Privacy Policy

Who we are

Loaded Holdings, Inc. and its affiliates (collectively, "Loaded," "we," "our," or "us") are committed to protecting the privacy and security of the information we collect on the Discord platform (www.discord.com, or "Discord") through our Fan Dynamics services (the "FD Services") and our marketing website (the "Site" and, together with the FD Services, the "Services"). The FD Services include the dashboard we provide to FD Partners. Where this policy refers to the Site, it means our marketing website only, and not the dashboard.

The FD Services provide data, engagement, and analytics tooling to publishers, developers, artists, and Discord server owners and controllers (each an "FD Partner" and, collectively, "FD Partners") to support growth, user engagement, and commercialization of their games, products, and Discord communities. This Privacy Policy applies to users of Discord servers that use our FD Services (each a "User"), our Site visitors (each a "Visitor"), and our FD Partners.

What information we collect

When you use our Services, we may collect, store, and process various kinds of data, including personal information about you. Personal information refers to information that can be used to identify you.

Information we collect on our Site

We may collect personal information when you visit our Site and:

• Submit a form on the Site;
• Contact us with inquiries, including via email; or
• Otherwise voluntarily provide information.

When you visit the Site, we may also automatically collect certain details of your visit, including traffic data, location data, weblogs and other communication data, your IP address, browser type, the date and time you accessed or left the Site, and which pages you viewed. Some parts of our Site use cookies and similar technologies to collect this information about your general internet usage.

We use cookies (small text files stored in your browser) and other techniques such as web beacons ("Tracking Technologies"). Tracking Technologies collect information about how you use our Site. Using them does not give us access to the rest of your device.

Information from Discord

Fan Dynamics is a Discord application that FD Partners install in their own Discord servers. Each feature is a module the server's administrators switch on or off, so what we collect in a given server depends on what that server has enabled. This section describes the categories of information the application collects.

Account and membership information

Your Discord user ID, username, display name, avatar, the servers you share with the application, your roles in those servers, and when you joined and left. We use this to know who you are across features, to apply the correct server's settings, and to grant role rewards to the right person.

Activity and engagement information

Counts and timestamps of your activity: messages sent, voice channel time, reactions added, poll votes, event responses, invites used, and the experience points, streaks, and rewards those produce. Where an FD Partner has enabled invite tracking, we record which member's invite brought you to the server.

Message content

Where an FD Partner enables the relevant modules, our application reads the content of messages sent in that server's public channels in order to:

• Apply the server's automated moderation rules, such as blocked links, spam, mass mentions, excessive capitals, repeated text, and emote flooding;
• Match the keyword and phrase triggers that server staff configure for automatic replies and custom commands; and
• Produce aggregate reporting for server staff on the words and emoji the community uses.

We do not use message content to train machine learning or artificial intelligence models, and we do not send message content to any third-party model provider.

Information you give us directly

Some modules ask you for information through a Discord form, and we store what you enter. What is asked is configured by the FD Partner running the server, and answering is your choice.

• Welcome and sign-up flows. An FD Partner can ask new members for an email address, a phone number, an age group, a country, and free-text answers to questions of their own, such as a favourite song or which city an artist should tour next. Where you provide an email address or phone number, we pass it to that FD Partner's mailing or messaging provider so they can contact you, and we record your answers in a spreadsheet the FD Partner controls. This is described further under How we share information.
• Support tickets. If you open a support ticket, we store the subject and description you write, and any notes the server's staff add to it, so staff can handle your request and refer back to it.
• Applications. If you apply to a server's moderation team through the application, we store your answers so staff can review them.

Presence and activity status

Where an FD Partner enables the relevant modules, our application reads the activity status Discord makes visible about you, meaning whether you are currently listening to something, playing a game, or streaming, and the name of that game, artist, or track. We use it in two ways.

First, to award experience points. A server can configure a once-per-day reward for members who start listening or start playing, which is a common engagement mechanic for an artist's or a studio's community.

Second, to produce aggregate reporting for the FD Partner on what their community is collectively playing and listening to. This reporting is aggregate by design. Before your activity contributes to any counter, your Discord user ID is converted to a hash, and those hashes are accumulated into statistical estimators that hold counts rather than identifiers. The hashes themselves are never written to storage. What we retain is a figure such as the number of members listening to a given artist in a given hour. We do not keep any record that links you personally to what you were playing or listening to.

The FD Partner dashboard

FD Partners and their staff sign in to our dashboard using Discord. When they do, we receive their Discord account identity from Discord and store a session for up to seven days so they stay signed in. We also log administrative actions taken in the dashboard, together with the IP address they came from, so that we can investigate misuse. This applies to the FD Partner staff who sign in, not to ordinary members of a Discord server.

Information from Steam

Some FD Partners run campaigns that let you link your Steam account to earn rewards. Linking is optional and entirely your choice. Nothing in this section is collected unless you complete the Steam sign-in yourself.

Signing in through Steam does not give us access to your Steam account. Steam's sign-in tells us your Steam ID and nothing more. We never receive your Steam password, we cannot act on your account, and we cannot see anything your Steam privacy settings hide. If your game details are not public, we simply cannot see your wishlist, and we record that as unknown.

