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PRIVACY POLICY

Last Updated: December 9, 2025

This Privacy Policy (“Policy”) describes how Division (“Company,” “We,” or “Us”) collects, uses, stores, and protects personal data when individuals (“Users” or “You”) access or interact with our website, purchase digital keys, or use our Software, loader, or related services (collectively, the “Services”).

By accessing or using the Services, You consent to the data practices described in this Policy.

1. GOVERNING LAW

This Policy is governed by the Personal Data Protection Act 2012 (PDPA) of Singapore.
Where applicable, We extend certain rights and disclosures to Users located in the European Union (GDPR) and California (CCPA/CPRA).

2. INFORMATION WE COLLECT

We collect only the data necessary to operate, maintain, secure, and deliver the Services.

2.1 Information You Provide Directly

  • Email address

  • Our third-party payment processor handles payment information.

  • Order details

  • Support communications via email or Discord

2.2 Automatically Collected Technical Data

When You download, activate, or use the Division loader or Software, We may collect:

  • Hardware identifiers (HWID)

  • IP address

  • System configuration details (OS version, CPU/GPU identifiers, device metadata)

  • Loader usage logs

  • Crash reports

  • Key authentication timestamps

  • Fraud detection telemetry

2.3 Website Analytics

Our website may collect:

  • Cookies and session identifiers

  • Browser type, device type

  • Referrer URLs

  • Usage statistics

We do not use invasive fingerprinting or behavioral tracking outside what is required for Service functionality and fraud prevention.

3. HOW WE USE YOUR INFORMATION

We process personal data solely for legitimate business purposes, including:

3.1 Service Delivery

  • Issuing, validating, and managing digital keys

  • Authenticating Users

  • Operating and securing the Division loader

3.2 Fraud, Abuse, and Security

  • Preventing unauthorized access or key sharing

  • Detecting suspicious device changes

  • Ensuring license integrity

3.3 Product Improvement

  • Debugging and understanding software crashes

  • Enhancing loader stability and compatibility

3.4 Customer Support

  • Responding to inquiries

  • Resolving technical issues

3.5 Legal and Compliance

  • Complying with Singapore PDPA requirements

  • Responding only to legally valid requests made through proper Singapore procedures

  • Enforcing our Terms of Service

We do not sell or rent User data to any third party.

4. HOW WE STORE AND PROTECT DATA

4.1 Storage

Personal data is stored securely using industry-standard encryption and access policies.

4.2 Access Restriction

Only authorized personnel with a legitimate operational need may access User data.

4.3 Retention Period

We retain personal data only for as long as necessary to:

  • Provide the Services

  • Maintain operational integrity

  • Comply with legal obligations

Telemetry and HWID data may be retained for fraud prevention and recordkeeping.

5. DISCLOSURE OF INFORMATION

We do not disclose User information except in the following limited circumstances:

5.1 Service Providers

We may share data with:

  • Email delivery platforms

  • Server hosting providers

These providers act under confidentiality obligations.

5.2 Legal Requirements

We disclose data only when required by:

  • A valid Singapore court order

  • A lawful request served according to Singapore procedural law

  • Arbitration proceedings agreed under our Terms of Service

We do not comply with informal or extrajurisdictional requests for information.

5.3 Protection of Operations

We may disclose data to enforce:

  • Terms of Service violations

  • Fraud investigations

  • Security breaches

6. INTERNATIONAL DATA TRANSFERS

Because We serve a global audience, certain data may be transferred to servers located outside the User’s country.

We ensure all such transfers comply with Singapore PDPA requirements and with reasonable security safeguards.

7. COOKIES AND TRACKING TECHNOLOGIES

We may use:

  • Session cookies

  • Analytics cookies

  • Security-related cookies

Cookies may be required to:

  • Operate our website

  • Authenticate User actions

  • Prevent automated fraud

Users may disable cookies, but the Services may not function correctly.

8. CHILDREN’S PRIVACY

Our Services are not intended for individuals under 18 years old. We do not knowingly collect data from minors.

If We become aware that data from a minor has been collected, We will delete it promptly.

9. USER RIGHTS

Subject to jurisdiction-specific restrictions, You may have rights to:

  • Request access to Your data

  • Request correction of inaccurate data

  • Request deletion of certain personal data

  • Request limitation of processing

  • Object to data processing

  • Request data portability (GDPR residents only)

  • Opt-out of data sale (CCPA—We do not sell data)

Requests may require identity verification.

10. DATA REQUESTS BY GAME COMPANIES OR ANTI-CHEAT PROVIDERS

Division does not honor data requests made by:

  • Game publishers

  • Anti-cheat developers

  • Their representatives, affiliates, or outsourced investigators

Data is disclosed only under valid Singapore legal compulsion.

11. THIRD-PARTY LINKS AND PLATFORMS

Our Services may link to or integrate with:

  • Discord

  • Email providers

These third parties operate under their own privacy practices, for which We are not responsible.

12. ACCOUNT & LICENSE TERMINATION

We may delete, anonymize, or disable User data when:

  • A license expires

  • A User violates our Terms of Service

  • Fraud or abuse is detected

13. CHANGES TO THIS PRIVACY POLICY

We reserve the right to update or modify this Policy at any time. Changes take effect immediately upon posting.

Continued use of the Services constitutes acceptance of the revised Policy.

14. CONTACT INFORMATION

For questions or PDPA-related data requests, contact:

Division — Data Protection Officer
(Private business address withheld for security and confidentiality)
Email: [email protected]

All legal notices must comply with Singapore service-of-process rules.