Last updated: 23 August 2024

Welcome to the Playground Platform Privacy Notice for services provided by DNFT INC. ("Privacy Notice"). Please take a few minutes to read it carefully before providing any information about yourself or any other person.

Introduction

We respect your privacy and are committed to protecting your personal data. This Privacy Notice applies to the processing of personal data by DNFT INC. ("Playground," "we," "us," "our") in connection with the use of our products, services, or applications related to our non-fungible tokens ("NFT") services (collectively, the "Services"). It also applies when you visit or use our website ("Site") to the extent related to the Services. Please note that our Services and Site are not intended for minors below the age of 18 years, and we do not knowingly collect data relating to minors.

Purpose

This Privacy Notice explains why and how we collect and process your personal data. It informs you of your privacy rights and how data protection principles set out in the EU General Data Protection Regulation ("GDPR") and the UK GDPR protect you. It is important that you read this Privacy Notice along with any other notice or policy we may provide when collecting or processing personal data about you, so you fully understand why and how we are using your data. This Privacy Notice supplements other notices and policies and does not override them. Please note that all or part of our Services may not be available in your region.

Who We Are

Data Controller: The controller of your personal data is DNFT INC., a company incorporated under the laws of Delaware, with a registered address at 251 Little Falls Drive, Wilmington, DE 19808. This company is responsible for handling your personal data related to the use of our products, services, or applications related to our NFT services.

Complaints: You have the right to make a complaint about how we process your personal data to a supervisory authority. If you reside in an EEA Member State, you can complain to the supervisory authority in your country of residence, place of work, or where the alleged infringement occurred. You may also contact your local data protection regulatory authority. However, we would appreciate the chance to deal with your concerns first, so please feel free to contact us directly.

Our Duties and Your Duties in Case of Changes: We keep our Privacy Notice under regular review. This version was last updated on the date indicated above. Please check for new versions from time to time. We will also inform you of material changes to this Privacy Notice in a manner that will effectively bring the changes to your attention. It is important that the personal data we hold about you is accurate and up-to-date. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links: The Site and any applicable web browser required to access the Services may include links to third-party websites, plug-ins, and applications ("Third-Party Sites"). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these Third-Party Sites and are not responsible for their privacy statements and policies. When you leave our Site, we encourage you to read the privacy notice or policy of every Third-Party Site you visit or use.

What Data We Collect About You

Personal Data: Personal data or personal information refers to any information that relates to an identified or identifiable living individual. This includes specific pieces of personal data such as your name, identification number, location data, online identifier, and other factors related to your identity. It does not include data where the identity has been removed (anonymous data).

Categories of Personal Data We Collect: Depending on whether and how you use our Services or Site, and whether you sell or buy NFTs, we may collect, use, store, and transfer different kinds of personal data about you, including:

• Identity Data: Name, display name, profile picture, background picture, short biography, social media accounts.

• Contact Data: Email address, phone number.

• Financial Data: Payment card details, virtual currency accounts, stored value accounts, amounts associated with accounts, external account details.

• Transactional Data: Details about payments to or from you, other transaction details.

• Investment Data: Information about royalties, fees, sales price, and sell-through information.

• Technical Data: Internet connectivity data, IP address, login data, browser type and version, device type, time zone setting and location data, browser plug-in types and versions, operating system and platform, diagnostics data like crash logs.

• Profile Data: Username, password, identification number, preferences, feedback, and other information generated by you during interactions with us.

• Usage Data: Information about how you use the Site, Services, and other offerings.

• Marketing and Communications Data: Preferences in receiving marketing, communication preferences, survey responses.

Special Categories of Personal Data: We currently do not process any special categories of personal data (such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs).

Refusal to Provide Personal Data: Where we need to collect personal data by law or under the terms of a contract with you, and you refuse to provide that data, we may not be able to perform the contract. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case.

How We Collect Your Data

We collect information from and about you through various methods, including:

• Direct Interactions: You may provide us with Identity Data, Contact Data, Financial Data, Investment Data, Profile Data, and Marketing and Communications Data through direct interactions with us, such as filling in forms, emailing us, or otherwise interacting with our Site or Services.

• Automated Technologies: We automatically collect Technical Data about your equipment, browsing actions, and patterns as you interact with our Site. This data is collected using cookies, server logs, and similar technologies. We may also collect Transactional Data, Investment Data, and Usage Data automatically.

