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Privacy Policy

Last updated: March 11, 2024

This Privacy Policy describes how your personal data is collected and processed when you, an individual, are a user of the website _____ (hereinafter "Website") or related dApps.

To simplify reading this Privacy Policy, our Website, dApps, service content, and all related features, services, content, and applications that we may provide to you from time to time, etc., are collectively referred to as "Services".

We ask you to carefully read this Privacy Policy, which was last updated on the date indicated above (hereinafter "Privacy Policy"), as it contains important information about who we are, how and why we collect, store, use, transfer and share personal information, about your rights regarding your personal information, and how to contact us and supervisory authorities in case you have a complaint. This Privacy Policy should be read together with and in addition to any separate product or service agreement entered into between us from time to time.

Whenever we refer to "law" within this Privacy Policy, we mean all laws as amended from time to time. If we have used but not explained the meaning of a certain term in this Privacy Policy, that term has the same meaning as in the Terms of Use. When we refer to "information" or "data" within this Privacy Policy, we mean your personal information.

We collect your personal information when you visit, use, or interact with us online, as well as through our advertising displayed through online services operated by us or unrelated third parties. We may use or share the collected personal information to provide you with products and services, as well as for advertising purposes.

By browsing, accessing, or using the Services, you hereby unconditionally agree to this Privacy Policy.

The terms "Company", "we", "us", "our" or _____ refer to _____, a company with registration number _____, registered at: _____.

This Privacy Policy is governed by the applicable laws and regulations of England and Wales.

For users from the EU, the provisions of the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR) and the Data Protection Act 2018 apply.

The Company makes every effort to protect your privacy. The Company uses the information collected about you to fulfill its contractual obligations and improve customer service.

All terms defined in the Terms of Use have the same meaning in this Privacy Policy. "Personal Data" and "Personal Information" mean any information relating to an identified or identifiable living person.

We request your consent when necessary; otherwise, by using our Services, you agree to the collection, use, and sharing of your personal information in accordance with applicable laws and other notices you may have received based on your relationship with us.

PLEASE READ THE PRIVACY POLICY CAREFULLY BEFORE CREATING YOUR ACCOUNT. IF YOU DO NOT AGREE WITH ALL OR ANY OF THESE TERMS, PLEASE LEAVE THE WEBSITE OR DAPP IMMEDIATELY

1. COLLECTION OF YOUR PERSONAL DATA

1.1. Personal data that we may collect

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information that we receive automatically when you use our Services, and information from other sources, such as third-party services and organizations, as described below.

1.1.1 Information that you provide to us directly

We may collect the following personal information that you provide to us:

  • Account creation. We may collect information when you create an account with us, such as name and email address, as well as your mobile money ID. We may also require you to provide additional information for identification and verification.
  • Transaction information. To complete transactions within the Services, you may need to provide us or our third parties with information about your payment or information about your digital wallet, etc. We will never request or collect your private keys.
  • Other transactions. We may collect personal information and details related to your activities in our Services.
  • Your communication with us. We may collect personal information, such as email address, when you request information about our Services or otherwise communicate with us.
  • Interactive features. We and other users of our Services may collect personal information that you submit or make available through our interactive features (for example, through Discord community, messaging and chat features, and social media pages). Any personal information you provide in public sections of these features will be considered "public" ("User Content"), unless otherwise required by applicable law, and is not subject to the privacy protection mentioned herein. Please be careful before disclosing any information that could identify you in the real world to other users.
  • Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, which may include personal information.
  • Business development and strategic partnerships. We may collect personal information from individuals and third parties to evaluate and implement potential business opportunities.

1.1.2 Information collected automatically

We may automatically collect personal information when you use our Services:

  • Automatic data collection. We may automatically collect certain information when you use our Services, such as your Internet Protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), Internet service provider. We may also automatically collect information about your use of our Services, such as pages you visit before, during, and after using our Services, information about links you click on, types of content you interact with, frequency and duration of your activities, and other information about how you use our Services.
  • Policy on the use of cookies, pixel tags/web beacons, and other technologies. We, as well as third parties providing content, advertising, or other features on our Services, may use cookies, pixel tags, local storage, and other technologies ("Technologies") to automatically collect information through your use of our Services.
  • Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
  • Pixel tags/web beacons and other technologies. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about interactions with our Services. The use of a pixel tag allows us to record, for example, that a user has visited a specific web page or clicked on a specific advertisement. We may also include web beacons in emails to understand if messages were opened, acted upon, or forwarded.

