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KINGUIN NFT Marketplace PRIVACY POLICY


This privacy policy (“Privacy Policy”) sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, when preparing to provide or providing, our NFT Marketplace that allows buyers and sellers to trade digital assets. We respect your privacy and we are committed to protecting your personal data. This Privacy Policy will inform you as to how Kinguin Digital Limited (“we/us”) look after your personal data when using any of our services or applications (together the “Services”) or when visiting or using our websites, https://www.kinguin.net/nft/collections (“Sites”).

In providing you with the Services, we naturally collect information about you. This Privacy Policy sets out what we collect, how we use, how we store that information, who we might share it with, and the steps we take to make sure it stays private and secure.

We are committed to safeguard the privacy of individuals with respect to your personal data. We assure that our policies and practices, and those adopted by our affiliated companies and agents in relation to the collection, use, retention, disclosure, transfer, security and access of your personal data comply with the requirements under the Personal Data (Privacy) Ordinance (Chapter 486) (the “Ordinance”) under the laws of Hong Kong, as well as the relevant code of practice and guidance issued by the Office of the Privacy Commissioner for Personal Data, Hong Kong. The meaning of the term "personal data" adopted in this Statement is defined in the Ordinance. In addition to the Ordinance od other Hong Kong laws, individuals located in the European Union (EU) may also have rights under the General Data Protection Regulation 2016/679 (GDPR).

This Privacy policy constitutes an integral part of the NFT Marketplace Terms & Conditions (hereinafter referred to as the “T&C”), available on our website (as amended from time to time).

Please read the following information carefully as this Privacy Policy aims to give you information on how we collect and process your personal data when you visit our Site, or through your use of the Services and any data you may provide when you register for or use the Services, sign up for alerts or newsletters, contact us with a question or request for help, participate in any renewals, promotions or surveys.

If you agree with this privacy policy, you must click on the respective button suggested to you.


Collection, processing and use of your information

HOW WE COLLECT PERSONAL INFORMATION

We collect personal information in a variety of ways, including:
  • Directly: We collect personal information which you directly provide to us, including when you register on the NFT Marketplace, through the ‘contact us’ form on our websites or when you request our assistance via email, our online chat or over the telephone.
  • Indirectly: We may collect personal information which you indirectly provide to us while interacting with us such as when you use any of our Sites, in emails, over the telephone and in your online enquiries.
  • From Third Parties: We collect personal information from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.
We can collect, use or disclose your personal information without your consent for legal, security or certain processing reasons as required by law to deter fraud and money-laundering, or for other legal purposes.


PERSONAL INFORMATION

The types of personal information we may collect about you include:
  • your name;
  • your contact details, including email address and name;
  • your Ethereum (and/or other public blockchain) address and wallet;
  • your credit card or payment details (through our third party payment processor);
  • your preferences and/or opinions;
  • information you provide to us through customer surveys;
  • details of products and services we have provided to you and/or that you have enquired about, and our response to you, including any support requests and any bug reports;
  • your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behavior;
  • information about your access and use of our Services, including through the use of Internet cookies, your communications with our Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
  • additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
  • any other personal information requested by us and/or provided by you or a third party. We may collect these types of personal information directly from you or from third parties

COLLECTION AND USE OF PERSONAL INFORMATION
 
We may collect, hold, use and disclose personal information for the following purposes:
  • to enable you to access and use our Services, Sites, associated applications and associated social media platforms;
  • to enable you to perform transactions on the Services;
  • to contact and communicate with you about our Services;
  • for internal record keeping, administrative purposes, invoicing and billing purposes;
  • for analytics, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms;
  • to run promotions, competitions and/or offer additional benefits to you;
  • for advertising and marketing, including to send you promotional information about our group’s products and services and information about third parties that we consider may be of interest to you;
  • to comply with our legal obligations and resolve any disputes that we may have;
  • if you have applied for employment with us, to consider your employment application; and
  • if otherwise required or authorised by law.

DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
 
We may disclose personal information to:
  • third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing providers, professional advisors and payment systems operators;
  • our employees, contractors and/or related entities;
  • our existing or potential agents or business partners;
  • sponsors or promoters of any competition we run;
  • anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
  • credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
  • courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
  • third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of Hong Kong; and
  • third parties to collect and process data, such as Google Analytics or other relevant businesses. This may include parties that store data outside of Hong Kong; and
  • any other third parties as required or permitted by law, such as where we receive a subpoena.
Overseas disclosure: Where we disclose your personal information to third parties listed above, these third parties may store, transfer or access personal information outside of Hong Kong, including but not limited to, United States of America.

