Privacy Policy
Last updated: 2025-12-15
1. Introduction
This Privacy Policy explains how Fortem (“we”, “our”, or “us”) collects, uses, stores, and protects personal data in connection with the Fortem platform (the “Service”).
The Service is operated by FORTEM LABS S.A., a company incorporated in Panama, which acts as the Data Controller.
This Policy applies to all users of the Service.
By using the Service, you consent to the practices described in this Policy.
2. Data We Collect
Fortem follows a data minimization principle and collects only the information necessary to operate the Service.
We may collect the following categories of data:
A. Account & Identity Information
Email address (if provided)
Wallet address
Username or display name
B. Usage & Technical Data
IP address
Browser and device information
Access logs and session information
Security and rate-limit logs
C. Transaction & On-chain Interaction Data
Minting, listing, selling, and purchasing metadata
Ownership changes recorded on-chain
Smart-contract execution states (success/failure)
D. Game Integration Data
Export requests
Single-use Redeem Code issuance and validation results
Game synchronization states and timestamps
E. Cookies & Analytics
Essential cookies for authentication and session management
Analytics cookies for service improvement and usage analysis
Fortem does not collect:
Credit card or bank information
Government-issued identification
Biometric data
Off-chain financial data
3. How We Use Data
We use personal data solely for legitimate operational purposes, including:
Providing and maintaining access to the Service
Processing listings, purchases, and on-chain actions
Managing Export, Redeem, and game integration workflows
Ensuring platform security, fraud prevention, and abuse detection
Improving platform performance and user experience
Complying with applicable legal obligations
Fortem does not sell personal data to third parties.
4. Data Storage & Security
Personal data is stored on servers located in Panama and the United States (Virginia).
We implement reasonable technical and organizational safeguards, including:
Encryption in transit and at rest
Role-based access controls
Audit logging and monitoring
Secure internal access policies
Only authorized personnel may access personal data for legitimate operational purposes.
5. Cross-border Data Access and Transfers
Due to the global nature of Fortem’s operations, personal data may be securely accessed from multiple jurisdictions, including:
Panama – primary operations and administration
United States (Virginia) – infrastructure and hosting services
Republic of Korea – authorized technical and operational staff
Such access is limited to what is strictly necessary and is protected through:
Encrypted communication channels
Role-based access controls
Internal confidentiality and security policies
Fortem ensures that any cross-border access maintains an appropriate level of data protection.
6. Legal Basis for Processing
We process personal data based on one or more of the following legal grounds:
Performance of a contract (providing the Service)
Legitimate interests (security, fraud prevention, platform optimization)
Compliance with applicable laws
User consent where required (e.g., optional analytics cookies)
7. Data Retention
Fortem retains personal data only for as long as reasonably necessary to fulfill operational and legal purposes.
On-chain Data Exception
Blockchain records are immutable and cannot be altered or deleted.
If you request deletion, Fortem will remove off-chain identifiers that link personal data to on-chain records, where technically feasible.
8. Your Rights
Depending on applicable law, you may request:
Access to your personal data
Correction of inaccurate information
Deletion of off-chain personal data
Restriction of processing
Information regarding automated processing
Details about cross-border data access
Requests may be submitted through Fortem support channels.
9. Cookies
Fortem uses:
Essential cookies required for authentication and security
Optional analytics cookies for service improvement
Fortem does not use advertising or third-party tracking cookies.
10. Third-Party Services
Fortem may use third-party infrastructure and analytics providers (such as cloud hosting or security services).
All such providers operate under contractual obligations to protect data and process it solely for Fortem’s operational purposes.
Fortem does not use third-party payment processors and does not handle fiat payments.
11. Children
The Service is intended for users aged 18 or older.
Fortem does not knowingly collect personal data from minors.
12. Changes to This Policy
Fortem may update this Privacy Policy from time to time.
Any changes will be posted on this page, and continued use of the Service constitutes acceptance of the revised Policy.
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