GAME Credits Privacy and Cookies Policy

This GAME Credits Privacy and Cookies Policy (the “Policy”) describes how NFT Platform LTD (“GAME Credits” “Company”, “we”, “our”, or “us”) collects, uses, shares, and stores personal information of users of our websites, https://www.gamecredits.org and https://app.gamecredits.org  (the “Site”) and the way we use cookies on the Site. This Policy applies to the Site, applications, products and services (collectively, “Services”) on or in which it is posted, linked, or referenced.

By using the Services, you accept the terms of this Policy and our Terms of Use, and consent to our collection, use, disclosure, and retention of your information as described in this Policy. If you have not done so already, please also review our terms of use. The terms of use contain provisions that limit our liability to you and require you to resolve any dispute with us on an individual basis and not as part of any class or representative action. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF USE, THEN PLEASE DO NOT USE ANY OF THE SERVICES.

Please note that this Policy does not apply to information collected through third-party websites or services that you may access through the Services or that you submit to us through email, text message or other electronic message or offline.

Please also note that the Company has offices outside of the EU and has affiliates and service providers in the United States and in other countries. Your personal information may be transferred to or from the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.

If you are visiting this Site from the European Union (EU), see our Notice to EU Data Subjects below for our legal bases for processing and transfer of your data.

1. The Types of Data We Collect. We collect various types of data from you as described below.  This may include, but is not limited to, both “Personal Data” and “Anonymous Data.” “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, government issued identification documents (such as a passport or driver’s license), as well as any other non-public information about you that is associated with or linked to any of the foregoing data.  “Anonymous Data” means data, including aggregated and de-identified data, that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons.
   1. Information You Give Us
      1. We may collect Personal Data from you, such as your first and last name, e-mail and mailing addresses, payment details, telephone number, and password when you create an account to log in to our Services;
      2. Profile information, such as your interests, preferences, feedback and survey responses;
      3. Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with Service, receive customer support or otherwise correspond with us;
      4. Usage information, such as information about how you use the Service and interact with us; and
      5. Marketing information, such as your preferences for receiving marketing communications and details about how you engage with them.
   2. Information Collected Via Technology. As you interact with our Site or Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
      1. Information Automatically Collected. We may automatically record certain information about how you use our Site (we refer to this information as “Log Data“). Log Data may include information such as a user’s Internet Protocol (IP) address, device and browser type, operating system, the pages or features of our Site to which a user browsed and the time spent on those pages or features, the frequency with which the Site is used by a user, search terms, the links on our Site that a user clicked on or used, and other statistics. We use this information to administer the Services and we analyze (and may engage third parties to analyze) this information to improve and enhance the Service by expanding its features and functionality and tailoring it to our users’ needs and preferences.
      2. Cookies. We may use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level. For more information, please see Section 10 entitled “Cookies” below.
      3. Analytics Services. In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our Site. This includes third party analytics services, including but not limited to Google Analytics, HotJar, and Facebook Analytics (“Analytics Services”), that we engage to help analyze how users use the Site and/or Services. We may receive reports based on these parties’ use of these tools on an individual or aggregate basis. We use the information we get from Analytics Services only to improve our Site and Services. The information generated by the Cookies or other technologies about your use of our Site and Services (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ terms of use and privacy policy. By using our Site and Services, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services, please contact us at [email protected].
         1. Google Analytics: You can find more information about Google Analytics’ use of your personal data here: https://www.google.com/analytics/terms/us.html
         2. Facebook Analytics: You can find more information about Facebook Analytics’ use of your personal data here: https://developers.facebook.com/policy
         3. Hotjar: You can find more information about Hotjar’s use of your personal data here: https://www.hotjar.com/legal/policies/privacy/ 
   3. Information We Get From Others. We may receive Personal and/or Anonymous Data about you from companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our Site. These third party companies may supply us with Personal Data. We may add this to the information we have already collected from you via our Site in order to improve the Services we provide. Such information may include, but is not limited to:
      1. Social Media Widgets. Our Site may include social media features, such as the Facebook “like” button and widgets, such as the “share this” button. These features may collect your Personal Data and track your use of the Site. These social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing such functionality.
      2. Information collected from Metamask. MetaMask provides us with your Ethereum address and certain other information you choose to share with MetaMask.
   4. Information we will never collect. We will never ask you to share your private keys or wallet seed. Never trust anyone or any site that asks you to enter your private keys or wallet seed.
2. Use of Your Personal Data
   1. General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us better providing our Services. We use your Personal Data in the following ways:
      1. To enable you to access and use the Services;
      2. To facilitate the creation of and secure your Account on our Site;
      3. To identify you as a user in our system;
      4. To provide and deliver products and services that you may request including but not limited to facilitating your cryptocurrency transactions through MetaMask (https://metamask.io);
      5. To protect you and other users from any conduct that violates the Terms of Use or to prevent abuse or harassment of any user;
      6. To send information, including confirmations, technical notices, updates, security alerts, and support and administrative messages;
      7. To communicate with you. We use your Personal Data to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners;
