Privacy Policy

We are committed to protecting personal data and ensuring compliance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR).

Last Updated: December 4, 2025

This Privacy Policy describes how Emberforge Ltd, a company registered in Malta ("we", "us", "our"), processes personal data when individuals access or use the StreamPlacements platform, website, integrations, browser sources, APIs, and related services ("Services").

By using our Services, you acknowledge that you have read and understood this Privacy Policy.

1 Data Controller

The Data Controller responsible for the processing of personal data described in this Privacy Policy is:

2 Categories of Personal Data We Process

We process personal data only to the extent necessary to provide, maintain, secure, and improve our Services, fulfill contractual obligations, verify advertising delivery, prevent fraud, and comply with legal requirements. Depending on your use of the Services, we may process the following categories of personal data:

2.1 Account and Identity Information

  • Login credentials and associated identifiers
  • Contact details, including email addresses
  • Information relating to account preferences, marketing opt-in status, referral relationships, and verification processes
  • Technical metadata such as IP addresses and user agents
  • Timestamps relating to account creation, updates, and verification events

Purpose: Account creation and authentication, communication, fraud prevention, service administration, and compliance.

2.2 Payment and Payout Information

For streamers eligible for revenue share:

  • PayPal payout details
  • Transaction records, including payout amounts, dates, and processing status
  • Logs relating to changes to payout information, including metadata such as originating IP address and user agent

Purpose: Processing of payments, financial reconciliation, fraud prevention, accounting, and compliance with statutory record-keeping obligations.

2.3 Integration and Platform Data (Twitch, Kick, YouTube)

Where you connect a third-party streaming account to our platform, we process:

  • Platform profile and channel information
  • Stream performance metrics (e.g., follower counts, average viewers, viewer numbers, minutes streamed)
  • Content classification labels and broadcaster status (e.g., affiliate/partner)
  • Information required to confirm branded content compliance
  • OAuth tokens necessary to maintain authentication with third-party services
  • Chat-related data received through webhooks or APIs, including messages, message metadata, participant identifiers or usernames, timestamps, and spam/quality classifications
  • Moderator status of our automated bot

Purpose: Campaign eligibility checks, viewer-hour measurement, impression verification, analytics, fraud detection, and fulfillment of contractual obligations between advertisers and streamers.

2.4 OBS Browser Source Data and Visibility Verification

When using our advertising overlay via OBS or similar broadcasting software, we receive periodic technical data, including:

  • Source visibility state and rendering behavior
  • Overlay dimensions, resolution data, and related metadata
  • Information regarding which advertising asset is displayed at a given time
  • Error logs, transmission timestamps, and diagnostic data necessary to detect manipulation, visibility issues, or technical failures

Purpose: Verification of advertising impressions, campaign compliance, fraud detection, and overlay performance diagnostics.

2.5 Stream Screenshot and Banner Verification Data

To ensure contractual compliance with advertisers, we automatically retrieve publicly available stream thumbnail images and, where necessary, capture additional screenshots during the live broadcast from supported platforms. These images are stored and analyzed for the purpose of:

  • Verifying whether the advertising banner was visible
  • Detecting placement, size, clarity, and any obstruction
  • Generating internal visibility scores
  • Maintaining evidence supporting campaign delivery

Purpose: Fulfilling contractual obligations towards advertisers, fraud prevention, and quality assurance.

2.6 Audience Verification Submissions

For certain advertising campaigns, verification of a streamer's audience demographics is mandatory to determine campaign eligibility. To participate in such campaigns, streamers are required to submit audience analytics documentation through the methods provided within the platform.

Accordingly, we process the following information:

  • Audience analytics screenshots or supporting documentation submitted by the streamer
  • Extracted demographic data, including country-of-origin percentages, obtained through automated systems and/or vetted third-party data processors
  • Verification metadata, such as review status, internal notes, reasons for rejection, resubmission attempts, and compliance flags
  • Automated or manual assessment outputs required to validate accuracy and detect potential manipulation

Purpose: This processing is necessary to (i) assess eligibility for campaigns with demographic or regional requirements, (ii) comply with advertiser specifications, and (iii) conduct fraud prevention, risk assessment, and quality assurance to ensure that campaigns are delivered only to audiences meeting the required criteria.

2.7 Partnership and Link Tracking

When visitors interact with referral links, QR codes, promotional banners, or campaign-specific URLs, we process:

  • Technical request data (IP address, user agent, timestamps)
  • Information regarding the originating campaign, banner, or placement
  • Visitor interaction metadata, including click counts and deduplication identifiers
  • Conversion and attribution information

Purpose: Campaign analytics, attribution modeling, fraud prevention, and reporting to advertisers and streamers.

2.8 Earnings, Performance, and Reporting Data

We maintain detailed earnings records for:

  • Cost-per-view (CPV) impressions
  • Cost-per-viewer-hour (CPVH) calculations
  • Referral-based earnings
  • Associated performance logs and verification data

Purpose: Revenue calculation, payout processing, advertiser billing accuracy, fraud detection, and historical auditing.