Our use of these Technologies falls into the following general categories:

  • Operationally necessary. This includes Technologies that allow you to access our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to use our functionality;
  • Performance-related. We may use Technologies to assess the performance of our Services, including as part of our analytical practices to help us understand how people use our Services (see "Analytics" below);
  • Functionality-related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you log into our Services or tracking your specified preferences, interests, etc.;
  • Advertising or targeting-related. We may use our own or third-party Technologies to deliver content, including advertisements, relevant to your interests, on our Services or on third-party websites.

See "Your Privacy Choices and Rights" below to understand your choices regarding these Technologies.

Your Privacy Choices

The privacy choices you may have regarding your personal information are determined by applicable law and described below.

  • Electronic messages. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those messages (e.g., communications regarding our Services or updates to our Terms of Use or this Privacy Policy).
  • "Do Not Track". "Do Not Track" ("DNT") is a privacy preference that users can set in certain web browsers. Note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
  • Cookies and interest-based advertising. You can stop or limit the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Note that cookie-based opt-outs are not effective on mobile applications. However, you may opt out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others. Please note that you must separately opt out in each browser and on each device.

The online advertising industry also provides websites from which you can opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access them and learn more about targeted advertising, consumer choice, and privacy by visiting the Network Advertising Initiative, Digital Advertising Alliance, European Digital Advertising Alliance, and Digital Advertising Alliance of Canada.

Your Privacy Rights

In accordance with applicable law, you may have the right to:

  • Access personal information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; or (iii) receiving an electronic copy of personal information that you have provided to us, or asking that we send this information to another company (the right to data portability);
  • Request correction of your personal information if it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
  • Request deletion of your personal information;
  • Request restriction of or object to our processing of your personal information, including where the processing of your personal information is based on our legitimate interest or for direct marketing purposes; and
  • Withdraw your consent to our processing of your personal information. Please note that your withdrawal will only apply to future processing and will not affect the lawfulness of processing before the withdrawal.

If you wish to exercise any of these rights, please contact us. We will process such requests in accordance with applicable laws.

Analytics

We may use our Technologies and other third-party tools to process analytics information on our Services. These technologies allow us to process usage data to better understand how our Services are used, and to continually improve and personalize our Services. Some of our analytics partners include:

  • Google Analytics. For more information about how Google uses your data (including for its own purposes, such as for profiling or linking it to other data), please visit Google Analytics' Privacy Policy.

Social Media Platforms

Our Services may contain social media buttons such as Discord, Snapchat, Twitter, and Telegram, which may include widgets such as the "share this" button or other interactive mini-programs. These features may collect your IP address and information about which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing them.

1.1.3 Information collected from other sources

Third-party sources. We may receive information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available through your privacy settings.

2. USE OF YOUR PERSONAL DATA

2.1. We use your data for the following purposes:

  • 2.1.1 To fulfill obligations and provide you with services for which we have received your consent;
  • 2.1.2 To understand your needs and preferences when using our Services;
  • 2.1.3 To develop new and improve existing service and product offerings, to notify you of changes related to our Services;
  • 2.1.4 To verify and confirm the identity of users who open and manage accounts, in order to prevent fraud, deception, and other illegal activities;
  • 2.1.5 To comply with legal requirements for combating money laundering and terrorist financing;
  • 2.1.6 To ensure the security of our Website, our Services, and your account;
  • 2.1.7 To support, respond to, and resolve your complaints and issues related to the use of our Services and the capabilities of our Website or our dApps.
  • 2.1.8 Other purposes. We also use your information for other purposes at your request or in accordance with applicable law.

Automated Decision-Making

We may engage in automated decision-making, including profiling. Our processing of your personal information will not result in a decision based solely on automated processing that significantly affects you, unless such a decision is a necessary part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision-making. If you have questions about our automated decision-making, you may contact us.

De-identified and Aggregated Information

We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified location information, information about the device from which you access our Services, or other analyses we create.

