PRIVACY POLICY

Last updated October 20, 2022

This Privacy Policy provides our privacy policy regarding the nature, purpose, use, and sharing of personal data or other information collected from the users of the website https://gamedao.co and other websites which use subdomains of gamedao.co ('Website'). We are committed to protecting and respecting your privacy. Please read this carefully as this Privacy Policy is legally binding when you use the Site.

As used in this Privacy Policy, "we", "us" or "our" refers to GameDAO AG, a Liechtenstein based limited company. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at compliance@gamedao.co.

ACCEPTANCE OF THE PRIVACY POLICY

By accessing, connecting, clicking on, using, or engaging in our Services, you indicate and confirm that you have consented and agreed to the terms of this Privacy Policy. We will not use your Personal Information for any other purpose that has not been covered in this Privacy Policy or the T&Cs without providing you prior notification or obtaining your consent.

If you do not agree, either partially or wholly, to this Privacy Policy, you must immediately discontinue accessing, connecting, using, or engaging in our Services and GameDAO Platform. This Privacy Policy does not apply to services offered by other companies or service providers or other websites linked from our Platform.

DATA PROCESSING IN CONNECTION WITH THE WEBSITE

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Use of Cookies and Similar Technologies

The Site is using cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies are typically stored on your computer's hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Site and analyze trends. The information collected from cookies allows us to determine such things as which parts of the Site are most visited and difficulties our visitors may experience in accessing the SIte. With this knowledge, we can improve the quality of your experience on the Site by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties.

We use third party service providers, to assist us in better understanding the use of our Site. Our service providers will place cookies on the hard drive of your computer (or use similar technologies) and will receive information that we select that will educate us on such things as how visitors navigate around our Site. This information is aggregated to provide statistical data about our users' browsing actions and patterns, and does not personally identify individuals. This information may include:

  • Computer or mobile device information,
  • Website usage information, such as: -- Page views, -- Button clicks, -- Input form changes (without the values being entered), -- Errors.

Our service providers analyse this information and provide us with aggregate reports. The information and analysis provided by our service providers will be used to assist us in better understanding our visitors' interests in our Website and how to better serve those interests. If you want to avoid using cookies altogether, you can disable cookies in your browser. However, disabling cookies might make it impossible for you to use certain features of the Website. Your use of the Site with a browser that is configured to accept cookies constitutes an acceptance of our and third-party cookies.

Email Marketing

If you subscribe to our newsletter we may occasionally communicate project news, updates, promotions and related information relating to GameDAO. We shall only do this where you have given us your consent. If you want to opt out of receiving promotional and marketing emails in relation to which you might receive in accordance with this section, you can best opt out by clicking "unsubscribe" at the bottom of an email we sent you.

Social media

We may use plugins from social networks such as GitHub, YouTube, Reddit, Twitter, Telegram, Medium on the Website. When you activate them (by clicking on them), the operators of the respective social networks may record that you are on the Website and may use this information. This processing of your personal data lays in the responsibility of these individual social media platforms and occurs according to their privacy policies. Please check with these individual social media platforms regarding their privacy policies. We are not responsible for data collected by these individual social media platforms.

2.1 Personal Information Provided by you.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • names
  • phone numbers
  • email addresses
  • usernames
  • passwords
  • contact preferences
  • contact or authentication data
  • home address
  • digital wallet address

2.1 Information provided by you when connecting with GameDAO and for KYC purpose

GameDAO uses a third party service to perform KYC checks, when necessary. This means that GameDAO does not store any information provided through the third party provider. Nevertheless, GameDAO receives a positive or negative answer whether an user is verified during such a KYC process. All Affiliate and Third Parties with whom you share your Personal Information have their privacy policies. However, they will be expected to protect this information in a manner that aligns with the provisions described in this Privacy Policy.

For the KYC examination, you must provide your full name, phone numbers, birthday date, nationality, home address, location, government identification number (Identification Card/Passport Number and Date of the Issuance of Identification Card/Passport), telegram username, digital wallet address, email address, IP address, documentation for proof of address and other information as we required which can be used to distinguish your identity, to access the GameDAO Platform and for the Know Your Customer ("KYC") Verification purpose.

In addition, you might be required to upload facial image data, namely photo images of your face and provide additional information when first connecting with GameDAO such as linking to your Facebook account, Telegram, LinkedIn, GitHub, Google, or Twitter or other social media accounts, and more.

2.2 Communication Information

You hereby agree that we are entitled to collect and use or process the Personal Information you have provided on our Platform or generated through your usage of GameDAO Services for the purpose of being able to communicate with you through messages, requests, emails, live chats, file attachments in connection with your transactions on GameDAO, or any other information related to your contact with GameDAO. If you contact us, we will keep a record of the information shared during the correspondence.

