The SolaVerse Privacy Notice

Modified on: April 1st, 2022.

1. Summary of how we use your data

   1. The SolaVerse (also referred to as "SolaVerse", "we" or "us") uses your personal data to allow you to access the SolaVerse game, the SolaVerse marketplace and our website, altogether the “SolaVerse Platform”.
   2. We manage our token system $SOLA (“SOLA”) which you can earn through the SolaVerse Platform and which allows you to make purchases or exchanges in our marketplace. We do not manage the wallet with which you sign up to our SolaVerse Platform.
   3. If you access the SolaVerse Platform, SolaVerse will in particular use your data to manage the operation of the marketplace, to promote and retain records of the game, ensure that in-game and out-of-game discipline is maintained in accordance with the Platform T&Cs and that the integrity of the SolaVerse Platform are upheld. SolaVerse will also use your data to verify and carry out any transactions that you enter into in the marketplace.
   4. Where we rely on your consent, such as for direct marketing, you can withdraw this consent at any time.
   5. Our privacy policy sets out more details of this processing, including details of your data protection rights, including your right to object to certain processing.

2. What does this policy cover?

   1. SolaVerse allows you to access and take part in the SolaVerse Platform. This policy describes how SolaVerse will make use of your data in doing so, and it also describes your data protection rights, including a right to object to some of the processing which SolaVerse carries out. More information about your rights, and how to exercise them, is set out in the "What rights do I have?" section.

3. What information do we collect?

   1. We collect and process personal data about you when you interact with us by using the SolaVerse Platform, such as when you sign up for an account on our website, when you purchase goods and services on the marketplace, and when you play our game. This personal data will typically be provided directly by you. Most of the details being provided by you will be made clear in forms you complete or will be provided directly by you in volunteering information in communications or content you provide us. SolaVerse also collects information as part of its analytics, administration and management of the SolaVerse Platform and as part of its collection of data for promotional use.
   2. We will collect the following categories of data:
      1. When you sign up for an account or contact us we will collect your first and last name and email address. We collect this data directly from you.
      2. In-game statistics: We may collect certain in-game statistics for game development and improvement purposes and to track SOLA tokens earned by you based on game time.
      3. Technical data: The technical data will include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your SolaVerse Platform use. We collect this data through our analytics providers - namely, Google and Bing.

4. What information do we receive from third parties?

   1. We may generate or collect information about you ourselves. Much of this is set out in our Cookies Policy below.
   2. Sometimes, we receive information about you from third parties such as social media sites. For example, if you use a "like" or a "share" button for a feature on our sites or apps, then the third party site you share this on will share information with us. We may also obtain information about you from third party analytics providers (as mentioned above), which we may use to help us better understand our users and send them appropriate offers and information.

5. How do we use this information, and what is the legal basis for this use?

   
   We process this personal data for the following purposes:

   1. To fulfil a contract, or take steps linked to a contract: this is relevant where you play our game or undertake a transaction on the marketplace. This includes:
      1. taking payments when you purchase $SOLA tokens;
      2. verifying payments made in the marketplace using $SOLA tokens;
      3. communicating with you; and
      4. providing customer services and arranging the provision of products and services;
   2. As required by SolaVerse to conduct our business and pursue our legitimate interests, in particular:
      1. we will use your information to provide products and services you have requested, and respond to any comments or complaints you may send us;
      2. we monitor use of the SolaVerse Platform, and use your information to help us monitor, improve and protect our products, content, services and websites, both online and offline;
      3. we use information you provide to personalise the SolaVerse Platform for you;
      4. we monitor customer accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
      5. we use information you provide to investigate any complaints received from you or from others, about our website or our products or services;
      6. we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation);
      7. we administer and manage our game by carrying out SolaVerse's disciplinary role in enforcing the terms of the Platform T&Cs, including sharing information with relevant third parties as necessary and described below; and
      8. we use information such as photographs and gameplay footage collected in our game, in order to promote our game, our marketplace and our other related products and services.
   3. Where you give us consent:
      1. we will send you direct marketing in relation to the SolaVerse Platform;
      2. we place cookies and use similar technologies in accordance with our Cookies Policy and the information provided to you when those technologies are used;
      3. on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time; and
   4. For purposes which are required by law:
      1. in response to requests by government or law enforcement authorities conducting an investigation; and
      2. maintaining records as required by law.

6. Relying on our legitimate interests

   1. We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on our balancing tests by contacting us using the details set out later in this notice.

7. Withdrawing consent or otherwise objecting to direct marketing

   1. Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.

8. Apple iOS, Android and other mobile, gaming or smart devices

   1. By accessing the SolaVerse Platform from these devices you consent to cookies being stored to your device (and other tracking technologies being used to read data from your device) for the following purposes: keeping you logged in, ensuring that an appropriate version of content is presented, analytics and advertising. Although the use of some of these cookies are optional, many of these cookies and technologies are essential to the operation of the application. It is not currently possible to opt out or remove these essential cookies (or prevent use of these technologies) from the device without deleting the application.
   2. For more information on cookies please see our full Cookies Policy below.

