Privacy Policy
Effective as of April 1, 2019

Welcome to Midgame! We have prepared this Privacy Policy (“Policy”) to describe our practices regarding how we collect, use disclose and otherwise process personal information in connection with our website located at (referred to as the “Website”) and our other services including our online services (collectively with our Website referred to as the “Services”).

We respect your privacy and hope this Policy explains how we use your information to improve your experience while using our Website and Services. We also encourage you to review our Terms of Use, which govern your use of the Website and Services.

If you are located in the European Union, we recommend you read the important information provided below, in addition to the other provisions in this Policy.

The Midgame Sites and Services are operated by Headlight Corp (“we”, “us” or “our”). If you have any questions about this Policy or our practices, please contact us at

A Note to Users Outside of the United States

We are headquartered in the United States and has service providers in the United States and other countries. Your data, including personal information that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using the Website or the Services, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.


Children under the age of 13 are not eligible to use our Services. Protecting the privacy of children is very important to us. We do not intentionally gather personal information from visitors who are under the age of 13. If you believe that we might have any personal information from a child under 13, or a parent or guardian becomes aware that his or her child under the age of 13 has provided us with information without his or her consent, please contact us at, and we will delete such information from our files as soon as reasonably practicable.

Personal Information We Collect

Information you give us

We collect personal information that you submit to us voluntarily at registration and in the course of your use of the Website and/or Services. For example, to use our Services, we may require you to create an “Account” by providing your name, email address and a password, and other information you voluntarily submit to us. Personal information that you may provide through the Services or otherwise communicate with us includes:

  • Contact information, such as your first name, last name, and email address.
  • Profile information, such as your username and password, your photograph, interests and preferences.
  • Feedback and correspondence, such as information you provide when you report a problem with the Services, receive customer support, or otherwise correspond with us.
  • Transaction information, such as billing information and details about purchases or transactions you make through the Services or while using the Services, and information you provide when you enter into one of our contests or other promotions.
  • Marketing information, such your preferences for receiving marketing communications and details about how you engage with marketing communications.
  • Location information, such as information about your location based on technologies including GPS, IP address or connected or nearby Wi-Fi networks.
Information we get from others

We may receive additional information about you from third parties, including partners that provide us information that is publicly or commercially available, and may combine that information with the other information we collect about you to improve your experience with our Services and to provide you with more relevant information related to our service offerings.

Information from third party interactions

The Services may allow you to connect with other Website, platforms and services, including Discord and other social media and/or gaming platforms (“Third Party Sites”) through Midgame. We typically work with the Third Party Site’s application protocol interface (better known as their developer API) in a way that allows you to authorize us to access your account on that Third Party Site on your behalf. In order to provide this authorization, you do not provide us with your user name or password to the Third Party Site, but you will need to log-in to that Third Party Site directly through our Services. Once authorized by you, the Third Party Site provides us a token that allows the Third Party Site to recognize us when we ask, on your behalf, for access to your account information or to post information. For example, when you click “Connect” to grant Midgame access to your Discord account, we will import your username and profile photo from Discord, as well as other information. Also, both Midgame and the Third Party Site may have access to certain information about you and your use of the Services and the Third Party Site.

The information we collect in connection with your use of or interaction with Third Party Sites is subject to this Policy. However, we do not control any policies or terms of such Third Party Sites. As a result, we are not responsible for any collection or use of your information or content by a Third Party Site, including whether a third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on a Third Party Site. You can revoke our access to any Third Party Site at any time by amending the appropriate settings from within your account settings on the applicable Third Party Site.

Information automatically collected

We may automatically collect information about you or your computer or mobile device and how you use and interact with the Services and with other users of the Services. This may include information about your particular devices (e.g., the make and model and registration number of the computer, or other hardware used to interact with the Services), Internet Protocol address and other connectivity information such as browser type or Internet service provider, date/time stamp for and length of each session, pages you viewed, and geographic location. We also collect information about any in-application purchases or any in-game microtransactions made while using Third-Party Platforms.

We collect this information about you using cookies or similar technologies. Please refer to the Cookies and Similar Technologies section for more details.

Posted Content

When you post content (text, images, photographs, messages, comments or any other kind of content that is not your e-mail address) to or through any of the Services, the information contained in your posting will be stored in our servers and may be reproduced and viewed by other users. Please note that, as explained in the User Generated Content section of this Policy, we ask you not to include personal information in any files you upload to the Services or in the messages you exchange via the Services. If you choose to include personal information within those functionalities, we will not be able to limit the collection and use of that information by other users. If you submit user content, we may use your content and any excerpt from your user content in connection with our advertising marketing, publicity and promotional activities.

Sensitive Personal Information

We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

Cookies and Similar Technologies

What are cookies?

We may use cookies to collect information and enhance your user experience. Cookies are small pieces of information that a website sends to your computer’s or mobile device’s hard drive while you are viewing the website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Website. This type of information is collected to make the Website more useful to you and to tailor your experience with us to meet your special interests and needs.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Website; and (2) third party cookies, which are served by service providers on our Website, and can be used by such service providers to recognize your computer or mobile device when it visits other Website.

Cookies we use

Our Website use the following types of cookies for the purposes set out below:

  • Essential Cookies, These cookies are essential to provide you with Services available through our Website and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
  • Functionality Cookies, These cookies allow our Website to remember choices you make when you use our Website, such as remembering your language preferences, remembering your login details and remembering the changes you make on other parts of our Website which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Website or use our Services.
  • Analytics and Performance Cookies, These cookies are used to collect information about traffic to our Website and how users use our Website and Services. The information gathered may include the number of visitors to our Website, the Website that referred them to our Website, the pages they visited on our Website, what time of day they visited our Website, whether they have visited our Website before, and other similar information. We use this information to help operate our Website and Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Website and Services. We use Google Analytics for this purpose. Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available here. We also use Heap Analytics and Hotjar for analytics and performance analysis purposes.
  • Targeted and Advertising Cookies, These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information third party advertisers can place cookies to enable them to show advertisements which we think will be relevant to your interests while you are on third party Website.
  • Social Media Cookies, These cookies are used when you share information using a social media sharing button or “like” button on our Website or Services or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.
Disabling cookies

If you decide at any time that you no longer wish to accept cookies from our Services for any of the purposes described above, then you can typically instruct your browser, by changing its settings, to remove or stop accepting cookies or to prompt you before accepting a cookie from the Website you visit. In order to do this, consult your browser’s technical information (instructions are usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit

If you do not accept our cookies, you may experience some inconvenience or not be able to use all portions of the Services or all functionality of the Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Website.

Third party analytics providers and ad servers

We may work with certain third parties (including network advertisers, ad agencies and analytics companies) to provide us with information regarding traffic on the Website, to serve advertisements, including our advertisements elsewhere online, and to provide us with information regarding the use of our Website or Services and the effectiveness of our advertisements. These third parties may automatically collect information about you using their own cookies or other technologies, or may otherwise collect or have access to, information about your visits to this and other Website, your IP address, your ISP, the browser you use to visit our Website and other usage information. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Website and the other sites tracked by these third parties. If you would like more information about this practice and to know your choices about not having this information used by these companies, you may visit,, or (for users in the EU).

How We Use Your Personal Information

To provide our services

If you have an Account or use our Services, we use your personal information to:

  • Administer your Account;
  • Provide the Services and customer support;
  • Improve the Services and our product and service offerings;
  • Tailor the features and content of the Services to you;
  • Market our products and services and those of third parties to you that we believe may be of interest to you;
  • Respond to your requests, resolve disputes and/or troubleshoot problems; and
  • Communicate with you about the Services or your Account, including by sending you service announcements, technical notices, updates, security alerts and support and administrative messages.
To communicate with you

We may use your personal information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. If you request information from us (such as signing up for our newsletter), register on the Website, or participate in our contests or promotions, we may send you Midgame-related marketing communications as permitted by law. You will have the ability to opt out of such communications.

To comply with the laws

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

With your consent

We will request your consent to use your personal information where required by law, such as where we use certain cookies or similar technologies or would like to send you certain marketing messages. If we request your consent to use your personal information, you have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us. If you have consented to receive marketing communications from our third party partners, you may withdraw your consent by contacting those partners directly.

To create anonymous data

In an ongoing effort to better understand and serve our users, we may create anonymous data from your personal information and other individuals whose personal information we collect by excluding information that makes the information personally identifiable to you. We use anonymous data for our lawful business purposes, including to analyze trends, administer and improve the Services, track users’ movements while using the Services, gather demographic information about our user base as a whole, and better tailor our Services and any new services to our users’ needs.

For compliance, fraud prevention and safety

We use your personal information as we believe necessary or appropriate to enforce the terms and conditions that govern our Services, to protect our rights, privacy, safety, or property and/or that of you or others, and to protect against, investigate or deter fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Disclose Your Personal information

We may share non-personally identifiable information, such as aggregated user statistics or anonymous data, in our discretion and without restriction.

We may disclose personal information about you in the following circumstances:

  • To Users of the Services/Visitors to the Sites. Content you submit to the Website or through the Services including voice communications from game sessions are default private. However, it may be possible for you to share that audio and the associated stats with other users.
  • To Service Providers. We may share your personal information with our third party service providers that help us provide Services that we offer you or that provide Services on our behalf (such as customer support, hosting, email delivery and database management services). These third parties may use your information only as directed by us and in a manner consistent with this Policy, and are prohibited from using or disclosing your information for any other purpose.
  • To Affiliates. We may share your personal information with our parent company, subsidiaries or affiliates for purposes consistent with this Policy.
  • To Third Parties. When you use the Services, the personal information you provide will be shared with the third parties that you request or authorize to receive such information. For example, you may request that we share information about you with a third party when you use our Services to access an interactive feature or third party application, and we will typically do so under those circumstances. You may also be presented with an opportunity to receive information and/or marketing offers from one or more third parties, such as advertisers and advertising networks that require your personal data to select and serve relevant adverts to you and others. If you agree at that time to have your personal information shared, your personal information will be disclosed to that third party (or parties). Under any of these circumstances, all personal information that we share with third parties will be subject to the Policy and practices of that third party. We are not responsible for the privacy policies and practices of third parties and you should read and understand their privacy policies. If you later decide that you no longer want to receive communications from a third party or otherwise to do business with a third party, you will need to contact that third party directly.
  • Corporate Restructuring We may share your personal information in connection with or during a business deal (or potential business deal or negotiation thereof) such as a merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Policy.
  • Other Disclosures. We may disclose personal information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Services; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. We may also disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

How We Disclose Your Personal information

Under California Civil Code sections 1798.83- 1798.84, California residents have the right to ask for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for their direct marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us at or 340 S Lemon Ave #1023, Walnut, CA 91789 and put the following words in the subject line of the email or included in your written letter: "California Privacy Request." Please note that the California "Shine the Light" law does not cover all categories of information that may be collected and disclosed or shared, and our policy relates only to information covered by the law. Please also note that we are required to respond to one request per California user each year and we are not required to respond to requests made by means other than through this e-mail address or to the designated mailing address.

Your Choices


You may opt out of direct marketing emails or other communications by logging in and changing your account settings, by clicking on a link at the bottom of each such email, or by contacting us at You may continue to receive service-related and other non-marketing emails. Please note that your use of some of the Services may be ineffective upon opt-out.

Access, Update, Correct, or Delete Your information

All Account holders may review, update, correct or delete the personal information in their registration profile by logging into their Account. You may also contact us at to access, update or correct the personal information we maintain about you, or if you have additional requests or questions.