After you link, we periodically ask Steam's public API for your wishlist so we can check whether the campaign's game is on it. Steam returns your whole wishlist in that response. We read only whether the campaign's game is present and when it was added, and that is the only thing we store. We do not store the rest of your wishlist, and we do not read your friends, your messages, or your purchase history. These checks continue until you unlink, leave the server, or the campaign ends.

You can unlink at any time from your profile in Discord. Unlinking stops all further wishlist checks immediately. If you also want the stored link and wishlist status erased, contact us using the details below and we will delete them.

Information about FD Partners

In order to provide the FD Services to our FD Partners, we may collect:

• Account information relating to your Discord account, such as your username;
• Content you create on the Discord server, to the extent described under Information from Discord above;
• Information about your use of our Services and your activity in Discord servers, such as the servers and communities you join and your engagement; and
• Other information you provide directly to us as you use our Services.

Why we collect information

We may use the information we collect for the following purposes:

• To present and operate our Services;
• To personalize your experience;
• To provide you with information, products, or services, including customer service, that you request from us;
• To administer a Service feature;
• To perform analytics that help FD Partners understand and grow their communities, and to improve our Services;
• To send periodic emails to FD Partners relating to the provision of the Services;
• To assess or exercise a legal right;
• In any other way we describe when you provide the information; and
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or a similar proceeding, in which personal information held by us is among the assets transferred.

How we share information

Information we collect through Discord and Steam

We share information collected through the FD Services with the FD Partner whose Discord server you joined, so that they can use the FD Services. Some of this is individualized, such as your username, your engagement level, whether you linked Steam and wishlisted their game, and content you voluntarily post in their server where we store it, as described above. Other information is de-identified, statistical, or aggregate output. An FD Partner may give its affiliates, parents, subsidiaries, designees, representatives, and creators ("FD Partner Affiliates") access to the FD Services through their dashboard.

Beyond the FD Partner, we disclose this information only:

• To contractors and service providers who host and operate the software on our behalf, such as hosting, database, and error monitoring providers, who process it under contract and do not use it for their own purposes;
• Where you have given us an email address or phone number through an FD Partner's sign-up form, to the mailing, messaging, and spreadsheet providers that FD Partner has connected to their server, so that they can contact you and keep their own records. Depending on what the FD Partner has configured, these are currently Brevo, Klaviyo, Laylo, and Google Sheets. We send them the contact details and answers you provided, and your Discord username so the FD Partner can match the record to you;
• For any purpose with your consent;
• To enforce any agreement, including any applicable terms of service;
• To establish or exercise our right to defend against legal claims;
• To law enforcement and other government authorities, including legislatures, courts, agencies, and litigants, where we reasonably believe it is necessary to comply with the law or legal process, respond to requests from public or government authorities, protect the security or integrity of our information systems, or exercise or protect the rights, privacy, or safety of Loaded, our affiliates, our clients, you, or others; and
• To a buyer or successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal information held by us is among the assets transferred.

Information we collect on our Site

Information we collect from Visitors to our Site, such as cookie and Tracking Technology data, may additionally be shared with analytics and advertising providers, and with affiliates if you opt in to receiving communications from them. This applies only to information collected on our Site. It does not apply to any information collected through Discord or Steam.

What we never do with Discord data

Information we obtain through Discord is used only to provide the features described in this policy. Specifically, and without exception:

• We do not sell, license, or otherwise commercialize it.
• We do not disclose it to any advertising network, data broker, or other advertising or monetization service.
• We do not use it to target you with advertising or marketing. If you voluntarily give an FD Partner your email address or phone number through their sign-up form, we pass it to their mailing or messaging provider so they can contact you, because that is the purpose you provided it for, and you can unsubscribe with them at any time. We do not build marketing audiences from anything we obtain through the Discord API, and we do not add you to any mailing list you did not sign up for.
• We do not use it to train machine learning or artificial intelligence models.
• We do not use it for any purpose other than providing the stated functionality of our application.

These commitments reflect our obligations under the Discord Developer Policy and Discord Developer Terms of Service, which we are bound by and which take precedence over any more general statement elsewhere in this policy.

How long we keep information

We retain personal information only for as long as it is needed for the purpose we collected it for, including to satisfy any legal, accounting, or reporting requirement, unless a longer retention period is required or permitted by law.

We do not retain Discord data any longer than necessary to operate the application. We previously operated a feature that archived full channel message history. We discontinued it and deleted the stored content; message exports are now generated live from Discord at the moment they are requested and nothing is retained.

Your choices and opt-outs

Deletion and withdrawal requests

You can ask us at any time to delete any information we hold about you, by contacting us using the details below. So that we delete the right person's data and not someone else's, we will ask you to confirm the Discord account concerned before we act. Following a request, we will take all reasonable steps to delete your information as soon as is practicable, and in any event within 30 days. This will not affect processing that has already taken place. We reserve the right to retain certain information to the extent necessary for the operation of the Services, in archived or backup copies for our records, or as otherwise required by law or in order to remain in compliance with Discord's terms and policies.