2.9 Business & Support Communication Data

When you contact us or submit a business inquiry, we process:

  • Identification and company information
  • Contact details and communication content
  • Budget or campaign-related information (where voluntarily provided)
  • Technical metadata such as IP address and user agent
  • Internal notes, follow-up actions, and inquiry status

Purpose: Responding to inquiries, sales communication, internal documentation, and customer support.

2.10 Email Communication & Tracking Data

For system, onboarding, or permitted marketing communications, we may process:

  • Recipient contact information
  • Email type, delivery status, and interaction history
  • Open-tracking metadata (open counts, first-open timestamp, associated IP and user agent)
  • Unsubscribe tokens and preferences

Purpose: Communication analytics, service optimization, compliance with email regulations, and respecting user preferences.

2.11 Error, Diagnostic & Security Logging

We may process error and diagnostic information including:

  • Technical error messages, stack traces, status codes
  • Timestamp and URL where the issue occurred
  • Associated device and browser information

Purpose: Debugging, service security, ensuring platform integrity, and detecting malicious behavior.

3 Legal Bases for Processing (GDPR Articles 6 & 9)

We process personal data based on the following lawful bases:

  • Performance of a contract: providing advertising overlays, verifying impressions, calculating earnings, and processing payouts.
  • Legitimate interests: fraud detection, platform security, analytics, service optimization, and fulfillment of advertiser obligations.
  • Legal obligations: accounting, taxation, AML compliance where applicable, retention of financial records.
  • Consent: marketing communications, voluntary audience verification submissions, and certain third-party integrations.

Where processing relies on consent, you may withdraw it at any time without affecting prior lawful processing.

4 Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law. Typical retention periods include:

  • Account information: retained until account deletion
  • Financial and payout records: retained for statutory accounting periods
  • Screenshot and banner verification data: retained for a limited period consistent with advertiser requirements
  • Chat and impression data: retained for operational and verification purposes for a defined period
  • Error logs: retained for short-term diagnostic purposes
  • Marketing data: retained until consent is withdrawn

We may retain anonymized or aggregated data indefinitely.

5 Data Sharing and International Transfers

We may share personal data with carefully selected third parties when necessary to operate the Services, including:

  • Streaming platform providers (Twitch, Kick, YouTube)
  • Cloud infrastructure providers (e.g., AWS, Hetzner, OVHcloud)
  • Payment processors (PayPal for payouts)
  • Email and communication service providers
  • AI service providers (e.g., OpenAI for document analysis)
  • Professional advisors (legal, accounting) where required

Where data is transferred outside the EU/EEA, we ensure appropriate safeguards such as Standard Contractual Clauses (SCCs) or equivalent protections.

We do not sell personal data.

6 Security

We implement technical and organizational measures appropriate to the level of risk, including:

  • Encryption of data at rest and in transit
  • Secure storage of access tokens and authentication credentials
  • Access controls and role-based authorization
  • Continuous monitoring and logging
  • Regular audits and security reviews

7 Your Rights Under GDPR

You have the following rights regarding your personal data:

  • Right of access – to obtain a copy of your personal data
  • Right to rectification – to correct inaccurate or incomplete information
  • Right to erasure – where legally permissible
  • Right to restrict processing – under certain circumstances
  • Right to data portability – to receive data in a machine-readable format
  • Right to object – including to processing based on legitimate interests
  • Right to withdraw consent – where processing is based on consent
  • Right to lodge a complaint with the Malta Information and Data Protection Commissioner (IDPC)

Requests may be submitted at any time to support@streamplacements.com.

8 Cookies and Similar Technologies

We use cookies and similar technologies on our platform. Below is a detailed breakdown:

Essential Cookies (Required)

These cookies are necessary for the website to function and cannot be disabled. They include:

  • Authentication and session management
  • Language preferences (i18n_redirected)
  • Cookie consent preferences (sp_cookie_consent)
  • Security tokens and CSRF protection

Analytics Cookies (Optional)

Help us understand how visitors interact with our website by collecting anonymous information:

  • Google Analytics (G-H52X93QT9B) - page views, session duration, user interactions
  • Aggregated usage statistics and performance metrics

Marketing Cookies (Optional)

Used to track visitors across websites to display relevant advertisements.

Managing Your Preferences: When you first visit our website, you will see a cookie consent banner allowing you to accept all cookies, reject non-essential cookies, or customize your preferences. You can change your cookie preferences at any time by clearing your browser cookies and revisiting the site, or by using your browser's cookie management settings.

We implement Google Consent Mode v2 to respect your cookie choices. When you decline analytics or marketing cookies, Google Analytics will not store any identifying information.

9 Policy Updates

We may update this Privacy Policy from time to time. Material changes will be communicated through reasonable means, and continued use of the Services constitutes acceptance of the updated policy.

10 Contact Information

For any questions or requests related to this Privacy Policy or your personal data rights, please contact: