Privacy Policy

Effective Date: November 3, 2025

Entity: Vandelay Softworks Inc.

Jurisdiction: Vancouver, British Columbia, Canada

Introduction

This Privacy Policy ("Policy") sets forth the terms and conditions under which Vandelay Softworks Inc. ("Vandelay," "we," "us," or "our") collects, retains, processes, and discloses information from individuals ("you," "user," or "data subject") in connection with your use of the Down Bii platform and related services (collectively, the "Service").

By accessing or using the Service, you acknowledge that you have read, understood, and agreed to be bound by this Policy. If you do not agree with any portion of this Policy, you must immediately discontinue use of the Service.

Applicability of GDPR

This Policy shall apply in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") solely with respect to individuals who are verified residents of the European Union or European Economic Area, possessing a valid physical address within said territories. For all other users, this Policy shall be governed and interpreted in accordance with the laws of the Province of British Columbia, Canada, without regard to conflict of law provisions.

Categories of Data Collected

Vandelay Softworks Inc. collects and retains the following categories of data as part of the Service’s operation:

(a) Email Address

  • Collection Status: Optional
  • Retention Period: Indefinite (permanent)
  • Purpose: Collected voluntarily by the user for password reset functionality, authentication procedures, and issuance of payment receipts.

(b) User Profile Data

  • Collection Status: Required
  • Retention Period: Indefinite (permanent)
  • Purpose: Collected for the establishment and maintenance of the user’s Down Bii account, including the following profile attributes: user tag, profile badges, declared country of residence, tag color, payment status, clans owned or joined, Down Bii League rank (if applicable), and account tenure duration.

(c) Discord User Identification Data

  • Collection Status: Required
  • Retention Period: Indefinite (permanent)
  • Purpose: Collected to authenticate and associate your Down Bii interactions with your Discord account. This includes Discord User ID and Discord Username.

(d) Command Interaction Data

  • Collection Status: Required
  • Retention Period: One (1) day
  • Purpose: Collected temporarily to facilitate bot command processing and ensure proper execution of user-submitted requests. Said data is automatically deleted within twenty-four (24) hours.

(e) Patreon User Identification Data

  • Collection Status: Optional
  • Retention Period: Indefinite (permanent)
  • Purpose: Collected for users who have become donors to Down Bii through Patreon. Such data includes the Patreon User ID for verification and benefit allocation.

Lawful Basis for Processing

For users within the European Union, processing of personal data shall be conducted under Article 6(1) of the GDPR on the following lawful bases:

  • (a) Consent of the data subject, where applicable.
  • (b) Performance of a contract to which the data subject is a party.
  • (c) Legitimate interests pursued by Vandelay Softworks Inc., provided such interests are not overridden by fundamental rights and freedoms of the data subject.

Data Retention

Unless otherwise stated herein, data shall be retained for so long as it remains necessary for the fulfillment of the purposes set forth above, for legal compliance, or as required by applicable law. Upon the expiration of any applicable retention period, or upon verified request by the user, the data shall be securely deleted or anonymized.

Data Disclosure and Sharing

Vandelay Softworks Inc. does not sell, lease, or otherwise monetize user data. However, we may disclose personal data in the following limited circumstances:

  • To service providers or subprocessors (e.g., hosting providers, payment processors) strictly for operational purposes.
  • To comply with a lawful request, subpoena, or court order.
  • To protect the integrity, security, and lawful operation of the Service.
  • In connection with a merger, acquisition, or sale of substantially all assets of Vandelay Softworks Inc., subject to standard confidentiality obligations.

User Rights

For European Union Residents (GDPR):
Subject to verification of residency, users residing within the European Union possess the following rights under the GDPR:

  • Right of access to personal data.
  • Right to rectification of inaccurate data.
  • Right to erasure ("right to be forgotten").
  • Right to restriction of processing.
  • Right to data portability.
  • Right to object to processing.
  • Right to lodge a complaint with a supervisory authority.

For Non-EU Users:
Vandelay Softworks Inc. will honor reasonable requests for data deletion or export, subject to identity verification and applicable law.

Data Security

Vandelay employs commercially reasonable administrative, technical, and physical safeguards designed to protect user data against loss, unauthorized access, disclosure, alteration, or destruction. However, no data transmission or storage system can be guaranteed as absolutely secure, and the user acknowledges such inherent risks.

Requests to Cease Data Collection

Users may, at any time, request that Vandelay Softworks Inc. discontinue the collection of their personal data or delete existing data by contacting:
Email: legal@downbii.rocks