Effective Date: January 5th, 2024
Toaster Corp., a Delaware corporation, and Titanium Toaster (Bermuda)
Ltd., its Bermuda subsidiary (collectively, “we,” “our,”
and their derivatives) provide websites, including
and its subdomains (collectively, our “Websites”), the
video game known as Cubieverse (our “Game”), and other
online services (collectively, with our Websites and our Game, our
1. What does this Policy cover?
use, protect, store, disclose, and otherwise process your Personal
Data (defined below). This Policy does NOT apply to information you
provide to any third party or is collected by any third party (except
as otherwise provided below).
using our Services, you are confirming that you understand English
well enough to understand this Policy. Should you have questions
about this Policy, please contact us by emailing us at
2. How do we process Children’s Personal Data?
Our Services are not designed for Children, and we do not
intentionally or knowingly collect, use, store, disclose, or
otherwise process any Personal Data from Children. A “Child”
is a person under the age of digital consent (e.g., 18 years old in
the United Kingdom and 16 years old in the United States and Canada).
If you are a parent or guardian of a Child who has submitted Personal
Data, please contact us by emailing us at
3. What categories of Personal Data do we collect?
may collect different types of information from you depending on how
you use our Services, including Personal Data. “Personal Data”
means information that relates to an identified or identifiable
natural person. The categories of Personal Data we may collect are
When you visit our Websites, we may collect your:
- IP address; and
- website activity.
When you play our Game, we may collect your:
- email address;
- device ID;
- date of birth;
- headquarters location (for example, the latitude and longitude of
your preferred playing location);
- physical location or movements, including how many steps you take;
- gameplay information;
- purchase and sales history;
- gift card and prize information;
- first and last name (for non-U.S. users); and
- cryptocurrency exchange account information (for non-U.S. users).
may collect information from the content that you share publicly in
our Game through public functions (for example, your Discord and
Twitter IDs) or that you send to us directly when we communicate (for
example, photographs of your hand for fraud prevention purposes).
may also collect information that does not generally identify you but
may become associated with your account. We may use information that
does not identify you for any permissible purpose under applicable
4. From what sources do we collect Personal Data?
Directly From You
may collect your Personal Data when you provide it to us directly,
including the examples below.
- When you access our Game, we may collect your date of birth for
- When you register for an account to use our Game, we may collect
your email address and username to create an account.
- When you play our Game, we may collect your gameplay information to
provide our Game.
- When you win a contest in-Game, we may collect information needed to
award the prize.
- When you complete purchases or sales, we may collect your purchase
and sale history to fulfill those transactions.
- When you exchange in-game currency for cryptocurrency or gift cards,
we may collect your email address and conversion information to
fulfill those transactions.
- When you contact us, we may collect records and copies of your
correspondence to respond to such inquiries.
- When you use the public functions in our Game, we may collect the
information you choose to disclose such as your Discord or Twitter
ID to enable those features and for data analytics.
- When you submit a photograph of your hand, we may collect that image
for fraud prevention purposes.
- When you respond to a survey or questionnaire, we may collect the
information you provide for internal business purposes.
may receive your Personal Data from or through third parties that
help us provide or facilitate your access to our Services, including
those listed below.
- Mobile device carriers: For example, when you access our
Game, we may receive your country for age-gating purposes, and when
you register an account for our Game, we may receive your device ID
for fraud prevention purposes. By way of another example, when you
play our Game, we may receive your headquarters location, physical
location or movements, and how many steps you take to provide
geo-specific Game services and features.
- Cryptocurrency exchanges such as Catalyx, Orca, Biteeu, and
Complex: For example, when you convert in-game currency to
cryptocurrency, we may receive your first and last name and account
information to fulfill those transactions.
- Android and iOS stores such as Apple and Google: For example,
when you make purchases, we may receive your purchase history to
fulfill those transactions.
- Gift card platforms such as Tillo: For example, when you
convert in-game currency to a gift card, we may receive whether you
spent the gift card for tracking purposes.
abide by this Policy when we use Personal Data provided to us by
third parties. However, we may not control the Personal Data that
third parties collect or how they use that Personal Data. You should
review the third parties’ privacy policies for more information
about how they collect, use, and share the Personal Data they obtain
are small data file identifiers that are transferred to your computer
or mobile web browser that allow third parties to recognize your
browser or mobile device and transfer information about you and your
use of our Websites.
Party Cookies and Other Automatic Data Collection Technologies
and other automatic data collection technologies on our Websites may
come from third parties as listed below. These cookies and other
automatic data collection technologies improve your experience by
helping us better tailor our Websites to you.
