Privacy Policy

Last Updated: August 6, 2026

This Policy describes how Grim Empire (“Reseller,” “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 store services. We act as an authorized reseller and distributor of digital access keys for Division software and related products (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. As described in our Privacy Policy, we collect personal information from your interactions with us and our website, including through cookies and similar technologies.

2.1 Information You Provide Directly

  • Email address
  • Order details
  • Support communications via email or Discord

Note: Payment information is handled securely by our third-party payment processors.

2.2 Automatically Collected Technical Data

When You download, activate, or use digital keys and loaders associated with Division software, technical validation data may be processed or collected by the core software providers to maintain license integrity, including:

  • Hardware identifiers (HWID)
  • IP address
  • System configuration details and metadata
  • Key authentication timestamps and fraud detection telemetry

2.3 Website Analytics and Advertising

Our website may collect cookies, session identifiers, browser and device types, referrer URLs, and usage statistics.

We may also share this personal information with third parties, including advertising partners.

We do this in order to show you ads on other websites that are more relevant to your interests and for other reasons outlined in this privacy policy.

Sharing of personal information for targeted advertising based on your interaction on different websites may be considered "sales", "sharing", or "targeted advertising" under certain U.S. state privacy laws. Depending on where you live, you may have the right to opt out of these activities.

If you visit our website with the Global Privacy Control opt-out preference signal enabled, depending on where you are, we will treat this as a request to opt-out of activity that may be considered a “sale” or “sharing” of personal information or other uses that may be considered targeted advertising for the device and browser you used to visit our website.

3. How We Use Your Information

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

  • Service Delivery: Issuing, validating, and managing digital keys; authenticating Users; and delivering retail store services.
  • Fraud, Abuse, and Security: Preventing unauthorized access, key sharing, or fraudulent transactions.
  • Customer Support: Responding to inquiries and coordinating with technical support resources to resolve issues.
  • Legal and Compliance: Complying with Singapore PDPA requirements and enforcing our Terms of Service.

Except for sharing with advertising partners as outlined in Section 2.3, we do not sell or rent User data to any third party.

4. How We Store and Protect Data

  • Storage: Personal data is stored securely using industry-standard encryption and access policies.
  • Access Restriction: Only authorized personnel with a legitimate operational need may access User data.
  • Retention Period: We retain personal data only for as long as necessary to provide the Services, maintain transactional integrity, and comply with legal obligations.

5. Disclosure of Information

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

  • Service Providers: We may share data with email delivery platforms, payment gateways, server hosting providers, and advertising partners under strict confidentiality obligations.
  • Legal Requirements: We disclose data only when required by a valid Singapore court order or a lawful request served according to Singapore procedural law.
  • Protection of Operations: We may disclose data to enforce Terms of Service violations, conduct fraud investigations, and address 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 use session cookies, analytics cookies, and security-related cookies to operate our website, authenticate User actions, and 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 and will delete such data promptly if discovered.

9. User Rights

Subject to jurisdiction-specific restrictions, You have rights to request access, correction, deletion, restriction of processing, objection to processing, data portability (GDPR residents), or to opt-out of data sale or sharing for targeted advertising (CCPA/CPRA residents). Requests may require identity verification.

10. Data Requests by Game Companies or Anti-Cheat Providers

Grim Empire 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 and email providers, which operate under their own privacy practices for which We are not responsible.

12. Account & License Termination

As a reseller, we reserve the right to revoke store access, disable compromised keys, or terminate support when a license expires, a User violates our Terms of Service, or fraud/abuse is detected.

13. Changes to This 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, technical support, or PDPA-related data requests, contact:

Grim Empire — Reseller Support & Data Protection Officer

(Private business address withheld for security and confidentiality)

Email: legaldivision@atomicmail.io

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