Privacy Policy
1. PREAMBLE AND REMINDER Thank you for your interest in Clubeeo. This Privacy Policy processing and use of your Personal Data when you use Company website (“Site”) and our other associated Services. Any natural person or entity that logs into the Site or other associated Services, shall be a user thereof and are hereinafter referred to as "you" or any other applicable forms of the second-person pronouns. We fully understand and respect the importance of your Personal Information to you, and We will adopt corresponding appropriate safety protection measures to protect your Personal Information in accordance with the requirements of the applicable laws and regulations. In view of this, this Privacy Policy (hereinafter referred to as "this Policy/this Privacy Policy") is formulated and the following reminder is provided to you: This Policy applies to the information we collect on the Site and in email, text and other electronic communications between you and this Site. In particular, this Policy does not apply to services provided to you by any third party, and such services shall be subject to a privacy policy that is otherwise specified to you. Before using our Service, please read carefully and thoroughly understand this Policy, make sure that you fully understand and agree to it before you start using our products or services. If you do not agree with any term or condition in this Policy, You should promptly stop accessing this Service. 2. DEFINITIONS 1) Personal Information: various kinds of information recorded electronically or otherwise, which, alone or in combination with any other information, can identify the identity of a specific natural person or reflect the activities of a specific natural person. 2) Deletion of Personal Information: the act of removing personal information from the systems involved in daily business functions to keep it in a state that cannot be retrieved or accessed. 3) Services, Site: Clubeeo website, and other associated services 3. ACCEPTANCE OF THIS PRIVACY POLICY By accessing or using this Site or Company Services, you signify acceptance to the terms of this Privacy Policy. 4. THE PERSONAL INFORMATION WE COLLECT Personal Information is typically data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties. Information you provide to us To establish an account and access our Services, we'll ask you to provide us with some important information about yourself. This information is either required by law (e.g. to verify your identity), necessary to provide the requested services, or is relevant for certain specified purposes, described in greater detail below. As we add new features and Services, you may be asked to provide additional information. Your crypto wallet account number connected as your identifier within our services; Transaction data authorized by you designated for broadcasting by the means of our services, voting history; Information about your DAO you chose to publish at its page on the Site; Information you provide by sending us an email, contacting us with a messenger or otherwise voluntarily providing us with your Personal Data. Such information may include your name, date of birth, address, email address, telephone number, identifying documents, geographic location, personal description, photograph, bank details and other information obtained from your communications. Information we collect from you automatically To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information helps us address customer support issues, improve the performance of our Sites and Services, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes: technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone settings, browser plug-in types and versions, operating system and platform; information about your visit, including the full Uniform Resource Locators (URL) that take you to our website, through our website, and from our website (including date and time); the products you viewed or searched for; page response times, loading errors, duration of visits to certain pages, page interaction information (such as scrolling, clicking, and mouse switching), as well as the methods used to navigate away from the page, and any telephone number used to call our customer service. We may also use identifiers to recognize you when you access our Sites via an external link, such as a link appearing on a third party site. Information we collect from our affiliates and third parties From time to time, we may obtain information about you from our affiliates or third party sources as required or permitted by applicable law. We may analyze public blockchain data to ensure parties utilizing our Services are not engaged in illegal or prohibited activity under our Terms, and to analyze transaction trends for research and development purposes. We may also receive information that you provide to third parties when using the Clubeeo Service (i.e., an online payment service or an organization that provides user verification). 5. THE REASONS OF USING YOUR PERSONAL DATA We are going to use your Personal Information for the following purposes: Provision of our Services - to fulfill the obligations under contracts signed with you, as well as to provide you with the information, products and Services that you requested; - to ensure the security of our Services and your Account; - for administration of our Site and for internal operations, including troubleshooting, data analysis, testing, statistical data collection and for conducting surveys; - to support, respond and resolve your complaints and issues related to the use of our Services and the capabilities of our Site; - to provide relevant marketing, as well as to communicate with you by providing you with information about our events, seminars, or services, including client conferences or networking events, that may be interesting to you. This processing is necessary for our legitimate interest to send you tailored marketing messages, client newsletters, and invitations. Compliance with statutory requirements for user identification Understanding user needs and optimizing the service Safeguarding vested interests - for security and control of our IT systems, crime prevention; - for measuring the use of our Services and products for its further development; - for internal business and research purposes, i.e. interaction with users on other services regarding our products and Services; - for anonymized data analysis via web beacons and pixel tags to ensure our products and Services are relevant for the market we operate on. 6. LEGAL GROUNDS FOR THE PROCESSING OF YOUR PERSONAL DATA We may process your personal data on several legal grounds, depending on the specific purpose for which we use your data: Execution of the contract In the event that the processing of your personal data is necessary to fulfill the obligations under contracts signed with you, as well as to provide you with the information, products and Services that you requested. Legal obligation or public interest In the event that we need to process your personal data in accordance with legal obligations. The purposes of processing include the control of identity verification, the prevention of money laundering and fraud, risk control measures, and the provision of information to a competent authority, public authority or law enforcement agency. Legitimate interests Where necessary, we may process your personal data where we or a third party have a legitimate interest in pursuing commercial and business interests, unless such interests are overridden by your interests, fundamental rights and freedoms. Your consent In certain circumstances, we may, based on your contact details, ask you for specific permission to process personal information for specific purposes. Your data will be processed in this way if you consent to it. If the legal basis is the consent you have given, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of the data processed prior to the withdrawal. 