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Degenwars Privacy Policy

Last updated: April 16th 2024

This Privacy Policy is part of the Degenwars Terms of Service at https://www.degenwars.gg/terms.

All terms, conditions, and terminology are consistent with the Terms of Service, and the Terms of

Service are incorporated into this document by reference.

This policy governs the use of the Degenwars website at https://www.degenwars.gg and the

associated tools and services.

Collectively, the website and the associated tools and services are referred to as the “Services” in

these terms. The operator may offer other products and services.

In addition to the website and the associated tools and services, the Services include:

● The Degenwars Social Trading Card game

● The Degenwars Competition

● The Degenwars Player

● The Degenwars Analytics

● The Degenwars Home

● The Degenwars Marketplace

● The Degenwars Rewards

● The Degenwars Shop

● The Degenwars Referral Program

The Services do not include outside websites or platforms which may be linked or interconnected

to the Services. Such outside platforms may have their own terms of service, which control for

all transactions on such platforms.

The Services are offered by the site operator and are referred to as “operator,” “we,” or “us” in

these privacy policies.

The Blockchain

Blockchain technology, also known as distributed ledger technology (or simply ‘DLT’), is at the

core of our business. Blockchains are decentralized and made up of digitally recorded data in a

chain of packages called ‘blocks’. The manner in which these blocks are linked is chronological,

meaning that the data is very difficult to alter once recorded. Since the ledger may be distributed

all over the world (across several ‘nodes’ which usually replicate the ledger) this means there is

no single person making decisions or otherwise administering the system (such as an operator of

a cloud computing system), and that there is no centralized place where it is located either.

This means that by design, a blockchain’s records cannot be changed or deleted and is said

to be ‘immutable’. This may affect your ability to exercise your rights such as your right to

erasure (‘right to be forgotten’), or your rights to object or restrict processing, of your personal

data. Data on the blockchain can’t be erased or changed. Although smart contracts may be used

to revoke certain access rights, and some content may be made invisible to others, it is not

deleted.

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In certain circumstances, in order to comply with our contractual obligations to you (such as

delivery of tokens) it will be necessary to write certain personal data, such as your wallet

address, onto the blockchain; this requires you to execute such transactions using your wallet’s

private key.

In most cases ultimate decisions to (i) transact on the blockchain using your wallet address, as

well as (ii) share the public key relating to your wallet address with anyone (including us) rests

with you.

If you want to ensure your privacy rights are not affected in any way, you should not

transact on blockchains as certain rights may not be fully available or exercisable by you or

us due to the technological infrastructure of the blockchain. The blockchain is available to

the public and any personal data shared on the blockchain will become publicly available.

Individuals under the Age of 18

As per our Terms of Service, individuals under the age of 18 are not permitted to use the

Services. As such, we do not knowingly collect, solicit or maintain personal data from anyone

under the age of 18 or knowingly allow such persons to register for the Services.

In the event that we learn that we have collected personal data from an individual under age 18,

we will use commercially reasonable efforts to delete that information from our database. Please

child has provided personal data to the Services, please contact us so that we may remove such

data. Note that we cannot delete information stored on public cryptographic blockchains.

Collecting

We, and our partners, use cookies and similar technologies to give you the best possible content

and experience. Cookies are used to remember you and to collect information about how you

interact with the Services. If you have an account with the Services, we may link this usage data

with other information. You may have the option to either accept or refuse these cookies. If you

choose to refuse, you may not be able to use some portions of the Services.

Device Information

As described below, we collect information from and about the computers, phones, and other

web-connected devices you use that interact with our Services, and we combine this information

across different devices you use.

Information we obtain from these devices includes:

● Device attributes: information such as the operating system, hardware and software

versions, battery level, signal strength, available storage space, browser type, app and file

names and types, and plugins.

● Device operations: information about operations and behaviors performed on the device,

such as whether a window is foregrounded or backgrounded, or mouse movements

(which can help distinguish humans from bots).

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● Identifiers: unique identifiers, device IDs, and other identifiers.

