Dacoco GmbH, (hereafter the “Company”, “we”, “us” or “our”) is committed to protecting the privacy and security of the personal information that is provided to us or collected by us during the course of our business. We store and process personal information in accordance with the Swiss Data Protection Act and to the extent applicable, the EU General Data Protection Regulation.
- Who is responsible for your personal information?
- Which information about you is collected?
- How do we use your personal information?
- How and why may we share your personal information?
- Transfer of Data outside of the EEA
- How do we protect your personal information?
- How long do we keep your personal data?
- Your rights
1 Who is responsible for your personal information?
Dacoco GmbH, Dammstrasse 16, 6300 Zug, Switzerland is responsible for your personal information as provided to us or collected by us during the course of our business.
2. Which information about you is collected?
Whenever you access or make use of any of the Services, we may collect the types of information described in this section 2 from you:
2.1 Information you provide directly to us, including:
- if you purchase merchandise, your WAX or Ethereum address;
- your purchase history and other information relating to transactions made through the Website; and
- information contained in your correspondence with us, for example, when you send us an email.
2.2 Information collected during the course of your use of the Services or our websites or materials, including:
- character names and gameplay information;
- your credited name (if any);
- ‘crash reports’ in the event that a software crash occurs, which may include details of your User Account, a portion of the memory state of the game when the crash occurred and the game settings you were using, but not other information from your computer or its memory;
- information about the computer or device you use to access our Service, including the hardware model, operating system and version, MAC address, unique device identifier (“UDID”), phone number, International Mobile Equipment Identity (“IMEI”) and mobile network information; and
- data contained in log files (the information in log files may include your IP address, your ISP, the Web browser you used to visit the Services, the time you visited the Services, which web pages you visited on the Services, and other anonymous usage data).
2.3. Specific information collected from Participants under the Specific Terms for Galactic Hubs, where you engage in the Galactic Hubs Program, in particular (please refer to the Specific Terms for Galactic Hubs, which prevail over the following, illustrative list, in the event of discrepancies):
- basic information on your participating project, including your project’s name, notification address, Telegram handle, Twitter handle, referral information (if applicable), the grant amount you are seeking in TLM, grant category in which you are applying, your project idea and description, the current status of your project, your project’s needs and challenges, and any information you volunteer to set out why the your project and team is qualified, such as e.g. links to previous work.
- account information, including your project’s WAX account address and names of the owner(s), beneficiary owner(s) and additional Know Your Beneficiary information on the owner(s) if not otherwise disclosed;
- identifying information of all legal entities, partnerships, or other forms of organization connected to the project, in particular their names, jurisdictions, registration numbers, places of registration, registered addresses, principal places of business, and copies of a registration document;
- the identities of all team members and other individuals who are materially involved in the management, as well as those of the beneficial owners, in particular their names, residential addresses and copies of a valid identification document, and, for leading team members, a summary of their respective education and professional track record;
- with regard to grants or awards equivalent to amounts exceeding USD 3,000, certain additional data, being, (i) for entities under c. above, evidence of their registration and good standing, and (ii) for individuals under d. above, formal evidence regarding their identity, address and good standing, as well as certain additional information reasonably requested in connection with their track record; and
- with regard to grants or awards equivalent to amounts exceeding USD 10,000, certain further information, as reasonably and specifically requested by Us with regard to the background of the project or the individuals or entities engaged therein.
2.4 Information collected from third parties where you have authorized this or the information is publicly available.
2.6 Other contact or personal information we collect and process about you if you offer or provide products or services to us, if we evaluate your products or services, and generally when you request information from us or provide information to us.
3. How do we use your personal information?
3.1 We use the information provided by you in connection with providing our Services:
- to verify your identity and verify that your User Account is not being used by others;
- to fulfill any orders for merchandise ordered through the Website;
- to market products and services to you, including contacting you via email that you may choose (or opt in) to receive. You can stop receiving our promotional emails by following the unsubscribe instructions included in those emails;
- to enable and implement the Galactic Hubs program, identify the participants therein in line with the compliance standards we must observe under the applicable laws, regulations and best practices, and to assess the eligibility for grants and awards within the program;
- to communicate about grants and awards extended under the Galactic Hubs program; and
- to respond to communications from you.