7. DISCLOSURE OF YOUR PERSONAL INFORMATION Subject to the Policy, we do not sell, rent or share any of your personal information, including your email address, to third parties for marketing purposes without your express consent. However, your personal data may be disclosed as part of normal business processes to provide our services and products to customers. We may disclose your Personal Information to third parties in the following cases: 1) if we sell or buy any business or assets; Personal Information of users may be disclosed to a potential buyer or seller; 2) if we are required to disclose or transfer Personal Information of the user in accordance with any applicable laws or within the implementation of decisions of the relevant courts, requests of judicial and law enforcement authorities or we are compelled to force users to comply with the terms and conditions of the agreements signed with us; 3) in case it is necessary to protect our rights, property or to guarantee the safety of the Company, our users or others; this includes the exchange of information with relevant organizations to prevent fraud and reduce the likelihood of default. We may also disclose aggregated information about our users and information that does not identify any individual without limitation. We cannot guarantee that all of your private messages and other Personal Information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting the foregoing), we may be forced to disclose Personal Information, including your email address, to the government or third parties, under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or users may misuse or misuse your Personal Information that they collect from the Company. Therefore, while we use industry standard practices to protect your privacy, we do not promise, and you should not rely on or expect, that your Personal Information or private communications will always remain private. 8. SECURITY AND STORAGE OF PERSONAL INFORMATION We have implemented security measures to ensure the confidentiality of your Personal Information and to protect it from loss, misuse, alteration or destruction. We may transfer personal information outside Europe. In those cases we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information. Whilst the transmission of information via the internet is not completely secure, we will endeavor to protect your Personal Information. With this in mind, we cannot, however, guarantee the security of the channels you will use to transfer your personal information to our Site. In this regard, you are solely responsible for possible failures in the transfer of your Personal Information to the Website. Once we have received your Personal Information, we will use strict procedures and all necessary technical and security measures to prevent unauthorized access to your Personal Information. 9. MARKETING CHOICES You have control regarding our use of Personal Data for direct marketing. In certain markets, you will need to expressly consent before receiving marketing. In all markets, you can choose to not receive such communications at any time. If you no longer wish to receive any marketing communications or to remain on a mailing list to which you previously subscribed, please follow the unsubscribe link in the relevant communication or contact us at [email protected]. 10. YOUR RIGHTS Under certain conditions, by contacting us you can use the following rights: 1) the right to delete your Personal Information (all or part thereof, except blockchain storages); 2) the right to change or correct your Personal Information, in particular when it is incorrectly stated; 3) the right to object to us using your personal data for a particular purpose or purposes or restrict processing of your Personal Information; 4) the right to access your Personal Information; 5) the right to withdraw consent to our processing or (and) controlling your personal data. Please note that the implementation of some of your rights, depending on the situation, may limit, complicate or completely exclude the possibility of further cooperation with us. Your exercise of these rights is subject to certain exceptions to protect the public interest (such as preventing or detecting crime) and our interests (such as maintaining legal privileges). Notwithstanding the above, we cannot edit or delete any information that is stored on a 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. Our Site may contain active links from/to the websites of our partners and advertisers. If you are following an active link, please note that other websites have their own privacy policies, and we are not responsible for the provisions of these policies. Please review the privacy policies of these websites before sharing your Personal Information with them. If you have any complaints about the use of your data, please let us know and/or file a complaint using the contact details below. Complaints must be written in English in a comprehensive manner and contain sufficient detail and a clear description of the complaint. You can also file a complaint with the supervisory authorities, but if the complaint has not been submitted to us first, we may use this fact as evidence of your unwillingness to resolve the issue out of court. 11. RETENTION OF PERSONAL DATA Making sure your Personal Information is safe and secured is of the highest priority to us. We use secure storage facilities ensuring the safeguard of your Personal Information you share with us at all stages of interaction with our Site using our products and Services. All appropriate measures to secure your Personal Information from potential hacking attacks, loss or misuse are implemented by our security team. We will hold your Personal Information only for the duration of you using our products and Services via your account, having regard to the purposes described in this Privacy Policy as well as legal and regulatory obligations that we comply with. Unless otherwise provided by law, you agree that we have the right, but are not required to, retain all personal information collected for the duration of your use of our Services and for the period required by law, but no longer than 5 (five) years. The storage period may be extended for a period not exceeding 1 (one) year, if there is a reasoned request from the competent authority. The Company will retain your personal data for the duration of your contractual relationship with the Company and, to the extent possible, after the termination of that relationship, for as long as necessary to fulfill the purposes set out in this Policy. We may access your Personal Information or retain it for a longer period if it will be subject to an official request or legal obligation, an investigation by governmental bodies or investigation into possible violations of our Terms of Use and its essential parts, or in other cases to prevent possible harm based on our reasonable considerations. 12. UPDATES TO THIS PRIVACY POLICY Any changes we may make to our Privacy Policy in the future will be posted on this page. By continuing to use the Clubeeo service, you agree to the changes made, so we encourage you to check this page frequently to be aware of any updates or changes to the Privacy Policy. 13. CONTACT US If you choose to use our Services, your use and any dispute over privacy is subject to this Notice and our Terms of Use. If you have any concerns about privacy at Clubeeo, please contact us by email at [email protected]. Last updated: October 2022