, however, we will be obligated to remove you from the Trove Content Creator Program, as we would no longer be permitted to process your data after your objection. 

  1. Discord 

a. Extent of the data processing 

We operate accounts with the Discord service of Discord Netherlands BV. This allows us to communicate with you. Data processing by Discord takes place on the basis of the contract you have entered into with Discord itself. The scope and legal basis for processing by Discord can be found in their data protection information:  https://discord.com/privacy

We ourselves do not have access to the Discord database. 

b. Legal basis 

The legal basis for the processing of data for the participation in the Trove Content Creator Program with us is Art. 6 (1) (b) GDPR.  

c. Purpose of the data processing 

The data processing is carried out for the implementation of the Trove Content Creator Program.  

d. Duration of the storage 

The data will be stored with us for the duration of your participation in the Trove Content Creator Program. At the end of the program your provided information will be deleted. 

e. Possibility of objection and removal 

 You can object to the processing of your data for the participation in the Trove Content Creator Program. In this case, however, we will be obligated to remove you from the Trove Content Creator Program, as we would no longer be permitted to process your data after your objection. 

  1. Social Media, Platform and Further Exposure 

a. Extent of the data processing 

We maintain publicly accessible profiles on various social networks and online presences on platforms and websites. We use these profiles and presences to send information to reach (potential) customers. The information provided by you can be posted on our profiles and presences, including but not limited to your name and content. You can find details about the collection and storage of your personal data as well as the type, scope and purpose of its use by the operator of the respective social network in the data protection declarations of the respective operator: 

  • The privacy policy for the social network Facebook, which is operated by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, Ireland, can be viewed at https://www.facebook.com/privacy/policy/; 
  • the privacy policy for the social network Instagram, which is operated by Meta Platforms Ireland Limited, can be viewed at https://help.instagram.com/155833707900388; 
  • the privacy policy for the social network YouTube, which is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, can be viewed at https://policies.google.com/privacy?hl=en; 
  • the privacy policy for the social network X, which is operated by Twitter International Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, Ireland, can be viewed at https://twitter.com/en/privacy; 
  • the privacy policy for the social media presence Discord, which is operated by Discord Netherlands BV, Schiphol Boulevard 195, 1118 BG Schiphol, Netherlands, can be viewed at https://discord.com/privacy; 

the privacy policy for the social network Reddit, which is operated by Reddit Netherlands B.V., Euro Business Center, Keizersgracht 62, 1015CS Amsterdam, Netherlands, can be viewed at https://www.reddit.com/policies/privacy-policy. 

We do not have access to the databases of social media providers. 

b. Legal basis 

The legal basis for the processing of data for the participation in the Trove Content Creator Program with us is Art. 6 (1) (b and f) GDPR.  

This data processing serves our legitimate interest in enabling dialogue with other players about our game. 

c. Purpose of the data processing 

The data processing is carried out for the implementation of the Trove Content Creator Program and to facilitate interaction with other players regarding our game Trove through your potential exposure on the social media sites. 

d. Duration of storage 

The storage duration of data processing operations on our social media presences is determined by the respective data protection regulations of the social media providers. On our own presences, the data will be stored with us for the duration of your participation in the Trove Content Creator Program. At the end of the Trove Content Creator Program your provided information will be deleted unless there is any further statutory reason obliging us to continue to store the data. 

e. Possibility of objection and removal 

 You can object to the processing of your data for the participation in the Trove Content Creator Program. In this case, however, we will be obligated to remove you from the Trove Content Creator Program, as we would no longer be permitted to process your data after your objection.  

Data Processing with respect to California Residents 

California Privacy Notice 

  1. Personal Data 

The following is a list of the categories of personal information which we collect, or have collected, in the twelve months prior to the effective date of this Privacy Policy, the categories of sources from which such category is collected; and the categories of third parties with whom we share such information. 

Categories we collect: The provided information as defined in Section II above, email addresses, mobile advertising identifiers, session and persistent cookies, apps used or downloaded, web sites visited, browser and operating system type, type of devise used, information actively provided by users responding to a form in an ad, randomly assigned identifiers, precise and general location information and system information that our SDK may collect about your device or network provider. 

