Privacy Policy

PRIVACY POLICY | V.1.2

[:LAST UPDATE: 02 NOV. 2025]

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INTRODUCTION

Welcome to Shaga Labs, Inc. (“Shaga,” “we,” “us,” or “our”). We value your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, share, and safeguard your data when you access our platform (including our website https://shaga.xyz), applications, streaming interfaces, and any other services (collectively, the “Services”).

Controller v. Processor Roles:

Shaga acts as a data controller when it independently determines the purposes and means of processing personal data. This includes operating the gaming network, managing user accounts, distributing rewards, and maintaining system performance.

In some cases, such as integrations with third-party services or partner platforms, Shaga may process data solely based on the instructions of another entity. In these instances, Shaga acts as a data processor, and the third party remains the data controller. Where applicable, Shaga enters into a Data Processing Agreement (“DPA”) that outlines the scope, obligations, and safeguards involved.

By accessing or using the Services, you acknowledge that you have read and accepted the practices described in this Policy. If you do not agree, you should stop using the Services.

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SCOPE

This Policy applies to all data collected from:

Gamers who access or stream games through the platform;
Node Operators who contribute computing and bandwidth resources to the decentralized cloud network;
Content Creators and Streamers participating in referral, promotional, or affiliate initiatives;
Wallet Users, defined as users who connect a self-custodied wallet to Shaga for purposes such as earning, redeeming, or staking platform incentives.

Shaga’s platform supports an incentive system that begins with off-chain engagement (such as completing in-game actions, hosting gameplay, or enabling data sharing) and may lead to on-chain rewards, including tokenized incentives or Gaming Locally On Blockchain (“GLOB”) points.

This Policy does not apply to services that Shaga does not own or operate. This includes third-party game stores such as Steam and Epic Games, third-party analytics tools, or external wallet providers. Your interactions with those platforms are governed by their own privacy policies.

Where Shaga integrates with third-party platforms or provides services on their behalf, those third parties may determine how your personal data is used. In such instances, Shaga acts as a data processor, and the third party’s privacy policy governs how your personal data is handled.

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DATA WE COLLECT

Shaga collects personal data through direct input, automated tracking, and authorized third-party sources. This section outlines the categories of data we collect and how they relate to your use of the Services.

[:a DATA YOU PROVIDE ]

Account Information: Your name, email address, username, and regional or time zone settings.
Wallet Information: Public blockchain address, associated token identifiers, and wallet verification timestamps.
Support Interactions: Communications with Shaga support, including bug reports, feature requests, and dispute submissions.
Voice Data (Opt-In): If you enable voice chat or consent to voice data use, Shaga may collect audio from gameplay or communications. Voice data is not analyzed for identification or biometric profiling. Consent can be withdrawn at any time via your user dashboard.

[:b DATA WE COLLECT AUTOMATICALLY ]

Gameplay Recordings: In-game video and audio generated through gameplay, which may be captured or stored to support platform functionality, analytics, or approved partner uses.
Gameplay Telemetry: Frame rates, latency, control inputs, and other system performance metrics that support gameplay stability and optimization.
Streaming Activity: Session duration, approximate region (derived from IP address), and basic connection diagnostics.
Node & Hardware Telemetry: For users contributing hardware to the decentralized network, we collect data such as node uptime, GPU and CPU utilization, hardware diagnostics, bandwidth availability, and system reliability scores.
Device Information: Browser type, operating system version, device model, hardware specifications, and IP address.
Cookies & Usage Logs: Session identifiers, login timestamps, user preferences, crash data, and diagnostic logs.

This information is collected automatically and used to operate, secure, and improve the Services. It is processed under contractual necessity or Shaga’s legitimate interests and does not require additional consent. Where possible, we aggregate or pseudonymize telemetry and device-related data to minimize the identifiability of individual users. Data collected automatically is used primarily for technical optimization and service performance.

[:c THIRD-PARTY SOURCES ]

Shaga may receive personal or aggregated information from external sources to enable platform functionality, verify user access, or support enhanced features. These third-party sources may include:

Platform & Entitlement Services: Services that verify game ownership, platform access, or user entitlements across connected ecosystems.
Blockchain Observers & Infrastructure Providers: Tools that enable read-only access to on-chain wallet activity for purposes such as eligibility verification, fraud detection, or GLOB reward tracking.
Identity & Authentication Providers: Account connection services that facilitate login, profile linking, or community engagement through social identity verification or single sign-on capabilities.
Data & Analytics Services: Aggregated site usage data and engagement metrics to monitor platform health, performance trends, or gameplay patterns.
Content Tools & Creator Services: Systems that assist with gameplay recording, editing, distribution, or highlighting of user-generated content, such as video tools, clip feeds, or automated editors.
Feedback & Sentiment Platforms: Voluntary user surveys, bug reporting tools, or insight platforms that collect data to improve service offerings or assess community sentiment.
Custom Integrations & Developer APIs: Bots, extensions, or automation tools that interact with user accounts or in-session behavior to enhance functionality, notifications, or cross-platform interoperability.