2.2. We use aggregated personal data to understand how our users use our Services, provided that this data cannot identify any individual. We also use third-party web analytics tools that help us understand how users interact with our website.

3. DISCLOSURE OF YOUR PERSONAL DATA

3.1 We may share your information with selected third parties, including:

  • 3.1.1 business partners, suppliers, and independent contractors to perform any contract we enter into with them or with you;
  • 3.1.2 advertisers and advertising networks (only aggregated personal data);
  • 3.1.3 analytics and search engine providers that assist us in the improvement and optimization of services;

3.2 We may also disclose your personal data if:

  • 3.2.1 if we are obliged to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use or other conditions; or to protect the rights, property, or our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

4. SECURITY AND STORAGE OF YOUR PERSONAL DATA

4.1. We have implemented security measures to ensure the confidentiality of your personal data and to protect your data from loss, misuse, alteration, or destruction. Only authorized representatives have access to your personal data, and these representatives are required to treat the information as confidential. The security measures currently in place will be reviewed from time to time in line with legal and technical developments.

4.2. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

4.3. We will not sell, rent, or transfer your information to third parties. However, we may share your information with trusted third parties to help us perform statistical analysis, send you email, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to us, and they are required to maintain the confidentiality of your information.

4.4. Our website may from time to time contain links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for these policies. Please check these policies before you submit any personal data to these websites.

4.5. We will keep your personal information for as long as you are a customer of _____. We may keep your personal information for up to 5 years after you stop being a customer. The reasons we may do this are:

  • to respond to a question or complaint, or to show whether we gave you fair treatment;
  • to study customer data as part of our own research;
  • to comply with legal rules that apply to us about keeping records.

We may also keep your data for longer than 5 years if certain laws mean we cannot delete it for legal, regulatory, or technical reasons.

5. INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

6. MISCELLANEOUS

6.1. The Privacy Policy remains in full force and effect while you use the Website.

6.2 The Company reserves the right to change the Privacy Policy at any time at the Company's sole discretion. They will notify you of amendments by means of an automatic notification on the Website, but will not request any action to confirm your consent. If you do not agree with the new amended version, then you must immediately cease access to the Website and stop using all Services. If you continue to use the services, the amended Privacy Policy is legally binding for you, and your actions will constitute acceptance of the amendments.

6.4. If you are in the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

6.5. The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us. If we learn that we have collected a child's personal information in violation of applicable law, we will promptly take steps to delete such information.

6.6. You can withdraw your consent to our processing of your information at any time. Please contact us if you want to do this at: _____. This will only affect the way we use information when our reason for processing your information is that you have given your consent to this use. If you withdraw your consent, we may not be able to provide certain services to you. If this is the case, we will tell you. You then have the option to give us your consent again if you want to access our products or services.

6.7. We will apply adequate technical and organizational security measures to protect your personal information. We will make reasonable efforts to ensure that your personal data is accurate, complete, and up-to-date. Please ensure that you notify us without undue delay of any changes to the personal data you have provided to us by updating your details or contacting us using the contact details provided in this Privacy Policy.

6.8. By accessing the Website or using any of our products or services, you agree and authorize the export of personal data to the Company, as well as its storage and use as specified in this Privacy Policy.

This Privacy Policy is governed by, interpreted, and takes effect in accordance with the laws of England and Wales applicable to contracts deemed to be made within such state, without regard to choice of law or conflict of law provisions. Exclusive jurisdiction for all disputes between you and the Company will belong to the state and federal courts located in England and Wales, and you and the Company waive any objections to jurisdiction and venue in such courts.

HOTBY YOU WAIVE YOUR RIGHT TO A JURY TRIAL IN RESPECT OF ANY CLAIM, ACTION OR PROCEEDING DIRECTLY OR INDIRECTLY ARISING OUT OF OR RELATING TO THIS AGREEMENT, TO THE MAXIMUM EXTENT PERMITTED BY LAW.

7. CONTACT INFORMATION

7.9. We are responsible as the "Controller" of this personal information for the purposes of those laws. If you have any questions about this Privacy Policy or how we (may) collect, store, or use your information, please contact us by email at: _____.