Further details may also be found in our general Privacy Policy available here. 

Sources: All the information above is collected when you register for the Trove Content Creator Program. We also acquire this information from partners or from advertising or data exchanges. 

Location information: We acquire location information when you provide it to an app which shares this information with us. 

Each Category is collected for the following business purposes: providing the Trove Content Creator Program, processing transactions, supporting forums and newsletters, delivering ads on publisher sites, reporting on ad delivery, securing, protecting, auditing, bug and fraud detection, debugging and repair of errors and the detection, protection and prosecution of security incidents or illegal activity; enforcing our terms and policies; complying with law. 

Each Category is also collected for uses that advance our commercial interests including creating profiles to target ads on behalf of advertisers, using data collected from publishers and from other third parties. 

  1. Sale/Sharing Information: Do Not Sell My Personal Information rights 

We may disclose the categories of information described above to vendors, such as analytics companies and may sell the information to advertisers, ad networks, other partners, and third parties. Please let us know you are a California resident and email us at dataprotection-us-inc(at)gamigo.com for instructions for how you can exercise your California access, deletion and Do Not Sell rights. 

  1. Do Not Sell signal 

If a partner has transmitted to us a Do Not Sell signal, we will limit our use of information from that partner and we will act only as a service provider as defined in the CCPA. 

  1. Access and Deletion 

Subject to certain exceptions and restrictions, the CCPA provides California Residents the right to submit requests to a business which has collected their personal information: (i) to provide them with access to the specific pieces and categories of personal information collected by the business about such California Resident, the categories of sources for such information, the business or commercial purposes for collecting such information, and the categories of third parties with which such information was shared; and (ii) to delete such personal information. 

If you are a California Resident, please let us know and email us at dataprotection-us-inc(at)gamigo.com for instructions for how you can exercise your California access, deletion and Do Not Sell rights. 

California Residents may designate an authorized agent to make California Requests on their behalf. 

  1. We do not discriminate against you 

You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. We do not discriminate against California Residents for exercising their rights. 

  1. We do not sell the personal information of minors under 16 years of age without affirmative authorization. 

For questions or further information please contact dataprotection-us-inc(at)gamigo.com 

Data Processing with respect to Residents of other States/Countries 

  1. Personal Data 

The following is a list of the categories of personal information which we collect, or have collected, in the twelve months prior to the effective date of this Privacy Policy, the categories of sources from which such category is collected; and the categories of third parties with whom we share such information. 

Categories we collect: The provided information as defined in Section II above, email addresses, mobile advertising identifiers, session and persistent cookies, apps used or downloaded, web sites visited, browser and operating system type, type of devise used, information actively provided by users responding to a form in an ad, randomly assigned identifiers, precise and general location information and system information that our SDK may collect about your device or network provider.  

Further details may also be found in our general Privacy Policy available here. 

Sources: All the information above is collected when you register for the Trove Content Creator Program. We also acquire this information from partners or from advertising or data exchanges 

Location information: We acquire location information when you provide it to an app which shares this information with us. 

Each Category is collected for the following business purposes: providing the Trove Content Creator Program, processing transactions, supporting forums and newsletters, delivering ads on publisher sites, reporting on ad delivery, securing, protecting, auditing, bug and fraud detection, debugging and repair of errors and the detection, protection and prosecution of security incidents or illegal activity; enforcing our terms and policies; complying with law. 

Each Category is also collected for uses that advance our commercial interests including creating profiles to target ads on behalf of advertisers, using data collected from publishers and from other third parties. 

  1. Sharing Information 

We may disclose the categories of information described above to vendors, such as analytics companies and may sell the information to advertisers, ad networks, other partners, and third parties. 

  1. Access and Deletion 

Applicable law may provide you the right to submit requests to us (i) to provide you with access to the specific pieces and categories of personal information collected by us about you, the categories of sources for such information, the business or commercial purposes for collecting such information, and the categories of third parties with which such information was shared; and (ii) to delete such personal information. If applicable law does not provide you these rights, we will nevertheless do our utmost to fulfil your requests. 

To send us an access and deletion request, or for questions, or further information please let us know where you are from so we can process your request and contact us under dataprotection-us-inc(at)gamigo.com 

Version: March 2025