3.2 We use the information generated by your access or use of the Services:
- to monitor the performance of our websites, materials and Services and ensure that such websites, materials and our Services perform in the best manner possible;
- for security and system integrity purposes; and
3.3 We may also use your personal information in connection with our rights and interests:
- to protect and/or enforce our legal rights and interests, including defending any claim;
- for any other purpose authorized by you, the Swiss Data Protection Act or other applicable law;
- to respond to lawful requests by public authorities, including to meet law enforcement requirements; and
- where this is necessary for our legitimate interests (except where such interests would be overridden by your fundamental rights and freedoms which require the protection of personal data).
3.4 We do not use personal information to make any automated decisions – automated processes do monitor gameplay to identify cheating and fraud but human intervention is applied in the decision-making process. Information is gathered transiently for these purposes but is not stored.
4. How and why may we share your personal information?
4.1 We may share your personal information with third persons (such as advisors, authorities and other persons) in Switzerland, the EU or other countries if required or useful for providing our products and services, in particular the Services. Further, we may share your personal information with third persons where:
- you have consented to us doing so (where necessary) or any other person has obtained your consent for us to do so (where necessary);
- we are under a legal, regulatory or professional obligation to do so (for example, to comply with anti-money laundering or sanctions requirements);
- it is necessary in connection with legal proceedings or in order to exercise or defend legal rights.
5. Transfer of Data outside of the EEA
5.1 The personal data we collect in relation to the Services and/or our websites and materials may be transferred to, and stored in, a country outside the European Economic Area (“EEA”). Under the GDPR, the transfer of personal data to a country outside the EEA may take place where the European Commission has decided that the country ensures an adequate level of protection. In the absence of an adequacy decision, we may transfer personal data provided appropriate safeguards are in place.
5.2 With regard to registrations or applications to Galactic Hubs, personal data, and in particular all personal data about European customers, is initially received and processed by Shopify International Ltd., which is located in Ireland. Shopify International Ltd. may then export this data as explained above, and is responsible for compliance with GDPR export requirements when it does.
We may use and publish non-personal aggregate statistics and group data about those people who access or make use of any of the Services and/or our websites and materials and their usage of any of the Services, websites or materials.
7. How do we protect your personal information?
8. How long do we keep your personal data?
We will retain your personal information for as long as is necessary for the purpose for which it was collected. We will further retain your personal information to comply with legal and regulatory obligations, for as long as claims could be brought against us and for as long as legitimate interest, including data security, requires.
9 Your rights
9.1 In relation to the processing of your personal information, you have rights that you can exercise under certain circumstances. These rights are to:
- request access to your personal information and certain information in relation to its processing;
- request rectification of your personal information;
- request the erasure of your personal information;
- request that we restrict the processing of your personal information; and
- object to the processing of your personal information.
9.2 If you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so. If we become unable to process your personal information in line with the above, we may refuse to provide you with access to any Services, and/or any websites or materials which rely on the use of such personal information.
9.3 We may refuse to provide access to data if the relevant data protection legislation or other legislation allows or obliges us to do so, in which case we will provide reasons for our decision as required by the law.
9.4 If you would like to exercise these rights, please contact us in writing by email to: [email protected] (if related to Alien Worlds), [email protected] (if related to Galactic Hubs) or by letter to: Dacoco GmbH, Dammstrasse 16, 6300 Zug.
9.5 You will not, in general, have to pay a fee to exercise any of your individual rights. However, we may charge a fee for access to your personal information if the relevant data protection legislation allows us to do so, in which case we will inform you as required by the law.
9.6 If you feel we have not handled your query or concern to your satisfaction you can contact the competent data protection authority in Switzerland, the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).
May 16th, 2022