Effective date: April 5, 2022
- Sources of Personal Data
- How We Collect Personal Data
- How We Use Your Personal Data
- How We Share Your Personal Data
- Data Security and Retention
- Personal Data of Children
- State Law Privacy Rights
- Contact Information
Sources of Personal Data
We collect Personal Data about you (including Personal Data from children under thirteen (13)) from:
You: when you provide such information directly to us, including by posting your name, voice recordings, photos, or videos of yourself, and when Personal Data about you is automatically collected in connection with your use of our Services. With respect to the non-fungible token (NFT) collectible we offer, we may collect your email address and your electronic digital wallet address.
Our subsidiaries and affiliates (together, “Affiliates”), when they provide us with Personal Data about you.
Third parties, when they provide us with Personal Data about you (“Third Parties”). Third Parties that share your Personal Data with us include:
- Service providers. For example, we may use analytics service providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
- Social networks connected to the services. If you as a parent provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, you understand some content and/or information in those accounts may be transmitted into your Account with us. We do not allow children under 13 to sign up or login with social networks credentials.
- Advertising partners. If you are under thirteen (13), we do not disclose your Personal Data to advertising partners. If you are a parent or guardian, these parties help us market our services and provide you with other offers that may be of interest to you. They include ad networks and marketing providers.
- Analytics partners. These parties provide analytics on web traffic or usage of the Services. They include: companies that track how users found or were referred to the Services and companies that track how users interact with the Services
How We Collect Personal Data
Information Collected Automatically
We use the following types of Cookies:
- Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
- Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit https://www.allaboutcookies.org.
How We Use Your Personal Data
We process Personal Data (including Personal Data from children under thirteen (13)) to operate, improve, understand and personalize our Services. We use Personal Data for the following purposes:
- To meet or fulfill the reason you provided the information to us.
- To communicate with you about the Services, including Service announcements, updates or offers.
- To provide support and assistance for the Services.
- To create and manage your Account or other user profiles.
- To personalize website content and communications based on your preferences.
- To process orders or other transactions — such as for your purchase, sale or trading of NFT collectibles.
- To respond to user inquiries and fulfill user requests.
- To improve and develop the Services, including testing, research, analysis and product development.
- To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of our Services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.
As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services. If you do not want to receive communications from us, please indicate your preference by emailing us at email@example.com.
How We Share Your Personal Data
Disclosures of Personal Data for a Business Purpose
We may disclose your Personal Data, including Personal Data of children under thirteen (13), to service providers and other parties for the following business purposes:
- Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging to identify and repair errors that impair existing intended functionality.
- Short-term, transient use of Personal Data that is not used by another party to build a consumer profile or otherwise alter your consumer experience outside the current interaction.
- Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing advertising and marketing services if you are over 13, or providing similar services on behalf of the business or service provider.
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of a service or device that we own, manufacture, was manufactured for us, or control.
We disclose your Personal Data (including Personal Data from children under thirteen (13)) to the following categories of service providers and other parties:
- Service providers, including:
- Payment processors.
- Security and fraud prevention consultants.
- Hosting and other technology and communications providers.
- Analytics providers.
- Staff augmentation and contract personnel.
- Our Affiliates.
- Parties who acquire your Personal Data through an acquisition or other change of control. Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
- Other parties at your direction.
- Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services).
- Third-party business partners who you access through the Services.
- Social media services (if you are over 13 and intentionally interact with them through your use of Services).
- Other parties authorized by you.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data (including Personal Data from children under 13) we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.
Data Security and Retention
We seek to protect your Personal Data, including Personal Data from children under 13, from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. For example, the Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data you provide to us. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services, however we do not retain Personal Information from children under thirteen (13) longer than is reasonably necessary in order to fulfill the purpose for which it was disclosed. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Personal Data of Children
The Children’s Online Privacy Protection Act (“COPPA”) requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under thirteen (13). We do not knowingly collect or solicit personally identifiable information from a child under thirteen (13) without obtaining verifiable consent from that child’s parent or guardian (“Parental Consent”), except for the limited amount of personally identifiable information we need to collect in order to obtain Parental Consent (“Required Information”). Until we have received Parental Consent, we will only use Required Information for the purpose of obtaining Parental Consent.
We obtain Parental Consent using method(s) that are approved under COPPA. For example, we obtain Parental Consent by asking a child’s parent or guardian to record a video of themselves and upload it on the Services. We may also obtain Parental Consent by requiring a child’s parent or guardian to use an online payment system (for example, a credit card or debit card) that notifies the primary account holder of that online payment system each time a separate transaction is made that relates to our Services (an “Online Payment System”).
If you are a child under thirteen (13), please do not attempt to send any personal information about yourself to us before we obtain Parental Consent, except for the Required Information in the context of the Parental Consent process. If you believe that a child under thirteen (13) has provided us with personal information (beyond the Required Information) without our obtaining Parental Consent, please contact us at firstname.lastname@example.org. We do not condition participation in our Services on disclosure of more Personal Information from a child under thirteen (13) than is reasonably necessary for that participation, and we do not retain Personal Information from children under thirteen (13) longer than is reasonably necessary in order to fulfill the purpose for which it was disclosed.
If you are a parent or guardian of a child under thirteen (13), you have the right to request that we allow you to review, modify or delete your child’s personal information, or that we stop further collection of the child’s personal information. If you wish to exercise those rights, please contact us at email@example.com. We will need to verify your identity before we can comply with your request.
To learn more about COPPA, you may consult this simple one-page informational guide from the kidSAFE Seal Program — www.kidsafeseal.com/knowaboutcoppa.html.
State Law Privacy Rights
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at firstname.lastname@example.org.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support DO Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at email@example.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
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