1.1. ~~Financial Information~~

You hereby agree that, for the purposes stipulated in this Privacy Policy, we are entitled to collect and use the information contained in or related to your financial information when you use our services. This includes, without limitation, your transaction history such as your initial cryptocurrency or token amount, your GameDAO Token amount, your staking instructions, your wallet address etc.

We collect this financial information to monitor suspicious financial activities to protect you from fraud, resolution of legal cases, as well as any other purposes disclosed in this Privacy Policy.

Parts of GameDAO Services are public, including any information disclosed on our social media accounts, thus you acknowledge that such parts of GameDAO Services may appear on search engines or other publicly available platforms, and may be "crawled", searched and used by the third parties or other Users and Customers of the Services. Please do not post any information that you do not wish to reveal publicly.

2.4 Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, phone number, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings). This information will either be directly obtained by GameDAO or through third party service providers.
  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
  • Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

HOW WE COLLECT PERSONAL INFORMATION

Information automatically collected by us

We will collect and process Personal Information automatically provided by you under the following situations.

  • ~~when you visit and/or firstly connect with the Website;~~
  • ~~when you voluntarily complete any user survey or provide feedback to Us via emails or any other electronic channels including on Our social media accounts;~~
  • ~~when you use browser cookies or any other relevant software upon visiting the~~ ~~Website; or~~
  • ~~other situations where we may automatically collect your information as described in this Privacy Policy, our T&Cs, or other relevant agreements with You.~~

Information collected by the third-party

We will collect your Personal Information from the third parties as required or permitted to the extent of applicable laws. Information from the third-party sources will include, but will not be limited to, public databases, ID verification partners, KYC Verification partners, blockchain data, marketing partners and resellers, advertising partners, and analytics providers.

Anonymised and Aggregated Data

We will also collect other Information in the form of anonymised and aggregate information where all information will be combined and then removed of personally identifiable information, making it unusable for the identification of specific individuals. Aggregated data could be derived from your personal data, but it is not considered as personal data under applicable laws. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific features of GameDAO Services. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, you acknowledge that we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We use anonymised or aggregate users' information for the purposes stipulated in this Privacy Policy at any time, including gaining better understanding of users' needs and behaviours, conducting business intelligence and marketing initiatives, and detecting security threats. In this regard, We reserve the right to implement innovative technologies as they become available to be used for strategic planning and operational processes.

HOW DO WE PROCESS YOUR INFORMATION?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
  • To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
  • For communication purposes. We use your Personal Information, collected or derived from your communication devices or your email address, to interact with You directly, to provide You with necessary support, and/or to keep you informed of wallets connected, transactions, staking instructions, security details, as well as other aspects. All direct communications will be appropriately maintained at GameDAO, or the service providers designated by GameDAO, to be reviewed for accuracy, retained as evidence, or used to perform other statutory requirements or other obligations as stipulated in this Privacy Policy and the T&Cs.
  • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
  • To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
  • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
  • To ensure that our interface and/or Platform is seamlessly accessible for all users around the world, except users in the prohibited jurisdictions.
  • To comply with regulations and compliance. For Our legitimate interests, We will use the information in compliance with Our legal obligations, global and local industry standards, and Our AML/KYC procedures. In the case where it is strictly necessary (i.e., to protect the vital interests of the users or other natural persons, to prevent or mitigate fraud, to fulfil the purpose of public interest, or to pursue Our reasonable interests), we may use and process your Personal Information without obtaining your consent. You hereby expressly authorise GameDAO to disclose any and all information relating to You in GameDAO's possession to any law enforcement or government officials upon a valid request.
  • For measurement, research and development purposes. We actively measure and analyse your information to understand the way you use and interact with our Services, and Our Platform, and to provide you with the unique and personalized experience. For example, we allow you to use social media plugins on our Services (e.g., Telegram, Twitter, etc.), we keep track of your preferences such as display name, time zone, and so on. This review is continuously conducted by our operation teams to continuously improve our Platforms' performance and to resolve issues with User experience.

WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share information in specific situations described in this section and/or with the following third parties.

  • ~~GameDAO may disclose your information if it is required by law or if, in good faith, it considers that such access or disclosure is reasonably necessary to (i) respond to a complaint against GameDAO, (ii) to comply with legal procedures~~
  • ~~To~~ o_~~ur partners who offer the service of sending marketing materials;~~_
  • ~~To~~ o_~~ur partners who offer the service of direct communication with you;~~_
  • ~~To~~ o_~~ur partners who offer electronic document signing services~~_ ~~(for example, DocuSign);~~
  • ~~If we sell a business or assets, we may disclose your personal data to the possible buyer or seller of such a business or asset;~~
  • ~~If GameDAO is acquired, in part or in full, by a third party, the personal data held by~~ GameDAO ~~of its members will represent one of the assets transferred.~~

GameDAO may disclose your information to the third parties in order to administer or process a transaction, or services you have authorised or requested, or in the context of facilitating the execution of a transaction, or we may disclose Personal Information to third parties that provide supporting services, or analytical information for the purpose of the Service improvement, only where we have a lawful basis to do so or under an agreement or legal requirements for the transfer of Personal Information.