A list of relevant vendors and categories may be made available on our site to supplement this summary. Shaga maintains contracts and operational controls to ensure these partners only process data in accordance with our instructions and applicable privacy law.

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HOW WE USE YOUR DATA

We use the personal data we collect to deliver, secure, and enhance the Shaga platform and to support features that benefit users through optional participation and incentives.

These uses include:

[:a CORE PLATFORM OPERATIONS ]

Operating, managing, and enabling access to the Services, including game streaming, account login, and edge-node connectivity
Matching users with optimized node hosts based on latency, bandwidth, and performance metrics
Resolving technical issues, ensuring uptime, and improving system reliability

[:b REWARDS, WALLETS & ELIGIBILITY ]

Administering platform-based incentives, including GLOB points, token rewards, and referral benefits
Verifying wallet ownership and on-chain eligibility for rewards or access tiers
Delivering discount-based or revenue-share incentives tied to data-sharing participation (Opt-In)

[:c GAMEPLAY & SYSTEM DATA (DEFAULT USE) ]

When you play, host, or stream through the Services, Shaga collects gameplay telemetry and system performance data. This includes frame rates, latency, control inputs, and similar metrics generated during normal platform use. The data helps keep gameplay stable, efficient, and adaptive to user demand.

Operating and optimizing gameplay, streaming, and edge-node performance.
Measuring system health, connectivity, and session reliability.
Diagnosing errors, maintaining security, and improving overall performance.
Analyzing gameplay trends and user interaction patterns to guide feature development.
Creating aggregated or de-identified datasets that may be used for analytics, research, or approved commercial licensing with trusted partners.

This information is processed as part of normal platform operations and does not require additional user action or consent.

[:d ENHANCED DATA CONTRIBUTION PROGRAM (OPT-IN) ]

Shaga may invite users to participate in the Enhanced Data Contribution (“EDC”) Program, which governs the collection of personal or sensitive data such as:

Voice or audio captured during gameplay.
Camera or biometric inputs, including facial or gesture data.
Chat or communications that may contain personal identifiers.

Participation in the EDC Program is voluntary and requires explicit consent through your account settings. The EDC Program does not include telemetry or system data already processed under the default gameplay and system data uses.

By enabling these features, you authorize Shaga to collect, de-identify, and use this sensitive data to improve platform intelligence and to support approved research or commercial partnerships, as described in this Policy.

You may withdraw consent at any time. Withdrawal stops future collection but does not affect previously de-identified or aggregated data.

[:e COMMUNICATIONS & SUPPORT ]

Contacting you with account-related notifications, updates, or support resolutions
Responding to your inquiries or feature requests
Providing legal or system alerts when required

[:e FRAUD DETECTION & LEGAL COMPLIANCE ]

Detecting fraudulent behavior, Terms of Service violations, or abuse of Services
Meeting legal obligations, including tax compliance, regulatory inquiries, and platform enforcement

Shaga does not sell personal data and does not use personal data for targeted advertising.Gameplay telemetry and other non-identifiable operational data are processed by default, while personal or sensitive elements are processed only with your consent under the EDC Program.

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BLOCKCHAIN & WALLET INFORMATION

Shaga operates using a hybrid infrastructure that combines off-chain accounts with on-chain wallet interactions. Your public wallet address may be associated with your Shaga user account in order to:

Tracking engagement for platform rewards or participation incentives;
Determine eligibility for access tiers, incentive programs, or monetized participation in EDC Program activities;
Validate session identity and protect against unauthorized access or node abuse; and
Administer content licensing rights, payout eligibility, or revenue share for users who opt into gameplay recording and data-sharing programs.

Shaga does not collect or store your private keys. Wallet transactions are conducted exclusively through third-party interfaces (e.g., wallet apps or browser extensions) under your control.

Information recorded on public blockchains is immutable, transparent, and cannot be deleted or altered by Shaga. However, where applicable, we will delink or pseudonymize associated wallet addresses from our systems when you request account deletion or deactivation, subject to technical feasibility.

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DATA SHARING UNDER THE EDC PROGRAM

Shaga offers users the opportunity to voluntarily contribute gameplay and engagement data through the EDC Program. This includes voice chat, camera input, biometric or gesture data, and identifiable communications. The EDC Program supports platform advancement, system intelligence, and approved research or development initiatives. Gameplay telemetry, system metrics, and other non-identifiable data are processed as part of normal platform operations and are not subject to this Program.

[:a TYPES OF DATA USED ]

If you participate in the EDC Program, Shaga may collect and process:

Voice & Audio Data: Voice chat recordings or in-session sound when the feature isenabled.
Camera or Biometric Data: Facial, gesture, or other sensor-based inputs when a compatible device is connected.
Chat & Communication Content: Text or audio messages that contain identifiable personal information.

Shaga does not collect biometric identifiers for the purpose of identification or profiling.Voice and camera data, where collected, are processed solely for gameplay-related functionality, system improvement, or approved research uses.

[:b PURPOSES OF USE ]

Data contributed through the EDC Program may be:

Used internally to develop or refine system features and predictive models;
Licensed to third-party research institutions or publishers for approved uses;
Analyzed to study user interaction trends, gameplay complexity, and system performance; and
Aggregated or pseudonymized where feasible prior to processing.

Shaga may share this data with third-party partners under limited-use agreements, including game developers, AI labs, or academic institutions. Shared data is aggregated, pseudonymized, or de-identified prior to disclosure, and does not include any directly identifying information such as your name, email, or wallet address.

[:c OPT-IN AND WITHDRAWAL ]

Participation in the EDC Program is voluntary and requires explicit, informed consent.

You may opt in or out through your account dashboard at any time. Withdrawal stops futurecollection and processing under this Program but does not affect data that has already been aggregated or used in ongoing research or development.

[:d INCENTIVES ]

Users who participate in the EDC Program may receive incentives, such as:

Platform credits or subscription discounts;
Access to exclusive features or early beta tools; and/or
Revenue shares if your gameplay data is used in a qualifying third-party project.

Incentives are granted only when your data is used in a licensed project and associated usage thresholds are met. Specific eligibility and terms are disclosed at the time of opt-in.

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COOKIES AND TRACKING TECHNOLOGIES

Shaga uses cookies and similar tracking technologies to support the functionality, security, and performance of the platform. These tools allow us to manage user sessions, measure engagement, and maintain functionality across devices and browsers.

The types of cookies we use may include:

Strictly Necessary Cookies: Required for basic operation of the Services (e.g., login, session management);
Performance Cookies: Help us analyze system performance and improve gameplay experiences;
Functionality Cookies: Remember user preferences and support platform customization; and
Analytics and Integration Cookies: Set by third-party services to help us understand site usage or provide content delivery, integrations, or EDC Program interactions.

Where required by law, we display a cookie banner that allows you to manage your preferences before any non-essential cookies are activated. You may also configure your browser settings to block or delete cookies. However, disabling certain types of cookies may affect your ability to access or use specific features of the Services.

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DATA SHARING & DISCLOSURE

We do not sell your personal information. We share data only when necessary to operate theServices, comply with legal obligations, or support approved development and research initiatives.

The categories of recipients include:

Service Providers that support platform hosting, infrastructure, diagnostics, analytics, or customer support;
Game Platform Partners that verify entitlements, enable access to third-party content, or facilitate integrations (e.g., Steam or Epic Games);
Payment Processors and Billing Vendors that manage financial transactions, token distribution, or subscription services;
Blockchain Infrastructure Providers that assist with wallet validation, smart contract execution, and decentralized network performance;
Research and Development Partners, including academic institutions, labs, or developers that receive data under controlled access for analytics, model training, or system improvement;
Regulatory or Legal Authorities when required under applicable law or pursuant to lawful requests; and
Security and Enforcement Partners as needed to investigate fraud, enforce our Terms of Use, or protect user rights and platform integrity.

Shaga may share aggregated or de-identified telemetry and gameplay data with trusted partners for analytics, system optimization, or product research. Personal or sensitive data contributed through the EDC Program is shared only with your prior consent and under specific use restrictions. We do not authorize third parties to use your personal data for their own advertising or marketing purposes.

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DATA STORAGE & RETENTION

Shaga retains personal data only as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law, audit obligations, or contractual arrangements. Technical, administrative, and physical safeguards are applied to help prevent unauthorized access, alteration, or misuse.

The typical retention periods by data category are:

Account Information: Retained until your account is closed or a verified deletion request is processed.
Wallet Linkage: Delinked upon request from Shaga’s internal systems. Public blockchain records remain immutable and outside our control.
Telemetry and Streaming Logs: Retained for 90 days to support diagnostics, platform optimization, and system reliability.
Rewards and GLOB Point History: Retained as needed to comply with tax reporting, audit verification, and program dispute resolution.
Cookies and Tracking Data: Session-based or retained for up to 12 months, depending on cookie type and applicable consent settings.
Gameplay Recordings: Retained for up to 24 months, or until they are used in model training, research, or licensed projects, whichever comes first.
Voice Recordings (Opt-In): Retained for up to 90 days unless used in AI model development or licensed research; in such cases, retention may continue for the life of the associated project or agreement.
Backup Data: Encrypted and stored securely for up to 180 days prior to automated deletion.

