Effective Date: 2026-08-12

Privacy Policy

Effective Date: 2026-08-12

1. Introduction

OVERDARE Inc.("we", "our", "Company" or "us") collect, use and process information about you("you" or "user"). We provide various services related to our app, website, event, survey, or customer service("Services"). This Privacy Policy ("Policy") covers the personal information that is provided, collected, or generated when you access, use or subscribe to our Services, except where separate privacy policies or terms and conditions apply. This Policy applies to our Services. Also explains the rights and choices you have with respect to this data, and how you can communicate with us. This Policy does not apply to and cannot control activities when you click or visit other sites from our Services.

'Forum' means the creators-only discussion board we operate at forum.overdare.com (or any successor URL). The Forum is part of our 'Services.'

We will occasionally update this Policy. When we do, we will revise the effective date above. While we will periodically inform you of this Policy or any material changes to it, your continued use of our Services after such changes means you accept the Policy as revised. We encourage you to periodically review this Policy to stay informed about how we collect and process your personal information. From time to time, we may ask you to confirm your acceptance of this Policy when we offer our Services.

2. What Information Do We Collect

We will collect the following categories of information that may directly or indirectly identify or describe you or your device or information that may be reasonably capable of being associated with or reasonably linked to you or your device. We collect your information with your consent, or when it is necessary to comply with legal obligations or to enter into or perform under a contract. The information you provide to us may differ depending on the circumstances. For example, these include:

Identifiers, such as phone number, email address, social media information(*), nickname, date of birth, etc.;
Commercial Information such as, purchase date and time, order number, amount, etc.;
Visual Information such as, profile image;
Payout details such as payout date and time, payout quantity;
Tax-documentation data, such as U.S. SSN / ITIN / EIN, foreign TIN, any treaty-claim details, etc.;
Wallet information such as wallet address, applicable only when linked;
Device or Network Information such as, device model, OS version, MAC address, device ID, advertisement ID(ADID, IDFA), etc.; and
Service information, such as information about crash report and system activity details (i.e. app setting, play date/time, etc.).
Forum-Activity Information - username, posts, replies, reactions, bookmarks, IP address, device data, and moderation logs associated with your use of the Forum;
AI Conversation Data - When you use AI-powered features within the Services, including AI agents that assist in developing UGC ("AI Features"), we collect the text, code, images, and other content you submit as input to AI Features ("AI Inputs"), AI-generated responses, code, assets, and other materials provided to you through AI Features ("AI Outputs"), and conversation logs between you and the AI agent. This data is collected directly from your interactions with AI Features on the OVERDARE platform. For clarity, data processed by third-party AI service providers that you access using your own credentials is governed by such providers' privacy policies. The terms AI Inputs, AI Outputs, and AI Features are defined in Section 4.5 of the Creator Terms;
AI Usage Data - We automatically collect technical and behavioral information related to your use of AI Features, including session timestamps, feature usage frequency, error logs, performance metrics, and aggregate statistics on asset and World usage patterns. AI Usage Data also includes the operation, diagnostic, and session logs we generate from your use of the AI Features for service operation and improvement, error and troubleshooting analysis, and analytics; any substantive content detected within such logs is masked or removed. AI Usage Data does not contain substantive content created by you.
AI Conversation Data and AI Usage Data are collectively referred to as "AI Training Data.

"Please note that when you use social features (such as in-service chat or the Creator's Forum), the information you disclose becomes public. We may store and access this information, and it may be read, copied, collected, or used by other users without your consent.

(*) When you access our Services using your platform account, Google, we collect certain information from the third-party platform provider, such as your platform profile/account, consistent with the terms of the third-party platform and your privacy settings thereon.

We use this data to operate and improve our Services. Some of this information is collected through our use of cookies and related online tools/technologies. See our "Cookies and Related Technologies" section below for more information.

3. How We Use Your Information

We use the collected information for a variety of purposes, primarily, to provide the Services to users like you and to improve the quality of our Services. These include:

To operate and provide our Services;
To operate, secure, moderate, and improve the Creators' Forum and enforce our Community Guidelines.
To develop new services, improve the quality of our Services, and fix bugs;
To detect and act upon the illegal or unauthorized use of our Services;
To manage inquiries and requests from you (e.g. refund, etc.);
To verify your phone number when you link it to your account;
To help you find or invite friends, by accessing your device's contacts with your permission;
To provide advertising information and other information on marketing, and conduct promotional events and surveys;
To use indicator analysis for tracking usage patterns, analyzing trends of users, and calculating statistics on Services;
To prevent, detect, identify, investigate, and respond to potential or actual claims, liabilities, prohibited behavior, cheating, hacking or criminal activity
To collect, verify, file, and (where required) furnish tax forms (e.g., Forms W-8BEN, W-9, 1042-S, 1042, 1099) and to meet global withholding-tax obligations;
To comply with and enforce legal requirements, agreements, and policies;
To facilitate World Product transactions;
To monitor, filter, and moderate AI Inputs and AI Outputs for safety, security, and compliance with the Creator Hub Review Guidelines, including to detect and prevent prohibited content and to improve the effectiveness of our content moderation systems (Legal Basis: Legitimate interest in maintaining platform safety and integrity); and
To train, validate, test, and improve OVERDARE's artificial intelligence and machine-learning models, systems, and related technologies, using AI Conversation Data in de-identified form, with your separate consent (Legal Basis: consent). Separately, and as a distinct purpose, we use AI Usage Data to operate and improve the Services on the basis of our legitimate interest, as such data does not contain substantive content created by you; you may exercise your right to object to that processing as described in Section 11. OVERDARE does not use AI Training Data to profile, score, or target individual users, and does not provide AI Training Data to third parties for their independent AI training purposes. The detailed terms governing the license for AI Conversation Data used in model training are set forth in Section 4.5 of the Creator Terms.

Most of the time, our processing of your personal information is necessary to respond to you or process your request. We may also process your information to comply with a relevant legal obligation. Therefore, please understand that if you do not provide your personal information, it may be difficult to achieve the above purposes. From time to time, we may ask for your consent to use your information for specific reasons. Where consent was provided and is required, you may withdraw your consent at any time by contacting us at the address provided in this Policy.

4. How We Share Your Information

We share certain personal information with third parties to provide our Services to you, including service providers that process personal information on behalf of us to provide our Services to you, like customer support and to manage our community. Some examples of these third parties are provided below.

Cloud computing service providers to provide cloud storage services;
Authentication and messaging service providers to link and verify a phone number with your account;
Chatting service providers to help you communicate in Services;
Marketing platforms and providers of analytics services relating to player behavior, in order to tailor the Service and to conduct marketing activities;
Third party payment service providers (including but not limited to App Store, Google Play) to assist with payment for transactions or providing withdrawing service for sellers;
Third party payout service providers;
3D image rendering service provider to provide you with a 3D image modeling service;
Creators of the World Product you purchase; and
Buyers of your World Product.
Third-Party AI Service Providers. AI Features may require you to authenticate with and use third-party AI service providers using your own credentials and account. In such cases, your data is transmitted directly from your device to the third-party provider's servers, and OVERDARE does not act as an intermediary for such data transfers; however, OVERDARE separately collects AI Training Data on the platform side as described in Section 2 for the purposes set forth in Section 3. Your use of third-party AI services is governed by the applicable provider's terms of service and privacy policy. We encourage you to review the applicable third-party privacy policies before using AI Features. OVERDARE does not share AI Training Data with third parties for their independent AI model training purposes; however, OVERDARE may engage authorized sub-processors to process AI Training Data solely on OVERDARE's behalf and under OVERDARE's instructions, subject to appropriate data processing agreements. Such sub-processors may not use AI Training Data for their own independent purposes, including independent AI model training.
AI Training Data. For the avoidance of doubt, AI Training Data (as described in Section 2) is processed by OVERDARE (or its authorized sub-processors acting solely on OVERDARE's behalf) for the purposes described in Section 3 of this Policy.
Gift-certificate fulfillment providers, in order to purchase and deliver mobile gift certificates for our events and promotions (e.g., PlanS Co., Ltd., processing on behalf of OVERDARE Korea, Inc.).

We may share your information where such disclosure is essential to comply with a legal obligation or a lawful data access request, pursuant to a merger or acquisition, with our affiliates(Overdare Korea, Inc. and Settlus, Inc.) for the purposes described in this Policy, or where you have otherwise provided your consent or at your direction.

5. Cookies and Related Technologies

We use cookies and other technologies to recognize your browser or device, learn more about your interests, and provide you with essential features and services and for additional purposes. Approved third parties may also set cookies and related technologies when you use our Services.

Cookies are small files downloaded to your computer (if your browser is enabled to accept cookies) to track movements within websites and to customize your experience within the website. Most Internet browsers will allow you to erase cookies from your computer's hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You should refer to your browser instructions or "Help" screen to learn more about how to manage cookies. Please note, however, that if you block cookies, some portions of our websites may not function properly.