We will be required to verify your identities by applicable laws and regulatory requirements and rely on third-party services to perform these verifications. Personal Information that you provide to Us during the initial connecting process is passed to these services at KYC Verification process and on an ongoing basis thereafter.

We may share your Personal Information with third-party processors acting on behalf of GameDAO or engaged by GameDAO to process your Personal Information for GameDAO, Our Affiliate and/or Our Partners.

All Affiliate and Third Parties with whom We share your Personal Information have their privacy policies. However, they will be expected to protect this information in a manner that aligns with the provisions described in this Privacy Policy.

Third-Party Collection of Personal Information

This Privacy Policy only addresses the use and disclosure of the Personal Information we collect from you. To the extent that you disclose your information to other parties through the use of Our Services such as by clicking on a link to any other websites of our partner networks, different rules regarding Privacy Policies may apply to their use or disclosure of the Personal Information You disclose to them.

You hereby acknowledge that we will not be responsible for the products, services, or descriptions of products or services that you receive from the third-party websites or to the content or privacy practices of the third-party websites. Also, this Privacy Policy will not be applied to any such third-party products and services that You access through GameDAO Platform. You are knowingly and voluntarily assuming all risks of using third-party websites to purchase products or services, and You agree that We will have no liability whatsoever concerning such third-party websites and your usage of them.

Your relationship with these third parties and their services and tools is independent of your relationship with Us. These third parties may allow You to permit/restrict the information that is collected. It may be in your interest to individually restrict or enable such data collections.

HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

You agree that we will not hold any responsibility for the acts committed by those who gain unauthorised access or abuse your information and services. In addition, We will not hold any responsibility for any act committed by the third-party service providers who are contractually engaged with Us to maintain an appropriate security measure for protecting your Personal Information. Thus, you are recommended to understand this responsibility and to independently take safety precautions to protect your Personal Information, particularly your credential information such as your wallet address. You hereby agree that we will not be liable for any information leakage and other damage or loss not caused by our intention or gross negligence, including, but not limited to, hacker attacks, power interruptions, or unavoidable technical failures.

WHAT ARE YOUR PRIVACY RIGHTS?

This provision applies to Users of the Services that are located in the EEA, United Kingdom and/or Switzerland (herein collectively referred as "Designated Countries") at the time of Data or Personal Information being collected. We may ask for your information regarding your nationality, your location, which country you are in when you use our Services or Platform, or we may rely on your IP address. We cannot apply this provision to Users who do not provide information about the location or obfuscates location information so as not to appear located in the Designated Countries.

We use and process your Personal Information based on a valid lawful basis of the GDPR and any equivalent regulations (collectively referred as "Data Protection Laws"). The lawful basis for processing your Personal Information includes (i) your consent, (ii) performance of a contract, (iii) a legitimate interest, (iv) a compliance with legal obligations, (v) protection your vital interest, and (vi) public task.

In the event of any conflict or inconsistency between any term in this provision and other terms contained in this Privacy Policy, the term in this provision will govern and control over Users in the Designated Countries.

Under certain circumstances when you use our Services, you have the rights under the Data Protection Laws in relation to your Personal Information. These rights include the followings:

Right to be informed

You reserve the right to be informed about the collection, use, and process of your Personal Information.

Right of access

You reserve the right to make a request for a copy of the Personal Information we hold about you and specific information regarding Our processing of this information.

Right to rectify

You reserve the right to request Us to update, correct, or complete your Personal Information that You believe to be outdated, inaccurate, or incomplete. You will rectify at any time by informing Us via our contact channels.

Right to Erasure ("Right to be Forgotten")

You may request to have your Personal Information deleted from Our records where (i) your Personal Information is no longer necessary to be used for the Services or on the Platform, (ii) Personal Information was collected in relation to processing that You previously consented to, but later withdrew such consent, or (iii) your Personal Information was collected in relation to processing activities to which You object, and there are no overriding legitimate grounds for Our processing.

Please be informed that the Right to be Forgotten mentioned above is not an absolute right. We are compelled to fulfil your request only where the retention of your Personal Information might cause an infraction of the GDPR or applicable law to which We are subject. We shall exercise reasonable efforts in having your Personal Information erased to the extent required by the GDPR or applicable law including in communicating erasure to Our recipients of your Personal Information unless that proves to be impossible or a disproportionate effort.