If you have participated in the EDC Program, your contributed data may be integrated into model training, licensed research, or aggregated datasets. Once integrated, retroactive deletion may not be feasible.

However, upon withdrawal of consent:

No further data will be collected or processed under the EDC Program;
Unused data will be deleted, delinked, or anonymized where possible;
Future licensing or reuse of your data will cease unless re-authorized.

All retained data is stored on secure servers, encrypted in transit and at rest. Access to archives, gameplay recordings, or voice data is limited to authorized personnel and governed by strict role-based access controls and audit protocols.

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YOUR RIGHTS

You have rights over your personal data, subject to applicable law, contractual obligations, and technical limitations. These rights empower you to control how your data is used and to manage your participation in optional programs.

You may have the right to:

Access the personal data we store about you;
Correct or update inaccurate or incomplete data;
Request deletion of your personal data (off-chain only);
Object to processing of your personal data under specific legal grounds;
Withdraw consent for optional features such as integrations, newsletters, platform integrations, or participation in the EDC Program; and
Manage opt-in or opt-out preferences for gameplay recordings, voice data, and data sharing under the EDC Program.

Where your account is linked to a blockchain wallet, Shaga may require cryptographic verification through a third-party wallet processor to confirm ownership before fulfilling certain requests.

Due to the immutable and decentralized nature of public blockchains, data recorded on-chain cannot be altered or deleted. However, Shaga will, where technically feasible, delink associated wallet addresses and related metadata from your internal user profile following a valid deletion request.

If you previously consented to participate in the EDC Program, please note that withdrawal applies only to future use. Any data already used for development, research, or licensing may not be retrievable or de-identified from external systems.

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INTERNATIONAL DATA TRANSFERS

Shaga operates globally, which means your personal data may be transferred to, and processed in, countries outside of your jurisdiction. These transfers may involve regions that do not have data protection laws equivalent to those in your home country.

When we transfer personal data across borders, we apply appropriate safeguards in accordance with applicable data protection laws, including but not limited to:

Standard Contractual Clauses (“SCCs”) approved by the European Commission
The UK International Data Transfer Addendum (“UK IDTA”)
Other contractual, technical, or organizational measures required by jurisdictions such as the California Consumer Privacy Act (“CCPA/CPRA”), Brazil’s LGPD, and Canada’s PIPEDA
Encryption of data in transit and controls restricting access to authorized personnel only

If you participate in the EDC Program, your gameplay or voice data may be accessed or processed by licensed research institutions, infrastructure partners, or development collaborators outside your jurisdiction. Such transfers are also governed by the safeguards described above and will not occur without your prior consent.

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CHILDREN’S DATA

Shaga’s Services are not directed to, and are not intended for use by, individuals under the age of 16. We do not knowingly collect, use, or process personal data from anyone below this agethreshold. If we learn that personal data has been collected from a child without verified parental or guardian consent, we will promptly delete that data and disable any associated accounts.

Users between 16 and 18 years old (or the age of digital majority in their jurisdiction) may access the Services only with verifiable parental or guardian consent. Where required by law or platform policy, Shaga may request cryptographic, documentary, or third-party age verification to confirm eligibility.

Participation in Shaga’s optional features (including wallet registration, token-based rewards, gameplay data sharing, and the EDC Program) is limited to verified users who have reached the age of digital consent in their country. If Shaga becomes aware that data from an ineligible user has entered the EDC Program or any other data-sharing initiative, that data will be removed from future processing or licensing to the extent technically feasible.

By accessing or using the Services, you confirm that you meet the minimum age requirement in your jurisdiction or that you have obtained verifiable parental or guardian consent to use Shaga’s platform.

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CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal obligations. When we make changes, we will revise the “Last Update”date at the top of the policy.

If a change materially affects your rights or how we collect, use, or share your personal data, we will provide prominent notice prior to the change becoming effective. This may include email notifications, in-app alerts, or updates via your account dashboard, as required by law.

You are encouraged to review this Privacy Policy regularly to stay informed about how Shaga manages your data. Continued use of the Services after a revised Policy becomes effective constitutes your acceptance of the updated terms.

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CONTACT US

If you have questions or concerns regarding this Privacy Policy, or if you wish to exercise your data rights, you may contact us at:

Email: legal@shaga.xyz

Mailing Address: ATTN: Legal Department; 8 The Green, STE 21181; Dover, DE 19901; USA

If you are a resident of the European Economic Area (“EEA”), United Kingdom, or another jurisdiction with a designated data protection authority, you may also have the right to file a complaint with your supervisory authority.