1. Who controls your data
Devign LLC, a limited liability company registered in the State of Wyoming, United States, 5830 E 2nd St, Ste 7000 #23016, Casper, WY 82609, United States, is the controller of the personal data described here. For privacy questions, including any request to exercise your rights, contact info@devignlb.com.
We are a United States company serving creators in Europe, Turkey, Latin America and the Middle East, so this policy is written to meet the GDPR and UK GDPR, Turkey's KVKK, and United States state privacy laws at the same time. Where those give you different rights, you get whichever applies to you.
2. What we collect, and why
We collect only what the Service needs to function.
- Account identifier: your email address, and a phone number if you confirm one (agency creators sign in with theirs; everyone else confirms one to start the free week). If you sign in with Google or TikTok we receive your name, email address or username, and profile picture from that service. Used to create your account, confirm your email and phone, send password reset links, and identify you across the Site and the Launcher. Your password is stored only as a one-way hash. Legal basis: performance of our contract with you.
- Creator profile: for agency creators, the display name, username, avatar URL, level and activity figures already held in your Devign creator record. Used to show who is signed in and to determine whether the catalogue is free for you. Legal basis: performance of our contract.
- Subscription, order and tax records: whether you are an agency member and whether you hold a paid subscription; for each order, the time you accepted the Terms and asked for the subscription to start, the amount, the VAT and your country, which the checkout asks for so that the right VAT is charged. Card details are never sent to or stored by us; they go directly to our payment processor. Legal basis: contract, and legal obligation for tax and transaction records.
- Cancellations and withdrawals: the email address and the name you enter on the cancel or withdraw page, the reason you give if you cancel with immediate effect, the time the request arrived and the IP address it came from. Used to carry out the request, confirm it to you, decide on a refund (a person on our team reads the reason for an immediate cancellation made after the withdrawal period) and keep proof of when it arrived. Legal basis: contract and legal obligation.
- Your country, for the price: to show the price with your country's VAT, our server looks up the country of your IP address in a geolocation database kept on our own server (IP to Country Lite by DB-IP, db-ip.com, licensed under CC BY 4.0). Nothing is sent to anyone else for this, and the country is not stored with your account. Legal basis: legal obligation to show prices including VAT, and our legitimate interest in showing you the price you will actually pay.
- Support correspondence: anything you send us, including diagnostic logs you choose to attach. Legal basis: our legitimate interest in answering you.
- Security and abuse signals: request metadata such as IP address and timestamps recorded by our servers, used to rate-limit sign-in attempts and one-time codes, and to detect abuse. Legal basis: our legitimate interest in keeping the Service secure.
You need an email address or a phone number to have an account; without one we cannot provide the Service. We do not make decisions about you by automated means that have legal or similarly significant effects on you.
3. What stays on your computer
This is the part most creators care about, so we want to be precise. When you run a game, the Launcher connects to your TikTok LIVE room and receives events: gifts, likes, comments, follows and shares. Those events are processed locally, on your own machine, by the Event Bridge component, and are passed straight to the running game to drive gameplay.
Viewer names and profile pictures arrive with those events and are cached locally so games can display them. We do not upload that viewer data to our servers, we do not build profiles from it, and we do not sell it. Clearing the Launcher's cache removes it.
Diagnostic logs are written to your machine and stay there unless you choose to send them to support.
4. Browser storage on this Site
The Site sets no advertising cookies. Visit counts use Umami, which is cookieless and stores nothing on your device. If you tap Accept on our banner, we also load Microsoft Clarity, which sets cookies on your device and records anonymised heatmaps and screen replays (clicks, scrolling and page navigation) so we can find and fix confusing pages. Clarity masks typed form input by its default settings, and it is not loaded on the sign-in, account, cancellation or withdrawal pages. Microsoft processes this data for us under its own terms.
If you tap Decline or ignore the banner, Clarity is never loaded. If your browser sends a Global Privacy Control or Do Not Track signal, we do not show the banner and do not load Clarity unless you have already accepted. To withdraw consent later, clear site data for gaming.devignlb.com; the banner will then ask again, and you can tap Decline. Separately, the Site stores three items in your browser's local storage:
- devign.session.v1: your signed-in session, so you are not asked to sign in on every page.
- devign.lang.v1: the language you picked, or the one we switched you to on your first visit to the home page from your browser language or country.
- devign.settings.v1: your launcher-related preferences, when set.
6. Where your data goes
Devign is a United States company. When you use the Service you give your data directly to us, and it is stored on servers we operate. The providers listed above may process it in the United States and in other countries.
If you are in the EEA, the UK or Switzerland, your data therefore goes to the United States, and the GDPR still applies to how we handle it. When we pass it to a provider outside the EEA, we rely on the European Commission's adequacy decision where that provider is certified under the EU-U.S. Data Privacy Framework, and otherwise on the Commission's Standard Contractual Clauses (with the UK Addendum where relevant), together with the security measures described in section 11. You can ask us for a copy of these safeguards at info@devignlb.com.
7. How long we keep it
- Account records: for as long as your account exists, and up to 12 months after deletion in a limited form to prevent re-registration abuse.
- One-time codes and email links: codes expire within minutes and reset links within an hour; neither is kept after it is used or expires.
- Payment, order and refund records: as long as tax and accounting law requires, which can be up to 10 years.
- Cancellation and withdrawal requests: 3 years after the end of the year in which the subscription ended.
- Support correspondence: up to 24 months.
- Locally cached viewer data and logs: controlled entirely by you, on your machine.
8. Your rights
Depending on where you live, in particular under the GDPR in the EEA, the UK GDPR, and Turkey's KVKK, you have the right to access the personal data we hold about you, to correct it, to delete it, to restrict processing, to receive it in a portable format, and to withdraw consent where processing is based on consent. Where we rely on our legitimate interests, you may object at any time on grounds relating to your particular situation.
To exercise any of these, email info@devignlb.com. We will respond within one month. You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the country where you live or work or where you believe the law was broken.
9. If you are in the United States
Residents of California and of other states with comprehensive privacy laws (including Colorado, Connecticut, Virginia, Texas and Utah) have the right to know what personal information we collect and why, to request a copy of it, to correct it, to request deletion, and not to be discriminated against for exercising any of those rights.
We do not sell personal information, and we do not share it for cross-context behavioural advertising. We run no advertising trackers on this Site. Microsoft Clarity loads only if you accept it, and you can decline or withdraw as described in section 4. You may also submit any of the requests above.
To make a request, email info@devignlb.com. We will verify it against the email address or phone number on the account before acting, and respond within 45 days. You may use an authorised agent.
10. Children
The Service is not directed at anyone under 18 and we do not knowingly collect personal data from anyone under 18. If you believe a minor has given us personal data, contact us and we will delete it.
11. Security
Passwords are stored only as a one-way hash, never in readable form, and resetting one signs every other device out. Phone numbers are confirmed with a one-time code. Traffic between the Site, the Launcher and our servers is encrypted in transit. No system is perfectly secure; if a breach affects your personal data and poses a risk to you, we will notify you and the relevant authority as the law requires.
12. Changes
If we change this policy materially we will update the date at the top and notify account holders before the change takes effect.