● Data from device settings: information you allow us to receive through device settings

you turn on, such as access to your GPS location, camera or photos.

● Network and connections: information such as the name of your mobile operator or ISP,

language, time zone, mobile phone number, IP address, connection speed and, in some

cases, information about other devices that are nearby or on your network.

● Cookie data: data from cookies stored on your device, including cookie IDs and settings.

● Information necessary to enable push notifications: if you enable push notifications in

our services, we will collect information from your device as may be necessary to enable

such notifications

Information from partners.

● The Services use Google Analytics and other Google services to gather information about

the computers and devices that connect to them. Although Google Analytics plants a

cookie on your web browser to identify you as a unique user the next time you visit this

site, the cookie cannot be used by anyone but Google. Google’s ability to use and share

information collected by Google Analytics about your visits to this site is restricted by

the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent

Google Analytics from recognizing you on return visits to this site by disabling

cookies on your browser.

● See the “Third-Party Data Collection” section for additional information on third-party

collection of data.

When using the Services

When using the Services, we may collect and process personal data. The data will be stored in

different instances. We collect and use this information to provide you the Services and to debug

issues and provide support.

1. On the Blockchain the following data may be stored:

● addresses of externally owned accounts

● transactions made; and

● token balances.

The data will be stored on the Blockchain. Given the technological design of the blockchain,

this data will become public and it will not likely be possible to delete or change the data at

any given time.

2. In our web servers, we will store the following data:

● addresses of externally owned accounts; and

● transactions made.

3. Log Data

● the Internet protocol address (“IP address”); and

● transaction id/ Hash.

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Tracking and Uses

We use the information we have (subject to choices you make) as described below and to provide

and support the Services. Here's how:

Provide, personalize and improve our Services.

We use the information we have to deliver our Services, including to personalize features and

content.

● Information across devices: We connect information about your activities on different

devices to provide a more tailored and consistent experience.

● Location-related information: We use location-related information-such as your current

location, where you live, the places you like to go, and the businesses and people you're

near-to provide, personalize and improve our Services.

● Product research and development: We use the information we have to develop, test

and improve our Services, including by conducting surveys and research, and testing and

troubleshooting new products and features.

● Ads and other sponsored content: We use the information we have about you –

including information about your interests, actions and connections – to select and

personalize ads, offers and other sponsored content that we show you.

Provide measurement, analytics, and other business services.

We use the information we have (including your activity on our Services) to help advertisers and

other partners measure the effectiveness and distribution of their ads and services, and

understand the types of people who use their services and how people interact with their

websites, apps, and services.

The Services use Google Analytics to gather information about their use. Google Analytics

collects information such as how often users visit this site, what pages they visit when they do

so, and what other sites they used prior to coming to this site. The Services use the information

we get from Google Analytics only to improve this site. Google Analytics collects only the IP

address assigned to you on the date you visit this site, rather than your name or other identifying

information.

Promote safety, integrity and security.

We use the information we have to verify accounts and activity, combat harmful conduct, detect

and prevent spam and other bad experiences, maintain the integrity of our Services, and promote

safety and security.

Communicate with you.

We use the information we have to send you marketing communications, communicate with you

about our Services, and let you know about our policies and terms. We also use your information

to respond to you when you contact us.

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Because recognition of the Do Not Track HTTP header feature of your web browser is not

standardized, the Services don’t recognize it for tracking purposes.

Third-Party Data Collection

Third parties may collect or receive certain information about you and/or your use of the

Services to provide content, ads (including personalized ads), or functionality, or to measure and

analyze ad performance, in or through the Services. These third parties include:

● Google (Terms, Privacy Policy)

● Vercel (Terms, Privacy Policy)

● Coinbase (Terms, Privacy Policy)

● Google Analytics (Terms, Privacy Policy)

● Mix Panel (Terms, Privacy Policy)

● AWS (Terms, Privacy Policy)

You may choose whether to receive certain personalized (also known as targeted) advertising

from participating ad networks, audience segment providers, ad serving vendors, other service

providers or entities by visiting websites operated by the Network Advertising

Initiative and Digital Advertising Alliance or if you are a user in the European Economic

Area, Your Online Choices. We adhere to the Self-Regulatory Principles for Online Behavioral

Advertising.

