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Effective date : 01.04.2021

Last updated: 08.04.2021

About this privacy policy

This privacy policy (as amended from time to time, “Privacy Policy”) sets out the basis on which Wildchain Limited (whose registered office is at 160 Robinson Road #24-09 SBF Centre, Singapore 068914, E-mail: pigeons@wildchain.io) and its affiliates (“Wildchain”, “we“, “us” or “our“) may collect, use, disclose and/or process personal data of users of our Wildchain mobile game application (the “Game”) and website (https://wildchain.io) (the “Site“) (we refer to the Game, Site and other services that we provide collectively as our “Services“) in accordance with applicable privacy laws and regulations (“Privacy Laws“). This Privacy Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose and/or process personal data for our purposes.

This Privacy Policy is designed to assist you in making an informed decision before providing us with any of your personal data. This Privacy Policy is also designed to assist our users who are in the European Economic Area (the “EEA”) to understand their applicable data privacy rights that exist under the European General Data Protection Regulation (“GDPR”) when they use our Services. Please refer to the clause ‎13 in this respect.

1. EFFECT OF PRIVACY POLICY AND CONSENT

  • This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
  • We reserve the right to revise this Privacy Policy from time to time without any prior notice, effective upon posting the revised policy on the relevant platform. You may determine if any such revision has taken place by referring to the date on which this policy was last updated. If such revision requires a notification and/or your consent under Privacy Laws, you will be notified and/or offered the opportunity to agree.
  • Where and as permitted by Privacy Laws, by using our Services, registering for an account with us or visiting our Site, you acknowledge and agree that you accept the terms outlined in this Privacy Policy and our Terms of Service, which is incorporated by reference, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR GAME OR SITE. By accessing or using our Services or otherwise communicating with us via telephone, email or otherwise, you acknowledge that you have reviewed and understand the provisions of this Privacy Policy.

2. PERSONAL DATA

  • As used in this Privacy Policy, “personal data” means data about an individual, device, or household who can be identified:
  • directly from that data; or
  • indirectly from that data and other information to which we have or are likely to have access.
  • Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as:
  • e-mail address;
  • age;
  • country;
  • language;
  • gender;
  • information sent by or associated with the device(s) used to access our Services; and
  • any other information about you when you sign up to use our Services, when you use our Services, as well as how you use our Services.
  • If you sign up to be a user of our Services using your social media account (“Social Media Account”), or otherwise link your Social Media Account to our Services, we may access information about you which you have voluntarily provided to your Social Media Account provider in accordance with such provider’s policies. We will manage and use such personal data in accordance with this Privacy Policy and Privacy Laws at all times. If you do not want us to collect such information/personal data, you should not link your Social Media Account to our Services or you may opt out at any time by notifying our Data Protection Officer (“DPO”) in writing. Further information on opting out can be found in clause ‎6

3. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

  • We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (and, where applicable, your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (and, where applicable, your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by applicable Privacy Laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where processing of the applicable data without your consent is permitted or authorised by applicable Privacy Laws).
  • For the avoidance of doubt, in the event that Privacy Laws or other applicable laws permit an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the laws shall continue to apply.
  • We may collect, use and/or process your personal data for any or all of the following purposes:
  • [verifying your identity;
  • performing obligations in the course of or in connection with our provision of Services;
  • responding to, handling, and processing queries, requests, applications, complaints, and feedback from you, or to otherwise communicate with you as part of dealing with or facilitating customer service;
  • notifying you of service issues and unusual account actions;
  • to manage, operate, provide and/or administer your use of and/or access to our Services, as well as managing your relationship and user account with us;
  • processing payment or credit transactions;
  • to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;
  • to protect the rights, property or safety of Wildchain, our Services as well as the ones of our users and others;
  • to prevent, investigate or enforce any actual or suspected violations of our Terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;
  • complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
  • to conduct research, analysis and development activities (i.e., data analytics, surveys, product and service development and/or profiling), to analyse how you use our Services, to improve our Services or products and/or to enhance your customer experience;
  • any other business purposes related to or in connection with our Services, such as sending you marketing information about our Services; and
  • any other purposes which we notify you of at the time of obtaining your consent.
  • We may disclose your personal data:
  • to third parties (i.e., third party services providers, agents), like AWS and Amazon EC2, whether sited in Singapore or outside of Singapore, where such disclosure is required to perform any of the functions listed in clause ‎3 above, or is otherwise required in the course of our provision of Services;
  • In connection with, or during the negotiation of, any investment activity or any merger, financing, acquisition, divestiture, or dissolution of any or all of our investments or all or a portion of our business; and
  • if required to do so by law or pursuant to an order of a court or by any governmental or regulatory authority having jurisdiction over us or in a good faith belief that such access preservation or disclosure is reasonably necessary to respond to any threatened or actual claims asserted against us.
  • Subject to clauses ‎11 and ‎13, the purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
  • As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws.
  • If you are located in the EEA, the relevant information on the legal basis can be found in the clause ‎13