We do not control cookies in third-party ads, and you are encouraged to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology. Ads appearing on our websites may be delivered to you by third-party advertising companies. These companies may use information about your visits to our websites in order to provide advertisements to you and other sites about goods and services that may be of interest to you.

Website and App Analytics

We use analytics services on our websites to allow us to record information on the use of this Site and to constantly improve our offering.

We use Google Analytics, provided by Google Inc., which collects personal data and uses cookies for reporting purposes. You can withdraw your consent by adjusting Google's advertising settings (https://myadcenter.google.com/) and learn about Google's privacy policy at https://policies.google.com/privacy. Opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

We may use mobile applications to utilize analytics services for understanding app usage and optimizing user experience.

6. International Data Transfers

We operate globally and to provide our Services may transfer your data to countries and other regions outside the country where you are located. If your personal information is transferred, stored or processed by us, we take reasonable steps to safeguard the privacy of your personal information, including entering confidentiality and standard contractual clauses with vendors where appropriate. Additional information concerning the international transfer of your information is available depending on your region.

OVERDARE stores and processes AI Training Data on servers located in the United States, the Republic of Korea, and Japan. Your information may be transferred to and processed in countries other than your country of residence, including the United States and Japan. Where required by applicable law, such transfers are made pursuant to appropriate safeguards, including Standard Contractual Clauses (SCCs) approved by the European Commission. If you are located in the European Economic Area (EEA), Switzerland, or the United Kingdom, you may request a copy of the applicable safeguards by contacting us at ovdr_privacy@overdare.com.

* United States. If you are located in the United States, AI Training Data relating to you may be transferred to, stored on, and processed on servers located in the Republic of Korea and Japan, outside the United States. As described in Section 2, we currently collect AI Training Data from U.S. users on a pseudonymous basis (without the account identifier). When this information is transferred and processed abroad, we protect it through appropriate contractual and technical safeguards, including data processing agreements with our affiliates and sub-processors, access controls, encryption in transit and at rest, and de-identification or masking where applicable. We do not "sell" AI Training Data and we do not "share" it for cross-context behavioral advertising, as those terms are defined under applicable U.S. state privacy laws. If we later transition to collecting AI Training Data from U.S. users on an account (identified) basis, we will update this Policy, provide notice of that change before it takes effect, and, where required by applicable law, obtain any additional consent or provide any additional opt-out mechanism before doing so.

7. Retaining and Deleting Personal Information

In principle, we will remove your personal information without delay after the purpose of collecting personal information is achieved. Personal information stored in physical form will be shredded or incinerated, and personal information stored electronically will be removed using technical measures in a way that the information cannot be reproduced. However, we may retain your personal information even after you have closed your account with us or we have ceased providing Services to you, if retention of your personal information is reasonably necessary to comply with our legal obligations, meet regulatory requirements, tax obligations, resolve disputes, prevent fraud, cheating or abuse, or enforce this Policy or any other agreement we may have with a user.

Forum posts you publish remain visible until you delete them individually or request account deletion; residual copies may persist in backups for up to 30 days before being overwritten.

With respect to AI Training Data (as described in Section 2), the following retention periods and deletion criteria apply to each category, in each case subject to any longer retention reasonably necessary for the legal, regulatory, tax, dispute-resolution, fraud-prevention, and enforcement purposes described above:

AI Account & Identifier Data. Retained while your account remains active and you continue to use the AI Features. We delete or anonymize this data within thirty (30) days following deletion of your account or withdrawal of your consent to the AI Features, except where longer retention is required by applicable law.

AI Conversation Data. Used for model training only in de-identified form. Any identifiable conversation data held pending de-identification is retained for no longer than ninety (90) days, after which it is de-identified or deleted. Once de-identified or aggregated and incorporated into AI models, the data is no longer considered personal information under applicable law and may be retained for as long as necessary to fulfill the purposes described in this Policy.

AI Usage Data. Retained in identifiable form for no longer than twelve (12) months following the date of collection (or your last use of the AI Features, if earlier), after which it is deleted or aggregated. If you object to (opt out of) this processing, we will cease using your newly generated AI Usage Data for service operation and improvement and will delete or de-identify your existing identifiable usage logs within thirty (30) days, except where retention is required for security or legal purposes.

8. Our Policy Concerning Children and Minors

We do not knowingly collect, use or share any information about underage users(the age rating depends on the country where you reside) without verifiable parental consent or as permitted by law. We require the parent or guardian to consent to the processing of personal information for underage users in some countries, so if you are a parent or guardian and you believe your child has provided us with information without your consent, you can contact us and request your child's information to be deleted from our system.