Retention

The Services may keep the information we gather about you for ten years.

To request that information collected about you be deleted, please contact us at the email

provided in this policy. A valid request must include sufficient information to identify your

personal data. Note that we cannot delete information stored on public cryptographic

blockchains.

Sharing

The Services only share information about you with others as follows:

● We employ other companies to perform functions on our behalf, such as service providers

that assist in the administration of the Services and our advertising and marketing efforts,

identity verification services, data analytics companies that help us target our offerings,

marketing partners, and payment providers. We may need to share your information with

these companies. These partners may access this information so long as you have an

account on the Services.

● We may also transfer your personal data to a third party as a result of a business

combination, merger, asset sale, reorganization or similar transaction or to governmental

authorities when we reasonably believe it is required by law or appropriate to respond to

legal process.

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● We will also share your information with third-party companies, organizations or

individuals if we have a good faith belief that access, use, preservation or disclosure of

your information is reasonably necessary to detect or protect against fraud or security

issues, enforce our terms of use, meet any enforceable government request, defend

against legal claims or protect against harm our legal rights or safety. In any such event,

and to the extent legally permitted, we will notify you and, if there are material changes

in relation to the processing of your data, give you an opportunity to consent to such

changes. Any third party with whom we share your data with will be required to provide

the same or equal protection of such data as stated in our Privacy Policy.

● To operate the Services, we share information about you as needed with our service

providers, including financial institutions, accountants, auditors, lawyers, payment

processors, information technology consultants, advisors, and our affiliates. We only

share information to the extent it is required to fulfill our obligations to you and to

regulators, and to operate the Services. The information is only shared so long as you are

have an account on the Services.

● We routinely share information with companies closely related to us – our “affiliates” –

for certain purposes under this policy. Our affiliates will be entitled to enjoy our rights

under this Privacy Policy and we will be responsible for our affiliates’ conduct related

thereto.

● We may share information about you with US, state or international regulators, SEC, or

FINRA where we believe doing so is required or appropriate to comply with any laws,

regulations or other legal processes or law enforcement requests, such as court orders,

search warrants, or subpoenas.

● The Services may contain links to third party websites and may redirect you to third party

websites. These sites include, among others, service providers who have a relationship

with the operator. Third party websites are not under our control, and we are not

responsible for any third party websites, or the accuracy, sufficiency, correctness,

reliability, veracity, completeness, or timeliness of their information, links, changes or

updates. The inclusion or access to these websites does not imply an endorsement by the

operator, or of the provider of such content or services, or of any third party website.

Please be aware that when you enter a third party website, any information you provide,

including financial information, is subject to the terms of use and privacy policy of that

website.

● Google (Terms, Privacy Policy)

● Vercel (Terms, Privacy Policy)

● Google Analytics (Terms, Privacy Policy)

● Mix Panel (Terms, Privacy Policy)

● AWS (Terms, Privacy Policy)

● Privy (Terms, Privacy Policy)

● Hasura (Terms, Privacy Policy)

● Retool (Terms, Privacy Policy)

Opt–Out

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If you wish to stop receiving marketing or promotional communications or to opt out of use of

your information for the purposes described in this policy, please follow the opt-out instructions,

such as clicking “Unsubscribe” (or similar opt-out language), in those communications. You can

also contact us at [email protected] to opt out. Despite your indicated email preferences, we

may send you service-related communications, including notices of any updates to our terms of

service or this policy. Please understand that you will not be allowed to opt–out of certain

communications required to comply with applicable laws, rules and regulations or other legal

and related notices concerning your relationship to the Services.

Security

We have put in place appropriate security measures to prevent your personal data from being

accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we

limit access to your personal data to those employees, agents, contractors and other third parties

who have a business need to know. They will only process your personal data on our instructions

and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify

you and any applicable regulator of a breach where we are legally required to do so.

Contact

If you have comments or questions about the privacy policies of the Services, contact

legal@degenwars.gg.