      8. To comply with law. We use your Personal Data as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government authorities;
      9. To optimize our platform. In order to optimize your user experience, we may use your Personal Data to operate, maintain, and improve our Services. We may also use your information to respond to your comments and questions regarding the Services and to provide you and other users with general customer service;
      10. For compliance, fraud prevention, and safety. We may use your Personal Data to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;
      11. With your consent. We may use your Personal Data with your consent, such as when you consent to let us post your testimonials or endorsements on our Site, you instruct us to take a specific action with respect to your Personal Data, or you opt into third party marketing communications; and
      12. In any other way we may describe when you provide the Personal Data.
3. Disclosure of Your Personal Data. We do not share or sell the Personal Data that you provide us with other organizations without your express consent, except as described in this Policy. We disclose Personal Data to third parties under the following circumstances:
   1. Third Party Professional Advisors and Service Providers.  We may share information with those who need it to do work for us. These recipients may include third party companies and individuals to administer and provide the Service on our behalf (such as customer support, hosting, email delivery and database management services), as well as lawyers, bankers, auditors, and insurers.
   2. Affiliates. We may disclose your Personal Data to our subsidiaries and corporate affiliates for purposes consistent with this Policy.
   3. Business Transfers. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Policy.
   4. As Legally Required. Regardless of any choices you make regarding your Personal Data (as described below), we may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Company; (c) to protect or defend the rights or property of Company or users of the Site or Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Policy, or our Terms of Use. We may share information in an emergency. 
   5. Emergencies.  This includes protecting the safety of our employees and agents, our customers, or any person.
   6. Other Disclosures. We may also disclose your Personal Data, to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide it; or with your consent. You may also permit us to share your Personal Data with other companies or entities of your choosing. Those uses will be subject to the privacy policies of the recipient entity or entities. We may also share aggregated and/or anonymized data with others for their own uses.
4. How Your Information is Secured
   1. Retention of Personal Data.  We retain information we collect as long as it is necessary and relevant to fulfill the purposes outlined in this Policy. In addition, we retain Personal Data to comply with applicable law where required, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Use, and other actions permitted by law. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.  In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
   2. Data Protection. We employ industry standard security measures designed to protect the security of all information submitted through the Services. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, biometrics, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected.
5. Third Party Websites. Our Site may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site and go to another site, and another entity may collect Personal Data or Anonymous Data from you. We cannot control, do not review, and cannot be responsible for, these outside websites or their content. The terms of this Policy do not apply to those outside websites or content, or to any collection of your Personal Data after you click on links to those websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of those third parties or their content or websites.
6.  Your Choices Regarding Your Information and Changes. You have various choices regarding the use of information on our Services:
   1. Accessing, Updating, Correcting, and Deleting your Information. You may access information that you have voluntarily provided through your account on the Services, and to review, correct, or delete it by sending a request to [email protected]. You can request to change contact choices, opt-out of our sharing with others, and update your Personal Data and preferences.
   2. Opting Out of Marketing Communications. We may use some of the information we collect for marketing purposes, including to send you promotional communications about the Services. If you wish to stop receiving these communications or to opt out of use of your information for these purposes, please follow the opt-out instructions by clicking “Unsubscribe” (or similar opt-out language) in those communications. You can also contact us at [email protected] to opt out.
   3. Disabling Cookies.  Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. For more information, please see Section 10 entitled “Cookies” below.
   4. Google Analytics. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.
7. Notice to California Residents. Under California Civil Code Section 1789.3, California users are entitled to the following consumer rights notice: California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.  
   1. This section provides additional details about the Personal Data we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”
   2. For more details about the Personal Data we collect from you, please see the “The Types of Data We Collect” section above. We collect this information for the business and commercial purposes described in the “Use of Your Personal Data” section above. We share this information with the categories of third parties described in the “Disclosure of Your Personal Data” section above. Company does not sell (as such term is defined in the CCPA) the Personal Data we collect (and will not sell it without providing a right to opt out). Please refer to Section 10 below entitled “Cookies” for more information regarding the types of third-party cookies, if any, that we use.
   3. Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of Personal Data we collect (including how we use and disclose this information), to delete their Personal Data, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
   4. California consumers may make a request pursuant to their rights under the CCPA by contacting us at [email protected]. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.
8. Notice to EU Data Subjects
   1. Personal Data. With respect to EU data subjects, “Personal Data,” as used in this Policy, is equivalent “personal data” as defined in the European Union General Data Protection Regulation (GDPR).
   2. Sensitive Data. Some of the information you provide us may constitute sensitive data as defined in the GDPR (also referred to as special categories of personal data), including identification of your race or ethnicity on government-issued identification documents.
   3. Legal Bases for Processing: We process personal data subject to GDPR on one or more of the following legal bases:
      1. Legal Obligation: to conduct anti-fraud and to fulfill our retention and other legal obligations;
      2. Contractual Obligation: to satisfy our obligations to you under our Terms of Use, including to provide you with our Services and customer support services, and to optimize and enhance our Services;
      3. Legitimate Interest: to monitor the usage of our Services, conduct automated and manual security checks of our Services, to protect our rights; and
      4. Consent: to market our Services. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before consent is withdrawn.
   4. Use for New Purposes. We may use your Personal Data for reasons not described in this Policy, where we are permitted by law to do so and where the reason is compatible with the purpose for which we collected it. If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the applicable legal basis for that use. If we have relied upon your consent for a particular use of your Personal Data, we will seek your consent for any unrelated purpose.
   5. Your Rights. Under the GDPR, you have certain rights regarding your Personal Data. You may ask us to take the following actions in relation to your Personal Data that we hold:
      1. Opt-out. Stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you Service-related and other non-marketing communications.
      2. Access. Provide you with information about our processing of your Personal Data and give you access to your Personal Data.
      3. Correct. Update or correct inaccuracies in your Personal Data.
      4. Delete. Delete your Personal Data.
      5. Transfer. Transfer a machine-readable copy of your Personal Data to you or a third party of your choice.
      6. Restrict. Restrict the processing of your Personal Data.
      7. Object. Object to our reliance on our legitimate interests as the basis of our processing of your Personal Data that impacts your rights.
      8. You can submit these requests by email to [email protected]. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your Personal Data or response to your requests regarding your Personal Data, you may contact us at [email protected] or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator in this list of data protection authorities.
   6. Cross-Border Data Transfer. Please be aware that your Personal Data will be transferred to, processed, and stored in the United States. Data protection laws in the U.S. may be different from those in your country of residence. You consent to the transfer of your information, including Personal Data, to the U.S. as set forth in this Policy by visiting our Site or using our service.  Whenever we transfer your Personal Data out of the EEA to the U.S. or countries not deemed by the European Commission to provide an adequate level of Personal Data protection, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection for Personal Data. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
9. A Note About Children. If you are under the age of majority in your jurisdiction of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. Consistent with the requirements of the Children’s Online Privacy Protection Act (COPPA), if we learn that we have received any information directly from a child under age 13 without first receiving his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Site and subsequently we will delete that information.
10. Cookies. We understand that your privacy is important to you and are committed to being transparent about the technologies we use. In the spirit of transparency, this Policy provides detailed information about how and when we use cookies on our Site.
    1. Use of Cookies 
       1. Our Site uses cookies to distinguish you from other visitors of our Site. Cookies are small text files that may be stored on your computer (or other internet enabled devices, such as a smartphone or tablet. They are sent by a server to your computer and stored on your hard drive to allow a website to recognise you when you visit. Cookies can be used by website to make the user’s experience more efficient. 
       2. Our Site uses different types of cookies. Some cookies are placed by third party services that appear on our pages. We use cookies to personalize content, to provide social media features and to analyse our traffic. This improves your experience when you browse our Site and allows us to improve the service we provide. By continuing to browse our Site, you are agreeing to our use of cookies.
       3. We also share information about your use of our Site with our social media and analytics partners who may combine it with other information that you have provided to them or that they have collected from your use of their services. 
       4. We use the following cookies:
          1. Strictly Necessary Cookies. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. These cookies enable basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
          2. Targeting Cookies. These cookies may be set through our Site by our advertising partners. Marketing cookies are used to track visitors across websites. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers. They do not store directly Personal Data, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
          3. Performance Cookies. These cookies are usually referred to as statistical cookies and allow us to count visits, traffic sources so we can measure and improve the performance of our Site. They help us to know which pages are the most and least popular and see how visitors move around the Site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our Site, and will not be able to monitor its performance.
    2. How To Disable Cookies. You can generally activate or later deactivate the use of cookies through a functionality built into your web browser. To learn more about how to control cookie settings through your browser:
       1. Go to the “Private Browsing” setting and managing cookie settings in Firefox;
       2. Go to the “Incognito” and managing cookie settings in Chrome;
       3. Go to the “InPrivate” and managing cookie settings in Internet Explorer; or
       4. Go to the “Private Browsing” and managing cookie settings in Safari.
    3. Additional Information. If you want to learn more about cookies, or how to control, disable or delete them, please visit https://www.aboutcookies.org for detailed guidance. In addition, certain third party advertising networks, including Google, permit users to opt out of or customize preferences associated with your internet browsing. To learn more about this feature from Google, click here.
11. CONTACT INFORMATION. We welcome your comments or questions about this Policy, and you may contact us at: [email protected].
12. CHANGES TO THIS POLICY. We may change this Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make any changes, we will change the Last Updated date below. Any modifications to this Policy will be effective upon our posting of the new terms and/or upon implementation of the changes to the Site (or as otherwise indicated at the time of posting). In all cases, your continued use of the Site or Services after the posting of any modified version of this Policy indicates your acceptance of the terms of the modified Policy.
13. Review of this Policy. We keep this Policy under regular review. This Policy was last updated in March 2021.