Right to data portability

You reserve the right to request to transfer a machine-readable copy of your Personal Information to You or the third-party of your choice. We will provide You, or third-party, your Personal Information in a machine-readable format. This right only applies to Personal Information you have consented to us to use.

Right to restrict processing

You may request us to restrict or suppress the processing of your Personal Information under certain circumstances as follows:

  • ~~to contests the accuracy of the Personal Information;~~
  • ~~when the processing is considered unlawful, but you do not wish to have your Personal Information erased;~~
  • ~~where We no longer need to process your Personal Information, but the information must be retained for the establishment, exercise or defence of legal claims; and~~
  • ~~where you have objected to our processing your Personal Information, but we need to determine whether our legitimate interest overrides your objection.~~

Right to object

You may object to Our reliance on Our legitimate interests as the basis of our processing of your Personal Information that impacts your rights. You may also object to our process of your Personal Information for direct marketing purposes.

Right to withdraw consent ("Opt-out")

You reserve the right to withdraw your consent at any time where We are relying on it to process your Personal Information. Withdrawing your consent does not affect the lawfulness of Our processing of your Personal Information prior to withdrawing.

If you wish to exercise these rights as aforementioned, please inform and contact us via our Platform, including the Website or send a request to compliance@gamedao.co

Please also be noted that there are some limitations when You wish to exercise any one of these individual rights. We may limit your individual rights in the following situations:

  • ~~Where denial of access is required by laws;~~
  • ~~When granting access would have a negative impact on others' privacy;~~
  • ~~In order to protect our rights and properties;~~
  • ~~Where the~~ request is burdensome_~~.~~_

Cross Border Transfer of Personal Information

As a part of your use of and to ensure better and seamless delivery of the Services to you, we may store, process, analyse, transfer your Personal Information in location globally, including countries other than your home jurisdiction, and/or locations outside the Designated Countries where there may have data protections with less protection than the EU GDPR or the equivalent data protection laws.

Our Service and Platform contain the transmission of your Personal Information to or to be transferred to or to be processed outside of the country where you are located or outside the Designated Countries, it is not suggestible if your Personal Information is restrictive.

However, if you wish to continue using our Services outside the Designated Countries and your home locations, we will ensure that we will transfer your Personal Information only to country that has the required contractual provisions for transferring Personal Information in place with the third parties to which your Information is transferred, or to country where is approved by the EU authorities as providing an adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection in the jurisdiction of the party receiving the information. In this manner, you hereby expressly consent to this transfer, and agree that we will not be responsible for any additional T&Cs, policies or any other guidelines implemented by any party receiving the information.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

DO WE MAKE UPDATES TO THIS NOTICE?

We will revise and update this Privacy Policy periodically, at our sole discretion, and the most current version will be published on the Website (as reflected in the "Last Revised" heading).

In the event of any material change which may affect your usage on our Services and Platform, We will notify You by means of a prominent notice in advance of such change coming into effect. A prominent notice may include sending through your email address or other communication channels you provide to us or providing you with an in-application notice such as a banner or pop-up alerting You of the change on the Website. We strongly encourage you to review this Privacy Policy actively. If you do not agree, either partially or wholly, the revised Privacy Policy, you should discontinue accessing or using Our Services. Your continued access to and use of our Services after any changes to this Privacy Policy constitutes your consent to any changes and agree to continue using the Services.

Furthermore, we may provide you with the "just-in-time" disclosures or additional information about Our data collection process, purposes for processing, or other information with respect to collection of your personal information. The purpose of the just-in-time notification is to supplement or clarify our privacy practice or provide You with additional choices about how We process your personal information.

LIMITATIONS

Our Services are not designed for the individuals who are under the age of 18 or under the legal age to provide consent under the applicable laws of the country or jurisdiction where you are using our Services or Platform. If you are not over 18 or of the legal age of your country, you will not provide any Personal Information to us, or to engage in Our services. We reserve the right to access and verify any Personal Information collected from You. If we are aware that you are under 18 or under the legal age who already shared your Personal Information with us, we will then discard such information and block your access to GameDAO Platform immediately.

We cannot guarantee that any losses, misuses, unauthorized accession, or alteration of your Personal Information will not occur. You hereby agree that You play a vital role in protecting your Personal Information, including your credentials.

HOW TO CONTACT GAMEDAO

For any questions regarding this Privacy Policy, your Personal Information collected or proceeded by Us, or in case You would like to exercise one of your legal privacy rights as stipulated in Clause 11, please submit your requests to compliance@gamedao.co or by post to:

GameDAO AG Werdenbergerweg 11 Vaduz 9490 Liechtenstein