- Google Analytics is a web analysis service of Google Inc., 1600
Amphitheatre Parkway, Mountain View, CA 94043, United States. The
Personal Data such as your IP address and website activity collected
by Google in connection with your use of our Websites is transmitted
to a server of Google in the United States, where it is stored and
analyzed. Google’s collection and use of Personal Data is subject
may set your browser to refuse all or some browser cookies (e.g., by
opting out of Google Analytics at
or to alert you when cookies are being sent. Please note that, if you
technologies, some aspects of our Websites may be inaccessible or not
6. For what purposes do we collect your Personal Data?
addition to the purposes described above, we may collect your
Personal Data for the below purposes.
- To provide or improve our Services: We may use your Personal
Data to process your requests to access our Services and certain of
their features and to generally present and improve our Services.
For example, we may use your Personal Data to improve our Game.
- To administer our Services: We may use your Personal Data for
any lawful business or operational purpose in connection with
administering our Services. For example, if you reach out to us, we
may use your Personal Data to respond to you or to troubleshoot a
problem you reported having with our Services.
- To market our Services: We may use your Personal Data to
market our Services to you. For example, with your prior consent, we
may send you news and updates about our products and our Services.
- In furtherance of legal and safety objectives: We may access,
use, and share with others your Personal Data for purposes of safety
and other matters in the public interest. We may also provide access
to your Personal Data to cooperate with official investigations or
legal proceedings (e.g., in response to subpoenas, search warrants,
court orders, or other legal processes). We may also provide access
to your Personal Data to protect our rights and property and those
of our agents, users, and others, including to enforce our
agreements, policies, and our Terms
of Service. For example, we may use your Personal
Data to respond to inappropriate conduct in-Game and to enforce user
bans for our Game.
- In connection with a sale or other transfer of our business:
In the event all or some of our assets are sold, assigned, or
transferred to or acquired by another company due to a sale, merger,
divestiture, restructuring, reorganization, dissolution, financing,
bankruptcy, or otherwise, your Personal Data may be among the
- As we may describe to you when collecting your Personal Data:
There may be other situations when we collect your Personal Data and
simultaneously describe the purpose for that collection.
only collect, use, or store your Personal Data for a lawful basis
- you voluntarily provide it to us with your specific, informed, and
unambiguous consent (for example, when you sign up for a marketing
- it is necessary to provide you with a Service that you have
requested (for example, providing you access to our Game);
- we have a legitimate business interest that is not outweighed by
your privacy rights (for example, to respond to your inquiries); or
- it is necessary to protect your vital interests or the vital
interests of others (for example, where necessary to protect the
safety of one of our users or someone else).
7. In what situations do we disclose your Personal Data?
may disclose your Personal Data to third parties that help us provide
or facilitate your access to our Services, including those listed
- Gift card platforms such as Tillo and related brands shown
in-Game: For example, when you convert in-game currency to a
gift card, we may disclose that conversion to fulfill the
transaction. By way of another example, when you win a contest
in-Game, we may disclose the information needed to award the prize
to that particular brand.
- Player support providers such as Zendesk: For example, when
you contact us, we may disclose that correspondence for support
purposes. By way of another example, when you submit a photograph of
your hand, we may disclose that photograph to our player support
providers for fraud prevention purposes.
We may also disclose your Personal Data:
- to our subsidiaries and affiliates;
- to our lawyers, consultants, accountants, business advisors, and
similar third parties who owe us duties of confidentiality;
- to a buyer or other successor in the event of a sale, merger,
divestiture, restructuring, reorganization, dissolution, or other
transfer of some or all of our assets, whether as a going concern or
as part of bankruptcy, liquidation, or similar proceeding, in which
Personal Data retained by us pertaining to the users of our Services
is among the assets transferred;
- to comply with any court order, law, or legal process, such as
responding to a government or regulatory request;
- to enforce any contract we may have in effect with you;
- if we believe disclosure is necessary or appropriate to protect the
rights, property, or safety of us, our users, or others; and
- if you have consented to such a disclosure.
8. How do we treat Personal Data transferred to the United States?
Place of Business
may store or process your Personal Data outside of the country where
we collect the information or the country in which you reside. Our
primary place of business is in the United States. You should
understand that we may transfer some or all of your Personal Data to
the United States to carry out certain operational and processing
needs as described in this Policy.
transferring Personal Data out of foreign countries, we implement
technical, organizational, and physical safeguards to protect your
Personal Data. We use European Commission approved standard
contractual clauses and implement related measures where required by
applicable law. Please contact us if you have questions related to
the relevant transfer mechanism for your Personal Data.