Where you have consented to our use of your information, you may withdraw that consent at any time and opt out of further use by contacting us and telling us what use you wish to opt out of. In some cases this may mean no longer being able to use the Services.

Activity status

You can stop us receiving your activity status entirely by turning off activity sharing in your Discord privacy settings. When you do, our application receives nothing about what you are playing or listening to.

Steam

You can unlink your Steam account at any time using the unlink control on your profile in Discord. This stops all further wishlist checks immediately. To have the stored link and wishlist status erased as well, contact us using the details below and we will delete them.

Discord's own settings

Please see the Discord Privacy Policy, the Discord Cookie Policy, your Discord account settings, and Discord's data privacy controls to learn more about Discord's own data practices and to exercise the choices Discord offers you.

Tracking Technologies on our Site

Most browsers accept cookies automatically. You may be able to set your browser to refuse all or some cookies, or to alert you when cookies are being sent. Check your browser's technical information for instructions. If you disable or refuse cookies, some parts of the Site may become inaccessible or stop working properly. Cookie-based opt-outs must be performed on each device and browser you want opted out.

Do Not Track

Our Services do not currently respond to "Do Not Track" or other similar browser signals.

How we protect information

We take commercially reasonable precautions and follow industry practice to make sure your personal information is not inappropriately lost, misused, accessed, disclosed, altered, or destroyed. Information is held in access-controlled systems, connections to our databases are encrypted in transit, and our hosting provider encrypts stored data at rest. However, no data protection procedure is entirely infallible, so while we work to protect your personal information we cannot guarantee it will be completely secure, and your transmission of information to our Services is done at your own risk.

All FD Partners are required to agree to and comply with this Privacy Policy, the agreement under which we provide them the Services, and the terms and policies of Discord. Each FD Partner must ensure that all FD Partner Affiliates do the same.

California residents

California's "Shine the Light" law (Civil Code Section 1798.83) permits users of our Site who are California residents to request certain information about our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, email contact@fandx.io.

International visitors

Our Services are hosted and operated in the United States. By interacting with a Discord server that uses our Services, you consent to the transfer of your personal information to the United States. If you are accessing a Discord server that uses our Services from outside the United States, please be aware that United States law may not offer the same privacy protections as the law of your jurisdiction.

European Economic Area, United Kingdom, and Switzerland

For Users, Visitors, and FD Partners residing in the European Economic Area, the General Data Protection Regulation ("GDPR") may apply. The GDPR provides a framework for protecting the personal information of European citizens and gives them certain rights.

Legal basis for processing

If you are located in the EEA, United Kingdom, or Switzerland, our legal basis for processing your personal information depends on the information concerned and the context in which it is collected. Normally we collect or process personal information from you only where we have your consent to do so, or where we need it to perform a contract with you, such as to deliver the Services.

In some cases we may have a legal obligation to process your personal information, or may need it to protect your vital interests or those of another person. Where we rely on your consent, you can withdraw or decline it at any time in writing or as otherwise permitted. This does not affect the lawfulness of processing carried out before withdrawal, nor processing conducted on lawful grounds other than consent.

Rights to access and control your personal data

Individuals residing in the European Economic Area, United Kingdom, and Switzerland have certain rights to access and control their personal data. These include:

• the right to be informed;
• the right of access;
• the right to rectification;
• the right to erasure;
• the right to restrict processing;
• the right to data portability;
• the right to object; and
• rights in relation to automated decision making and profiling.

You may also have the right to complain to your local data protection authority. Contact us and we will help.

Review and correction

You may review and correct the information we have collected about you at any time using the contact details below. If your information has been shared with a third party as described in this policy, that third party holds its own copy. If one of them has contacted you and you wish to correct or delete your information with them, please contact them directly.

Age requirements

Discord requires its users to be at least 13 years old, or older in some countries. Our Services are not intended for anyone below the minimum age in their country, and we do not knowingly collect personal information from children under 13. If you are under 13, do not engage with a Discord server that uses our Services. If we learn that we have collected personal information from a child under 13 without verified parental consent, we will delete it. If you believe we may hold information from or about a child without verifiable parental consent, please contact us at contact@fandx.io.

Changes to this policy

We update this Privacy Policy from time to time, so please review it regularly. If we materially change it, we will update the date at the top and post a notice on our Site. Your continued interaction with Discord servers using our Services will be deemed your agreement that your information may be used in accordance with the updated policy. If you do not agree with the changes, you should stop using the Discord servers that use our FD Services.

Contact us

If you have questions or comments about this Privacy Policy, or you would like to contact us about the Services, your data, or your deletion and opt-out options, email contact@fandx.io.

Trademarks

Fan Dynamics is not affiliated with, endorsed by, or sponsored by Discord Inc. or Valve Corporation. Discord is a trademark of Discord Inc. Steam and the Steam logo are trademarks of Valve Corporation. Our use of the Steam Web API is subject to the Steam Web API Terms of Use.