Changes

The Services may change their privacy policy at any time. Check this page for the latest.

CCPA Addendum – Compliance

You agree to do your respective parts to comply with the California Consumer Privacy Act and

its regulations, consistent with the operator’s role as a “service provider”, and not as a “third

party”, under that law.

Cooperation

Whenever it is feasible and legal to do so, both the operator and You will give the other prompt

notice of user rights requests, regulatory inquiries, and other communications under the

California Consumer Privacy Act. Both sides agree to cooperate in good faith to respond to and

honor such communications, and to meet other obligations under the California Consumer

Privacy Act.

Prohibitions

The operator may not:

● sell personal information collected from consumers covered by the California Consumer

Privacy Act that You disclose to the operator

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● retain, use, or disclose such information for any purpose other than for the specific

purpose of performing the services in the Terms of Service, including retaining, using, or

disclosing such information for a commercial purpose other than providing the services

● retain, use, or disclose such information outside of a direct business relationship between

the operator and You

Certification

The operator understands the restrictions in Prohibitions and will comply with them.

Minimization

Both You and the operator agree to limit use of personal information covered by the California

Consumer Privacy Act to that reasonably necessary and proportionate to achieve the purpose of

the Terms of Service, consistent with the meaning of “business purpose” under that law.

Subcontracting

The operator agrees to ensure that each subcontractor that processes Your information covered

by the California Consumer Privacy Act will also qualify as a “service provider”, and not as a

“third party”, under that law.

Personal Information

Of the following categories of personal information:

● identifiers (such as contact information, government IDs, cookies, etc.),

● information protected against security breaches (such as your name and financial account,

driver’s license, social security number, user name and password, health/medical

information),

● protected classification information (like race, gender, ethnicity, etc.),

● other information, including commercial information, Internet/electronic activity,

geolocation, audio/video data, professional or employment related information, education

information, biometrics, and inferences from the foregoing;

The operator may have collected and used for a business purpose such data within the last 12

months. The operator has not sold or disclosed any such data within the last 12 months, as of the

date of this agreement.

Previously Submitted Information

To request access or changes to information previously submitted, please contact the operator at

the address provided above (under the “Contact” heading).

Conflicts

If the terms of this addendum conflict with terms of the Terms of Service or Privacy Policy, the

terms of this addendum take precedence.

GDPR / EU Addendum

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Transferring Your data outside of the EU

The data mentioned in this document will be stored in the United States. We use Amazon Web

Server, which is based in the US. Amazon is certified under the EU-US Privacy Shield. Fabric.io

and Firebase are part of the Google LLC., which is based in the US. Google is certified under the

EU-US Privacy Shield.

But, when interacting with the blockchain, as explained above in this Policy, the blockchain

is a global decentralized public network and accordingly any personal data written onto

the blockchain may be transferred and stored across the globe.

Your Rights as a Data Subject

You have certain rights under applicable legislation, and in particular under Regulation

EU 2016/679 (General Data Protection Regulation or ‘GDPR’). We explain these below. You can

find out more about the GDPR and your rights by accessing the European Commission’s

website.

Right Information and access

You have a right to be informed about the processing of your personal data (and if you did not

give it to us, information as to the source). This document provides that information, and you

may contact us for additional information.

Right to rectification

You have the right to have any inaccurate personal information about you rectified and to have

any incomplete personal information about you completed. You may also request that we restrict

the processing of that information. The accuracy of your information is important to us. If you do

not want us to use your Personal Information in the manner set out in this Privacy Policy, or need

to advise us of any changes to your personal information, or would like any more information

about the way in which we collect and use your Personal Information, please contact us at the

above details.

Right to erasure (right to be ‘forgotten’)

You have the general right to request the erasure of your personal information in the following

circumstances:

o the personal information is no longer necessary for the purpose for which it was

collected;

o you withdraw your consent to consent based processing and no other legal justification

for processing applies;

o you object to processing for direct marketing purposes;

o we unlawfully processed your personal information; and

o erasure is required to comply with a legal obligation that applies to us.