9. How is my Personal Data protected?
Retention, Purpose Limitation, and Security Policies
protect your Personal Data through a combination of collection,
security, and retention policies.
- Limited retention: We retain each category of Personal Data
only for as long as necessary to fulfill the purposes for which the
Personal Data was provided to us or, if longer, to comply with any
legal obligations, to resolve disputes, and to enforce contracts.
For example, we may retain Personal Data collected about you to
prevent repeated violations or suspected violations of our Terms
of Service if your account has been banned or your
access to our Services has been disabled for any reason. 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
the Personal Data, the purposes for which we process the Personal
Data and whether we can achieve those purposes through other means,
and the applicable legal requirements. For example, subject to the
foregoing considerations, it is our policy to delete your Personal
Data if we stop operating our Game or the feature through which the
Personal Data was acquired.
- Purpose limitation: We will use your Personal Data only for
our Services you choose to access and for the purposes notified to
you, unless we otherwise obtain your consent. We limit the
collection of Personal Data to what is adequate, relevant, and
reasonably necessary for those purposes.
- Security measures: We use reasonable security measures to
ensure a level of security appropriate to the volume and nature of
Personal Data processed and risk involved, considering the size,
scope, and type of our business, and have implemented contractual,
technical, administrative, and physical security measures designed
to protect your Personal Data from unauthorized access, disclosure,
use, and modification, including industry-standard encryption for
the transmitting of Personal Data and industry-standard hashing
techniques for the retention of Personal Data. As part of our
privacy compliance processes, we review these security procedures on
an ongoing basis to consider new technology and methods as
necessary. However, please understand that our implementation of
security measures as described in this Policy does not guarantee the
security of your Personal Data. In the event of a security breach,
we will notify the proper regulatory authorities and any affected
users of the breach within 72 hours after we become aware of the
breach to the extent required by applicable law.
Practices and Activities
practices and activities are likewise very important for the
protection of your Personal Data. You should take certain steps to
help protect your Personal Data, such as being mindful of what you
share publicly in our Game, including the below.
- Do not use your real name when selecting a username.
- Do not share your real name or anything private about yourself or
anyone else with other users of our Game.
- Do not pick a password that is easy to guess, and do not share your
remember that we have no control over what other users do with the
content of your communications and no responsibility or obligation
regarding other users.
10. What rights do you have to your Personal Data?
to Access, Correct, Delete, or Restrict Processing
to any limitations and exceptions under applicable law, you may have
the right to request access to your Personal Data and exercise the
- You may have the right to correct or update certain types of
Personal Data. In many cases, you can review or update your account
information by accessing your account online.
- You may have the right to request deletion of your Personal Data. If
you choose to have your Personal Data removed from our Services, we
will carry out your request within 30 days of account verification,
subject to extension, and we will only retain minimal Personal Data
to document your request and the actions we took to carry out your
- You may have the right to restrict certain processing of your
Personal Data and the right to object to some types of processing of
your Personal Data.
- You may have the right to withdraw your consent at any time.
- You may have the right to lodge a complaint regarding our
collection, storage, or processing of your Personal Data with a data
protection supervisory authority in the country where you live or
will comply with your requests in accordance with, and subject to,
applicable law. For example, we are not required to delete your
Personal Data if we have an overriding legitimate ground for
retaining that information, such as to prevent fraud. Please note
that we are legally prohibited from carrying out requested actions in
some instances, including (1) when we are unable to confirm your
identity or (2) where doing so would adversely affect the rights or
freedoms of others. Further, we are not required to carry out a
requested action in some instances, including where the request is
are Here to Help
email us at firstname.lastname@example.org
with the subject line “Privacy Request” if you would like to
exercise any of the rights described above or if you have questions
regarding your rights.
11. Additional Notice for California Residents pursuant to California Online Privacy Protection Act
do not track users of our Services over time and across third party
websites or online services and therefore do not respond to Do Not
Track signals. We are not aware of any third party that tracks users
of our Services over time and across third party websites or online
services. Please note that Do Not Track is a different privacy
mechanism than the Global Privacy Control, a legally recognized
browser-based control that indicates whether you would like to opt
out of the processing of your Personal Data for certain purposes.
12. How will we notify you of changes to this Policy?
reserve the right to change this Policy from time to time consistent
with applicable law. If we make changes to this Policy, we will
notify you by revising the date at the top of this Policy and provide
you with additional notice such as an in-Game notice or email
13. How can you contact us?
you have questions, you may email us at
you are a law enforcement agency, please email us at
with your request for Personal Data with the subject line “Law