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Privacy Policy

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.

This Privacy Policy does not limit or exclude any of your rights under the Swiss Data Protection Act or other applicable laws. This notice should be read in conjunction with our Terms of Use, as referred to herein from time to time.

This Privacy Policy applies to “Alien Worlds,” offered by the Company through the website alienworlds.io and its subordinate sites, as further defined in clause 1 of our Terms of Use (as available under: Terms and Conditions - Alien Worlds), mobile devices or other platforms (“Alien Worlds”), as well as to Galactic Hubs, its website ghubs.alienworlds.io and the relevant subordinate websites, as further described in the Specific Terms for Galactic Hubs (available under: Terms and Conditions - “Galactic Hubs”, collectively with Alien Worlds, the “Services”). This Privacy Policy explains how we may collect and use any personal information that we obtain about you and your rights in relation to that information. Please read this carefully. By using the Services, you affirm that you have read and understand this Privacy Policy and that you consent to the collection and use of your personal information as outlined in this Privacy Policy.

We may provide you with additional privacy notices where we believe that it is appropriate to do so. Those additional notices supplement and should be read together with this Privacy Policy.

Overview

  1. Who is responsible for your personal information?
  2. Which information about you is collected?
  3. How do we use your personal information?
  4. How and why may we share your personal information?
  5. Transfer of Data outside of the EEA
  6. Statistics
  7. How do we protect your personal information?
  8. How long do we keep your personal data?
  9. 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:

  1. when you create a User Account (as defined in clause 4 of the Terms of Use), your email address if you provide one, WAX compatible digital wallet address and user name;
  2. if you purchase merchandise, your WAX or Ethereum address;
  3. your purchase history and other information relating to transactions made through the Website; and
  4. 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:

  1. character names and gameplay information;
  2. any Posts or Images (as defined in clauses 8 and 9 of the Terms of Use);
  3. Images (as defined in clause 9 of the Terms of Use);
  4. your credited name (if any);
  5. ‘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;
  6. 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
  7. 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):

  1. 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.
  2. 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;
  3. 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;
  4. 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;
  5. 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
  6. 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.

2.5 Information collected through our use of cookies or similar technologies. Please refer to our Cookies Notice (available under) for further information, including information on how you can disable these technologies.

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:

  1. to provide the Services in connection with our Terms of Use and/or the Specific Terms for Galactic Hubs to you;
  2. to verify your identity and verify that your User Account is not being used by others;
  3. to fulfill any orders for merchandise ordered through the Website;
  4. 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;
  5. 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;
  6. to communicate about grants and awards extended under the Galactic Hubs program; and
  7. to respond to communications from you.

3.2 We use the information generated by your access or use of the Services:

  1. 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;
  2. for security and system integrity purposes; and
  3. to conduct research and statistical analysis (on an anonymised basis) (see more in the Statistics section of this Privacy Policy below);

3.3 We may also use your personal information in connection with our rights and interests:

  1. to protect and/or enforce our legal rights and interests, including defending any claim;
  2. for any other purpose authorized by you, the Swiss Data Protection Act or other applicable law;
  3. to respond to lawful requests by public authorities, including to meet law enforcement requirements; and
  4. 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:

  1. you have consented to us doing so (where necessary) or any other person has obtained your consent for us to do so (where necessary);
  2. we are under a legal, regulatory or professional obligation to do so (for example, to comply with anti-money laundering or sanctions requirements);
  3. it is necessary in connection with legal proceedings or in order to exercise or defend legal rights.

4.2 We use third parties who provide products and services on our behalf and/or may support us in providing the Services, and may share your information with them, for example banks, insurance companies or technology suppliers who may have access to your personal information when providing support. We may disclose research and statistical analysis (on an anonymised basis) derived from your personal information to third parties (see more in the Statistics section of this Privacy Policy below).

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.

6. Statistics

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?

Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure. We will take reasonable steps to keep your personal information safe from loss, unauthorized activity or other misuse. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risks inherent in processing personal information. You can play an important role in keeping your personal data secure by maintaining the confidentiality of any passwords and accounts used in relation to the Services and/or our websites or materials, including by using a unique password that you do not use on any third-party websites or related services. Please do not disclose password used in connection with our Services, websites and/or materials to third parties. Please notify us immediately if there is any unauthorized use of an account you have with us in connection with our Services or any other breach of security. While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk. If you post your personal information on our websites’ public pages, you acknowledge that the information you post is publicly available. If you follow a link on our websites to another website, the owner of that website will have its own privacy policy relating to your personal information that you should review before you provide any 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:

  1. request access to your personal information and certain information in relation to its processing;
  2. request rectification of your personal information;
  3. request the erasure of your personal information;
  4. request that we restrict the processing of your personal information; and
  5. 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).

9.7 We reserve the right to update and change this Privacy Policy from time to time in order to reflect any changes to the way in which we process your personal information or changing legal requirements. Any changes we may make to our Privacy Policy in the future will be posted on this website. Please check back frequently to see any updates or changes to our Privacy Policy.

May 16th, 2022