But, when interacting with the blockchain we may not be able to ensure that your personal

data is deleted. This is because the blockchain is a public decentralized network and

blockchain technology does not generally allow for data to be deleted and your right to

erasure may not be able to be fully enforced. In these circumstances we will only be able to

ensure that all personal data that is held by us is permanently deleted.

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We will proceed to comply with an erasure request without delay unless continued retention is

necessary for:

o Exercising the right of freedom of expression and information;

o Complying with a legal obligation under EU or other applicable law;

o The performance of a task carried out in the public interest;

o Archiving purposes in the public interest, scientific or historical research purposes, or

statistical purposes, under certain circumstances; and/or

o The establishment, exercise, or defense of legal claims.

Right to restrict processing and right to object to processing

You have a right to restrict processing of your personal information, such as where:

o you contest the accuracy of the personal information;

o where processing is unlawful you may request, instead of requesting erasure, that we

restrict the use of the unlawfully processed personal information;

o we no longer need to process your personal information but need to retain your

information for the establishment, exercise, or defense of legal claims.

You also have the right to object to processing of your personal information under certain

circumstances, such as where the processing is based on your consent and you withdraw that

consent. This may impact the services we can provide and we will explain this to you if you

decide to exercise this right.

But, when interacting with the blockchain, as it is a public decentralized network, we will

likely not be able to prevent external parties from processing any personal data which has

been written onto the blockchain. In these circumstances we will use our reasonable

endeavors to ensure that all processing of personal data held by us is restricted,

notwithstanding this, your right to restrict to processing may not be able to be fully

enforced.

Contact

The identity and contact details of the organization, its representative, and its Data Protection

Officer are as follows: [email protected].

Right to data portability

Where the legal basis for our processing is your consent or the processing is necessary for the

performance of a contract to which you are party or in order to take steps at your request prior to

entering into a contract, you have a right to receive the personal information you provided to us

in a structured, commonly used and machine-readable format, or ask us to send it to another

person.

Right to freedom from automated decision-making

We do not use automated decision-making, but where any automated decision-making takes

place, you have the right in this case to express your point of view and to contest the decision, as

well as request that decisions based on automated processing concerning you or significantly

affecting you and based on your personal data are made by natural persons, not only by

computers.

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Right to object to direct marketing (‘opting out’)

You have a choice about whether or not you wish to receive information from us. We will not

contact you for marketing purposes unless:

o you have a business relationship with us, and we rely on our legitimate interests as the

lawful basis for processing (as described above)

o you have otherwise given your prior consent (such as when you download one of our

guides)

You can change your marketing preferences at any time by contacting us on the above details.

On each and every marketing communication, we will always provide the option for you to

exercise your right to object to the processing of your personal data for marketing purposes

(known as ‘opting-out’) by clicking on the ‘unsubscribe’ button on our marketing emails or

choosing a similar opt-out option on any forms we use to collect your data. You may also opt-out

at any time by contacting us on the below details.

Please note that any administrative or service-related communications (to offer our services, or

notify you of an update to this Privacy Policy or applicable terms of business, etc.) will solely be

directed at our clients or business partners, and such communications generally do not offer an

option to unsubscribe as they are necessary to provide the services requested. Therefore, please

be aware that your ability to opt-out from receiving marketing and promotional materials does

not change our right to contact you regarding your use of our Services or as part of a contractual

relationship we may have with you.

Right to request access

You also have a right to access information we hold about you. We are happy to provide you

with details of your Personal Information that we hold or process. To protect your personal

information, we follow set storage and disclosure procedures, which mean that we will require

proof of identity from you prior to disclosing such information. You can exercise this right at any

time by contacting us on the above details.

Right to withdraw consent

Where the legal basis for processing your personal information is your consent, you have the

right to withdraw that consent at any time by contacting us on the above details.

Raising a complaint about how we have handled your personal data

If you wish to raise a complaint on how we have handled your personal data, you can contact us

as set out above and we will then investigate the matter.

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that we have not addressed your concern in

a satisfactory manner, you may contact the Information Commissioner’s Office in your

jurisdiction.