PRIVACY POLICY

Last Updated: May 27, 2026

Entity: SterHK Limited

Business Registration Number: 80351629

Registered Office: RM 511, 5/F, MING SANG IND BLDG, 19-21 HING YIP STREET, KWUN TONG, HONG KONG

Contact Email: Support@winforge.gg

1. INTRODUCTION

• 1.1. SterHK Limited ("Company", "we", "us") is committed to protecting the privacy of our users ("User", "you").
• 1.2. This Privacy Policy explains how we collect, use, and safeguard your information when you use our B2C digital marketplace platform for digital consulting and coaching services.
• 1.3. By accessing the Platform, you consent to the data practices described in this policy.

2. INFORMATION WE COLLECT

We collect information necessary to facilitate consulting sessions, ensure security, and improve our services.

• Identity & Profile Data: Email address, username, user avatar (profile picture), and internal User IDs.
• Technical, Tracking, Authentication & Chat Data: IP address, browser type, device information, and session timestamps. We utilize secure cookies and authentication tokens to maintain your active logged-in session, secure your account, and analyze platform traffic. Live Chat History via our live support widget is also securely logged.
• Verification (KYC): For high-risk transactions, we may request a copy of a government-issued ID to comply with AML regulations.
• Consulting Session Data: To facilitate multiplayer coaching and gameplay optimization, we may collect your public in-game identifiers (e.g., public usernames or BattleTags). Note: We never ask for, collect, or store your personal game account passwords or login credentials. Our services are strictly coaching-based.
• Payment Data: We do NOT store full credit card numbers. Transactions are processed via secure, compliant third-party payment processors. We retain transaction references (IDs, dates, amounts) for tax, accounting, and dispute resolution purposes.

3. HOW WE USE YOUR INFORMATION

• 3.1. Service Fulfillment: To enable the scheduling, delivery, and completion of consulting sessions by Independent Coaches.
• 3.2. Security: To prevent fraud via our payment processors' security tools and monitor suspicious IP activity.
• 3.3. Marketing & Analytics: To measure the effectiveness of our advertising campaigns and improve Platform functionality.
• 3.4. Communication: To send session updates, schedules, and support responses.
• 3.5. Compliance: To adhere to Hong Kong laws and international AML standards.

4. SHARING OF YOUR INFORMATION

We do not sell your personal data. We share information only as follows:

• With Independent Coaches: Public in-game identifiers and session goals are shared only with the specific Independent Coach assigned to your consulting order. All Independent Coaches are bound by strict confidentiality obligations and are prohibited from using this data outside the scope of the coaching session.
• With Third-Party Tools: Payment Gateways for secure payment processing. Analytics providers (Google/Meta) subject to your explicit consent. Live chat providers (tawk.to).
• Legal Requirements: We may disclose data if required by law or to protect our rights (e.g., in case of chargeback fraud).

5. INTERNATIONAL TRANSFERS

• 5.1. SterHK Limited operates from Hong Kong. Your data may be processed globally, including where our Independent Coaches or servers are located.
• 5.2. By using the Platform, you consent to this cross-border transfer, ensuring that adequate security measures are in place.

6. COOKIES AND TRACKING TECHNOLOGIES

• 6.1. Usage: The Platform uses cookies and similar tracking technologies (such as Google Analytics, Facebook Pixel, and tawk.to) to analyze traffic, improve user experience, and manage advertising effectiveness.
• 6.2. Explicit Consent (GDPR Compliance): In accordance with the General Data Protection Regulation (GDPR) and applicable EU laws, the Platform utilizes an explicit opt-in consent mechanism. No non-essential cookies, tracking pixels, or marketing scripts will be executed or placed on your device until you have provided explicit, affirmative consent via the Cookie Banner displayed on the Platform. You are not required to provide consent for non-essential cookies to use the basic functions of the Platform.
• 6.3. Management: You can withdraw your consent at any time or manage your cookie preferences through your browser settings or our Platform's cookie control panel.

7. YOUR RIGHTS (GDPR & GLOBAL)

As a data subject, particularly if you reside in the European Union (EU) or European Economic Area (EEA), you have the following rights regarding your personal data:

• 7.1. Right to Access & Data Portability: You have the right to request a copy of your personal data in a structured, machine-readable format.
• 7.2. Right to Rectification: You may request the correction of inaccurate or incomplete personal data.
• 7.3. Right to Erasure ("Right to be Forgotten"): You may request the deletion of your account and associated personal data, subject to our legal obligations to retain transaction and AML records for a designated period.
• 7.4. Right to Restriction of Processing: You can request that we limit the processing of your data under certain circumstances.
• 7.5. Right to Lodge a Complaint: If you believe our processing of your personal data violates GDPR, you have the right to lodge a complaint with the relevant Data Protection Authority (Supervisory Authority) in your country of residence (e.g., the BfDI in Germany).
• 7.6. Account Deletion Process: Users may request the complete deletion of their account and associated personal data at any time by contacting our support team at Support@winforge.gg with the subject line "Account Deletion Request".

8. CONTACT INFORMATION