4. INFORMATION ON CHILDREN

  • As a parent or legal guardian, please do not allow such children under your care to submit personal data to Wildchain without your prior consent. In the event that personal data of a child under the age of 13 in your care is disclosed to Wildchain, you hereby consent to the processing of the child’s personal data and accept and agree to be bound by this Privacy Policy on behalf of such child. We will close any accounts used exclusively by such children and will remove and/or delete any personal data we believe was submitted without parental consent by any child under the age of 13.
  • If you are located in the EEA, the relevant information on the processing of data related to children can be found in the clause ‎13

5. COOKIES

  • We may from time to time implement “cookies” or other features to allow us or third parties to collect or share information that will help us improve our Site, Game or Services we offer, or help us offer new services and features. Personal data may be collected through cookies which we may deploy when you interact with our Site, Game or Services. For further information on what cookies are and how we use them, see our Cookie Policy.

6. WITHDRAWING YOUR CONSENT

  • The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is withdrawn by you in writing. In certain jurisdictions, you may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our DPO at the contact details provided in clause ‎1 below.
  • Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within 10 days of receiving it.
  • While we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our Services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing via email to our DPO at the contact details provided in clause ‎1 below.
  • Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable Privacy Laws.
  • If you are located in the EEA, the relevant information on the legal basis can be found in the clause ‎13

7. ACCESS TO AND CORRECTION OF PERSONAL DATA

  • If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our DPO at the contact details provided in clause ‎1 below.
  • Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
  • We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within 30 days after receiving your request, we will inform you in writing within 30 days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under applicable Privacy Laws).
  • If you are located in the EEA, the information on the rights granted to you can be found in the clause ‎13

8. PROTECTION OF PERSONAL DATA

  • To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
  • You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. To the maximum extent allowed by applicable law, you agree and acknowledge that Wildchain will not be liable or responsible if any information about you is intercepted, accessed, and/or used by an unintended recipient. If you have reason to believe that the security of your communications or personal data has been compromised, please notify us immediately using the contact information below.

9. LINKS TO OTHER SITES

9.1  Our Site may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our website and to read the privacy statements of any other linked sites that collect personal data.

10. ACCURACY OF PERSONAL DATA

  • We generally rely on personal data provided by you (or your authorised representative), and you agree not to submit any information to us which is inaccurate or misleading. In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data. We reserve the right at our sole discretion to require further documentation to verify the information provided by you.

11. RETENTION OF PERSONAL DATA

  • We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable Privacy Laws.
  • We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that (a) such retention no longer serves the purpose for which the personal data was collected; (b) is no longer necessary for legal or business purposes; and (c) no other legitimate interest warrants further retention of such personal data.
  • If you are located in the EEA, the relevant information on the applicable retention periods can be found in the clause ‎13

12. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

  • In most cases, your personal data will be processed in Singapore, where our servers are located and our central database is operated. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will transfer your information overseas in accordance with Privacy Laws, including obtain your consent for the transfer to be made and taking steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the Personal Data Protection Act 2012 (PDPA).
  • For more information about the transfer of personal data out of the EEA, please refer to the clause ‎13

13. ADDITIONAL PROVISIONS FOR EEA USERS ONLY

  • The provisions in this clause only apply if you are a user who is located in the EEA. These provisions take precedence over any inconsistent provisions in the remainder of this Privacy Policy.
  • Legal basis. We only use personal data collected through our Site when we have a legal basis to do so and for the purposes outlined above in clause ‎3.