Our policy on children and minors concerning the AI Features is set out below:

Age determination. We use the date of birth collected as AI Account & Identifier Data (Section 2) to determine your age category and to apply the protections described below.

Children under 13 (United States). The AI Features are not directed to, and we do not knowingly make the AI Features available to, children under 13 in the United States without verifiable parental consent obtained in accordance with the Children's Online Privacy Protection Act (COPPA). Consistent with the COPPA Rule, we treat the use of a child's personal information to train or develop artificial intelligence as a separate use that requires its own verifiable parental consent. Accordingly, we do not use the personal information of a known child under 13 for AI model training, and we do not retain a known child's AI Training Data for longer than reasonably necessary to fulfill the purpose for which it was collected.

Teens (ages 13-17). For users we know to be minors who are permitted to use the AI Features under applicable law, we limit our processing of AI Training Data to what is permitted under applicable U.S. state and other laws. We do not sell minors' personal information and do not use it for targeted advertising or cross-context behavioral advertising, and we do not process a minor's AI Training Data for any purpose that requires the minor's (or, where applicable, the parent's) consent unless and until that consent has been obtained.

Exclusion from model training. By default, we exclude users we know to be minors from the AI Model-Training category described in Section 2. We do not use a known minor's conversation or session data for AI model training, regardless of any opt-in setting, unless we have obtained the consent required by applicable law (including, for a child under 13, verifiable parental consent).

Parental rights. If you are a parent or guardian and believe your child has used the AI Features or provided personal information without the consent required by law, you may contact us at ovdr_privacy@overdare.com to request access to, or deletion of, your child's information.

9. Links and Third-Party Services

If you click on a link to a third-party website, including, without limitation, an advertisement, you will leave our website and go to the website you selected. Because we cannot control the activities of third parties, we cannot guarantee that they will adhere to the same privacy and security practices as we do. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third-party website that is linked to our Services, you should consult that site's privacy policy before providing any personal information.

10. Security of Your Information

We have put in place appropriate security measures, including encryption and de-identification, to protect your personal information. In addition, we limit access to your personal information to those employees, agents, persons, or companies who have a business need to know or access the information. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality where appropriate. Please note, however, that no data transmission over the internet is 100% secure, and that complete security of any information we collect and use therefore cannot be guaranteed.

11. Your Privacy Rights

Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your personal information, and to request access to, erasure, correction, and portability of your own personal information. Additionally, you may withdraw consent, oppose the use of your data for direct marketing, and contest decisions based on automated processing that significantly affects you. To make a request concerning your rights or if you have any other questions, please contact us by sending an email to the address specified in the "13. Contact Us" section. We respond to all requests we receive from individuals wishing to exercise their data protection rights under applicable data protection laws.

AI Training Data Rights. With respect to AI Training Data, you may request access to, correction of, or deletion of your identifiable AI Training Data by contacting us at the address provided in Section 13. Where AI Training Data has already been de-identified or aggregated and incorporated into AI models, it may not be practicable to identify and extract your specific data, and such de-identified data is no longer considered personal information under applicable law.

Withdrawal of Consent for AI Model Training. If you have provided consent for OVERDARE to use your AI Conversation Data for AI model training purposes (as described in Section 3), you may withdraw such consent at any time through your account settings or by contacting us at ovdr_privacy@overdare.com. Upon withdrawal, we will cease using your newly generated AI Conversation Data for model training within thirty (30) days. Withdrawal of consent will not affect the lawfulness of processing carried out prior to withdrawal, nor will it affect AI Training Data already de-identified and incorporated into models. Withdrawal of consent for AI model training does not affect OVERDARE's ability to process AI Training Data for safety and moderation purposes as described in Section 3, nor does it affect the processing of AI Usage Data on the basis of legitimate interest. With respect to AI Usage Data processed on the basis of legitimate interest, you may exercise your right to object at any time through your account settings or by contacting us at ovdr_privacy@overdare.com; upon receipt of a valid objection, we will cease such processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

12. Amendments

We may amend, at our discretion, any portion of this Policy at any time by posting or displaying the amended Policy on our Services. If we make material changes, we will post a prominent notice on our websites or in our Services or give you other reasonable notice before any material changes take effect. All other changes are effective upon posting.

13. Contact Us

If you have any questions about this Policy, or your dealings with our Services, please contact us by sending an e-mail to ovdr_privacy@overdare.com.