For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to requesting such change or deletion or for other reasons.

Choosing not to share your personal Information

Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services. We will tell you what information you must provide to receive the Services by designating it as required in the Services or through other appropriate means.


If you provide feedback to us, we may use and disclose such feedback in accordance with the terms in our Terms of Use, provided we do not associate such feedback with your personal information. We will collect any information contained in such feedback and will treat the personal information in it in accordance with this Policy, provided that we may contact you in regards to such feedback.


The security of your personal information is important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.

User Generated Content

We may make available on our Website or through our Services, or link to, features that allow you to generate your own content or share information online (e.g., on message boards or chat areas like a Discord channel, etc.). Please do not embed personal information in the content you generate or share personal information online in public or community forums. Whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage, dissemination or erasure of personal information embedded in user-generated content (including project files) or shared publicly. By posting personal information online in public or community forums, you may receive unsolicited messages from other parties.

Other Sites and Services

This Policy addresses only our collection, use and disclosure of information we collect from and/or about you on the Website and Services owned or controlled by Midgame and that post a link to this Policy. If you disclose information to others, or authorize us to do the same under this Policy, the use and disclosure restrictions contained in this Policy will not apply to any third party. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable.

The Website and Services may contain content or links to other Website or services that are not owned or controlled by us. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other Website. When you click on such a link, you will leave our Website and go to another site. During this process, another entity may collect personal information from you. The Website may also contain links to other Website controlled by us but which operate under different privacy policies. Please review the Policy of any new site you visit.

In addition, Midgame content may be included on web pages and Website that are not associated with Midgame and over which we have no control. These third parties may collect data through the use of their own cookies, pixel tags or other technology, independently collect information or solicit personal information, and may have the ability to track your use of their Website and services. Midgame is not responsible for the privacy practices or the content of any third party.

Changes to this Policy

This Policy may be updated from time to time for any reason, and we reserve the right to modify this Policy at any time. If we make material changes to this Policy you will be notified via e-mail (if you have an account where we have your contact information) or another manner through the Services that we believe reasonably likely to reach you (which may include posting the new Policy on our Website).

Any modifications to this Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes to the Services (or as otherwise indicated at the time of posting). In all cases, your continued use of the services after the posting of any modified Policy indicates your acceptance of the terms of the modified Policy. You should consult this Policy regularly for any changes.

Contact Us

If you have any questions or concerns or complaints about our Policy or our data collection or processing practices, please contact us at the following address or phone number:

Headlight Corp

Attn: Jason Shen

340 S Lemon Ave #1023
Walnut, CA 91789

Individuals in the European Union can also contact Jason Shen.

Additional Information for European Union Users

Personal information

References to “personal information” in this Policy are equivalent to “personal data” governed by European data protection legislation.

Controller and Data Protection Officer

Headlight Corp. is the controller of your personal information for purposes of European data protection legislation. See the Contact Us section above for contact details.

Our EU representative is Jason Shen.

Legal bases for processing

We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how we process your personal information, contact us at

  • To provide the Services Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services.
  • To communicate with you to create anonymous data for analytics For compliance, fraud prevention and safety These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
  • To comply with law Processing is necessary to comply with our legal obligations
  • With your consent Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Services or by contacting us at

Use for new purposes

We may use your personal information for reasons not described in this Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.


We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements

We may retain indefinitely certain information associated with content you upload to the Services, such as the title and authorship of your tracks. We encourage you not to embed any personal information in such content. When we no longer require the personal information we have otherwise collected about you, we will dissociate such information from the information attached to your content.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.

Your rights

European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

  • Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.
  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.
  • Correct. Update or correct inaccuracies in your personal information.
  • Delete. Delete your personal information.
  • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
  • Restrict. Restrict the processing of your personal information.
  • Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information.

You can submit these requests by email to or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described above or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

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