First, we process personal data for the management of our relationship on the basis of our contract in order to:

  • perform obligations in the course of or in connection with our provision of Services;
  • manage, operate, provide and/or administer your use of and/or access to our Services, as well as managing your relationship and user account with us;
  • verifying your identity;
  • process payment or credit transactions;
  • respond to, handle, and process queries, requests, applications, complaints, and feedback from you, or to otherwise communicate with you as part of dealing with or facilitating customer service; and
  • notify you of service issues and unusual account actions.

Besides, we rely on your prior consent in order to:

  • send you marketing information about our Services; and
  • use cookies, as described in our Cookie Policy.

Please note that you have the right to withdraw your consent at any time (without calling into question the processing previously carried out) by sending a request at the contact details specified at the end of this Privacy Policy.

In addition, we process personal data based on our legitimate interests in order to:

  • maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;
  • protect the rights, property or safety of Wildchain, our Services as well as the ones of our users and others;
  • prevent, investigate or enforce any actual or suspected violations of our Terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us; and
  • conduct research, analysis and development activities (i.e., data analytics, surveys, product and service development and/or profiling), to analyse how you use our Services, to improve our Services or products and/or to enhance your customer experience.

Finally, we process personal data to comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority.

  • Your rights. Please note that the GDPR provides for certain rights. In particular, you have the right to:
  • access personal data processed concerning you;
  • correct inaccurate personal data;
  • delete any personal data concerning you;
  • restrict processing;
  • receive your personal data provided to us in an interoperable format (data portability);
  • object to the processing on grounds relating to your particular situation; and
  • lodge a complaint with a competent supervisory authority.
  • Retention of personal data. We will retain your personal data during the period of our contractual relationship, extended by the applicable limitation period. With regard to marketing communications with prospects, we will keep your personal data for [three (3) years] after the last correspondence with us. With respect to the processing carried out in order to protect the rights, property or safety of Wildchain, our Services as well as the ones of our users and others, we will keep your personal data for the time of the relevant limitation period. As to the processing carried out as required by applicable laws, such as tax and accounting laws, we will keep your personal data for the duration of such obligation.
  • Transfers of personal data outside the EEA. As we are located in Singapore, your personal data needs to be transferred to Singapore for the purposes referred to under this Privacy Policy. Besides, we rely on certain service providers which are also located outside the EEA and this may imply that your personal data may be transferred outside of the EEA. In this context, we take appropriate steps to ensure that recipients of your personal data are bound to duties of confidentiality. Where the recipient is located in a country whose legislation has not been recognized by the European Commission as having an adequate level of protection, we implement standard contractual clauses as adopted by the European Commission to ensure that the recipients of such transfer protect and treat your personal data in accordance with all applicable Privacy Laws.
  • Information on Children. Our Services are not intended for children under the age of 16 who are located in the EEA. We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 16 who is located in the EEA, nor is any part of our Site, Game or Services directed to children under the age of 16 who are located in the EEA. We will close any accounts used exclusively by such children and will delete any personal data we believe was submitted by any child under the age of 16 who is located in the EEA.

14. DO NOT TRACK

14.1 “Do Not Track” is a privacy preference that you can set in your internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because our website is not configured to detect “Do Not Track” signals from a user’s computer, we do not respond to “Do Not Track” requests. More information about “Do Not Track” is available at www.allaboutdnt.org concerning such information.

15. CALIFORNIA SHINE THE LIGHT

15.1 California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your personal information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share personal information with third parties for the third parties’ direct marketing purposes.

16. DATA PROTECTION OFFICER

  • You may contact our DPO if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Name: [●]

Address: [●]

Email address: pigeons@wildchain.io

Telephone number: [●]

17. CONTACT

  • If you have any questions regarding our Privacy Policy or need to access the policy in an alternative format due to a disability, please contact us at pigeons@wildchain.io.