9. How is data shared, where and when?

   1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our holding company and its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
   2. Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
   3. Personal data will also be shared with third party service providers, who will process it on behalf of SolaVerse for the purposes identified above. In particular, we use third party providers for website design and hosting and maintenance, data storage, IT management and, developing our game engine and payment processing services. We also use third party analytical tools such as Google and Bing, which process your data to help us get better insights into our users and allow us to improve our services and promotions.
   4. In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser's adviser and will be passed to the new owners of the business.
   5. If you are participating in the game or marketplace, data may be shared with a number of third parties. Data, whether about your registration or your conduct, might need to be shared with other participants. For example, your username will be displayed on leader boards if you are a top player in the game. We will also publish certain information (including photographs and footage) and may share it with the media, and on results and records of the game, whether as statistics, press releases or promotional content.

10. When is data transferred internationally?

    1. Where information is transferred outside the EEA or UK, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission or the by the UK government, data is adequately protected by EU Commission or UK Information Commissioner approved standard contractual clauses or a vendor's Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request using the contact details set out below.

11. What rights do I have?

    1. You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
    2. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don't have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
    3. These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. If you ask to withdraw your consent us processing your data, this will not affect any processing which has already taken place at that time. Relevant exemptions are included in both the GDPR/UK GDPR and in certain local laws. We will inform you of relevant exemptions we rely upon when responding to any request you make.
    4. To exercise any of these rights, you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to a competent authority. This may be a data protection authority where you live, work or where you believe a breach may have occurred. We will always inform you where information you provide is mandatory.

12. How do I get in touch with you?

    1. We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at [email protected].

13. How long will you retain my data?

    1. Where we process data relating to your use of the marketplace, we retain this for 5 years.
    2. Where we process data for the purposes of providing the game, we retain this for 5 years.
    3. Where we process any technical data from your use of the SolaVerse Platform, we retain this for 5 years.
    4. Where we process data resulting from any communications you have had with us, we retain this for 7 years.
    5. Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.

14. Cookies Policy

    1. In common with many other website operators, we may use standard technology called 'cookies' on the SolaVerse Platform. Cookies are small pieces of information that are stored by your browser on your computer's hard drive and they are used to record how you navigate our website or use our services on each visit.
    2. Our cookies are used to enable us to develop the SolaVerse Platform and to enable you to properly navigate them. We use cookies to collect personal information to enable us to reflect our customers' interests and by noting who has seen which pages, properties and advertisements (including click through from emails), how frequently particular pages are visited and to enable us to determine the most popular areas of our website.
    3. We may use cookies to enrich your experience of using the SolaVerse Platform by allowing us to tailor what you see to what we have learned about your preferences during your visits to them. Sometimes we may use services of third parties and they may use cookies on our behalf in order to provide their services.
    4. The particular cookies we use on this website are as follows:
       1. Functionality cookie (persistent cookie)

          Functionality cookies are activated by the user at sign in and remember choices you make such as the country you visit the SolaVerse Platform from, language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. We set functional session cookies in order to remember users during their visit which are vital for user experience, especially when logged in and performing specific actions.

       2. Strictly necessary cookie (session cookie)

          Strictly necessary cookies are essential in order to enable you to move around the SolaVerse Platform and use its features. Without these cookies, services you have asked for such as remembering your login details cannot be provided. We set an XSRF-TOKEN cookie to help prevent cross-site request forgery. Amazon Web Services also set strictly necessary cookies such as AWSALB and AWSALBCORS used for load balancing.

       3. Analytics cookie (persistent cookie)

          Analytics cookies collect information on how people use the SolaVerse Platform. Such cookies help us understand how often customers use the SolaVerse Platform, and highlight areas where can improve areas such as navigation. We use targeted advertising cookies from Google Analytics.

       4. Targeting or advertising (persistent cookie)

          Targeting or advertising cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers. We use targeted advertising cookies from the following 3rd party platforms: TikTok, YouTube, Twitter and Google Analytics.

       5. Social media (persistent cookie)

          Social media cookies allow you to share what you've been doing on the SolaVerse Platform on social media, we use targeted advertising cookies from the following 3rd party platforms: TikTok, YouTube, Twitter. These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work.

       6. Third party (persistent cookie)

          Third party cookies (including Flash cookies) from our sponsors and advertisers may be stored on your device if you click on their links or adverts. You should review their privacy and security policies to understand how they use cookies. We use targeted advertising cookies from the following 3rd party platforms: TikTok, YouTube, Twitter and Google Analytics. These cookies are to help those platforms deliver you more relevant ads when you browse them.

    Preventing use of cookies

    5. Most browsers automatically accept cookies, but you can usually change your browser to prevent them being stored. With experience, you can usually choose to switch off all cookies or to allow only certain 'trusted' sites to place cookies. You can find out more about cookies and what cookies have been set on your device at www.allaboutcookies.org.
    6. PLEASE NOTE, IF YOU DO TURN COOKIES OFF, THIS WILL LIMIT THE SERVICE THAT WE ARE ABLE TO PROVIDE TO YOU AND MAY AFFECT YOUR USER EXPERIENCE.

    Web beacons

    7. Some of our website pages may contain electronic images known as web beacons (sometimes known as clear gifs) that allow us to count users who have visited these pages. Web beacons collect only limited information which include a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any personally identifiable information and are only used to track the effectiveness of a particular campaign.