We will only disclose your personal information to countries with laws which protect your personal information in a way which is substantially similar to the Hong Kong privacy principles or we will take such steps as are reasonable in the circumstances to protect your personal information in accordance with the Ordinance and other Hong Kong laws.
 

COOKIES
 
We may use cookies on our online Services from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online Services and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online Services with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our online Services.

We may use web beacons on our Site from time to time. Web beacons (also known as ClearGIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

We may use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time.
 

HOW WE KEEP YOUR INFORMATION SAFE

We protect your information using security standards such as firewalls and data encryption, physical access controls to our premises and information access authorization controls. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. We also authorize access to your information only for those employees or contractors who require it to fulfill their job or service responsibilities.

However, no security system is impenetrable and we cannot guarantee the security of our systems. In the event that any information under our custody and control is compromised as a result of a breach of security, we will take steps to investigate and remediate the situation and, in accordance with applicable laws and regulations, notify those individuals whose information may have been compromised.

You are responsible for the security of your digital wallet, and we urge you to take steps to ensure it is and remains secure. If you discover an issue related to your wallet, please contact your wallet provider.

Please note that transmission of data or information (including communications by e-mail) over the internet or other publicly accessible networks is not one hundred percent secure. Please note that we are not liable for the security of any data you are transmitting over the internet.


YOUR RIGHTS

You may access, review, edit, correct, remove and delete your personal data at any time by contacting our support team. You may be requested by our team to provide the respective confirmation documents in case of your personal data information change. Where required by law, we will facilitate your exercise of your rights.

Under the Ordinance, you have the right to:
  1. Check whether we hold any of your personal data;
  2. Access your personal data held by us;
  3. Request us to correct any inaccurate personal data held by us; and
  4. Ascertain our policies and practices established (from time to time) in relation to personal data and the types of personal data held by us.
If you want to access and/or correct your personal data which you have given us via Customer Service.

European users have the right under applicable privacy laws to:

Objecting to processing: You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights and freedoms, in order to proceed with the processing of your personal information.

Restricting processing: You have the right to request that we restrict the processing of your personal information, if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.

Access, erasure and data portability: You may have the right to request details of the personal information we hold about you, or to request that we erase the personal information we hold about you, or that we transfer this information to a third party.

Rectification: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, incomplete, misleading or out of date.

Notwithstanding the above, we cannot edit or delete any information that is stored on a blockchain, for example the Ethereum blockchain, as we do not have custody or control over any blockchains. The information stored on the blockchain may include purchases, sales, and transfers related to your blockchain address and NFTs held at that address.
 

THIRD-PARTY WEBSITES.

Our Service may contain links to third-party websites. When you click on a link to any other website or location, you will leave our Service and go to another site, and another entity may collect Personal Data from you. We have no control over, do not review, and cannot be responsible for these third-party websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these third-party websites or their content, or to any collection of your Personal Data after you click on links to such third-party websites. We encourage you to read the privacy policies of every website you visit. Any links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.
 

THIRD-PARTY WALLETS.

To use our Service, you must use a third-party wallet which allows you to engage in transactions on public blockchains. Your interactions with any third-party wallet provider are governed by the applicable terms of service and privacy policy of that third party.
 

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

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means and the applicable legal requirements. In some circumstances you can ask us to delete your data: see ‘access, erasure and data portability’ below for further information.

In some circumstances we may anonymise your personal information (so that it can no longer be associated with you) for analytics, research or statistical purposes in which case we may use this anonymised information indefinitely without further notice to you.
 

MINORS.

We do not intentionally gather Personal Data from visitors who are under the age of 13. Our Terms and Conditions require all users to be at least 18 years old. Minors who are at least 13 years old but are under 18 years old may use a parent or guardian’s NFT Marketplace account, but only with the involvement of the account holder. If a child under 13 submits Personal Data to Us and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible.
 

AMENDMENTS
 
We may, at any time and at our discretion, vary this Privacy Policy. We will notify you if we amend this Privacy Policy, by contacting you through our game or the contact details you have provided to us. Any amended Privacy Policy is effective once we notify you of the change.