• Third Parties or Publicly Available Sources: We may receive information about you from third parties or publicly available sources, including public blockchains and other publicly accessible data.

How We Use Your Data

We will only use your personal data when legally permitted. The most common uses of your personal data include:

• Performance of a Contract: Processing your data where necessary for the performance of a contract with you or to take steps at your request before entering into such a contract.

• Legitimate Interests: Processing your data for our legitimate interests or those of a third party, provided your interests and rights do not override those interests.

• Consent: Processing your data based on your freely given, specific, informed, and unambiguous consent. In certain circumstances, your consent should be explicit, and we will ask for it as required.

Purposes for Which We Use Your Personal Data

We use your personal data for various purposes, including:

• Registering you as a new customer.

• Processing and delivering our Services and features to you.

• Preventing abuse of our Services and promotions.

• Managing our relationship with you, including asking you to leave a review, take a survey, or keeping you informed of our business and product development.

• Managing, processing, collecting, and transferring payments, fees, and charges.

• Complying with legal obligations and responding to complaints.

• Enabling you to partake in prize draws, competitions, or surveys.

• Gathering market data to study customer behavior, preferences, and interests.

• Administering and protecting our business, Site, and social media channels.

• Delivering relevant website content and advertisements to you and measuring the effectiveness of our advertising.

• Using data analytics to improve our website, products, services, marketing, customer relationships, and experiences.

• Making suggestions and recommendations to you about goods or services that may be of interest to you.

Marketing

You will receive marketing communications from us if you have requested information from us and consented to receive marketing communications. We will use your Contact Data and Marketing and Communications Data for our respective activities.

Third-Party Marketing

We will obtain your opt-in consent before sharing your personal data with any third party for marketing purposes.

Opting Out

You can ask us to stop sending you marketing messages at any time by following the opt-out links in any marketing message sent to you. Where you opt out of receiving marketing messages, this will not apply to service messages related to the use of our Services.

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of the Services or Site may become inaccessible or not function properly.

Change of Purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis for doing so.

Sale or Transfer of Business

We may process your data in connection with or during the negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving all or part of our shares, business, or assets.

Disclosures of Your Data

We share your personal data with third-party service providers, agents, subcontractors, associated organizations, group companies, and affiliates to complete tasks and provide Services on our behalf. These entities are required to respect the security of your personal data and treat it in accordance with the law.

We may pass your personal data to the following entities:

• Companies and organizations that assist us in processing, verifying, or refunding transactions/orders and providing Services.

• Any third party to whom we lawfully transfer our rights and duties under the relevant terms and conditions governing the use of the Services.

• Any third party involved in any restructure, sale, or acquisition of our group or any affiliates, provided they use your information for the same purposes as originally supplied to us.

• Regulatory and law enforcement authorities, inside or outside the EEA, where the law allows or requires us to do so.

International Transfers

We may share your personal data within our group, which may involve transferring your data outside the EEA or the UK. Many of our external third parties are based outside the EEA or the UK, so processing your data may involve transferring it outside these regions. We ensure a similar degree of protection for your data by implementing safeguards like Standard Contractual Clauses.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorized way, altered, or disclosed. We also limit access to your personal data to employees, agents, contractors, and other third parties who have a legitimate business need to know. These parties will only process your personal data on our instructions and are subject to a duty of confidentiality. We have procedures in place to deal with any suspected data breach and will notify you and any relevant regulator where required by law.

Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including satisfying any legal, regulatory, tax, accounting, or reporting requirements. We consider the amount, nature, and sensitivity of the data, potential risks of harm, purposes of processing, and applicable legal requirements to determine the appropriate retention period.

Your Legal Rights

You have rights regarding your personal data, depending on our reason for processing it. These rights include:

• Access: You can request access to your personal data.

• Rectification: You can request the correction of inaccurate or incomplete data.

• Erasure: You can request the deletion of your data, subject to legal exceptions.

• Objection: You can object to processing based on legitimate interests or direct marketing.

• Restriction: You can request the suspension of data processing in certain circumstances.

• Data Portability: You can request the transfer of your data to you or a third party.

• Withdrawal of Consent: You can withdraw consent for data processing at any time.

You will not have to pay a fee to access your personal data or exercise your other rights. However, we may charge a reasonable fee or refuse to comply with your request if it is unfounded or excessive.

We aim to respond to legitimate requests within one month, which may be extended by two months if necessary due to complexity or number of requests. We may need to verify your identity before fulfilling your request.