PRIVACY POLICY
Last Updated: May 25, 2022
Crypto Clubhouses Canada Inc. (“Crypto Clubhouses”, “our”, “us”, “we”) takes your privacy and the protection of your personal information seriously. This Privacy Policy (the “Policy”) describes our data protection practises, the types of Personal Information we may receive or collect from you when you interact with our Platform (as defined hereunder) and of how we use, disclose, store and secure it. By doing so, you will be able to make wise and informed choices.
This Policy applies to our website accessible through www.cryptoclubhouses.io and our services related to NFTs (our “Platform”). However, we wish to draw your attention to the fact that the rights and obligations described in this Policy do not cover third-party websites that may be linked to or mentioned on our Platform. These third-party websites and services have their own privacy policies and we encourage you to read them carefully before accessing them, using them or otherwise providing Personal Information to them.
1. PERSONAL INFORMATION.
For the purpose of this Policy, “Personal Information” means any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. In general, Personal Information does not include business contact information, such as your name, title, or business contact information.
2. WHAT PERSONAL INFORMATION DO WE COLLECT?
When registering an account with us (if any), the Personal Information and Non-Personal Information that we collect may include, but is not limited to:
• Identifiers such as a name and last name, birthdate, email address, telephone number, postal address, country of residence to identify and correspond with you;
• Details of transactions that you carry through our Platform and the fulfillement of your orders;
• All the necessary information necessary to conduct a criminal background check as necessary (including but not limited to, copy of your ID, passport or driver licence, copy of your finger print, etc.);
• Your login information such as your username, account ID, login ID, display name, moniker, user handle, referral code (if any), creation date, email address and password;
• Any other Personal Information you volunteer, including in order notes, in relation to a promotion (including constests, sweepstakes, offers, and rebates) or survey, or on any of our community forums, social media offering or blogs.
In addition to the information above, if we reasonably suspect that your account or any of our services is being, or has been, misused, including by not limited by DoS attackes, cheating, fraud, hacking, distribution of spam or viruses, defamation, racism, hate speech, currency farming or any other violations of the relevant terms of service, we may collect additional Personal Information and Non-Personal Information to verify or refute such suspicions within the limits of applicable law and taking into account your reasonable data protection interests. When you provide us with bug reports, contact our support service for any technical issues or provide any feedback, in addition to the information above, we may also collect the Personal Information and Non-Personal Information that you provide us such as:
• Crash reports;
• Machine specifications or reports;
• Screenshots;
• Any other data that you may choose to provide.
3. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
Directly from you. Generally, we will collect the Personal Information that we need directly from you, for example when you use our Platform, through online forms, chat tools, when you create an account or when you communicate with us. We may also collect information relating to your use of our Platform including technical information about your visits such as number of visits, conversion rate, average lenght of a visit, action carried out on the Platform, pages viewed during the visit, type of device used, web browser used, IP address used, origin of visitors.With a legal basis such as your consent. The legal basis to process your Personal Information is typically because you have consented to it, unless applicable laws permit another applicable legal basis (e.g., for the purpose of complying with our legal obligations, where necessary for establishing, exercising, or defending a legal claim, a prospective legal claim, legal proceedings or prospective legal proceedings.).
From third party services. We may receive information about you from third parties and affiliates that help us provide, support, and secure our Platform or who would otherwise provide marketing services. In general, data shared with Crypto Clubhouses in this manner will be treated under the same privacy restrictions as any other data shared with Crypto Clubhouses.
Refusal of collection and withdrawal of your consent. You have the right, if you so choose, to refuse the processing of your Personal Information. You may also, at any time, and subject to reasonable notice and applicable legal or contractual restrictions, withdraw your consent (if any) to the processing of your Personal Information in our possession by contacting us. You should be aware, however, that if you choose not to provide us with your Personal Information, this may prevent you, for example, from using Platform or certain features, as this information is essential for such use. You may contact us as set forth in the Section “How to contact us?” to address any issue thereof.
4. WHY DO WE COLLECT YOUR PERSONAL INFORMATION?
For specific and limited Purposes. Crypto Clubhouses generally collects your Personal Information to:
• Establish and manage our relationship with you;
• Provide and maintain the services requested, such as the access and use of Platform, access to our services;
• Resolve disputes and troubleshoot problems;
• Perform research and development projects, including for statistical purposes;
• Fulfill your requests for certain products and services;
• Detect and protect against errors, fraud, or other criminal activities;
• Verify your information for internal security purposes;
• To verify your identity in the event you contact us for assistance;
• Compare information for accuracy and verify it with third parties;
• Improve your customer experience;
• Respond to your requests for information;
• Respond to your support requests;
• Enforce the relevant terms of service;
• Perform other duties as required by law.
• Enable business development and marketing, including informing our current and future customers about our new offerings, with the prior consent of the individual concerned;
(collectively, the “Purposes” ).
For secondary purposes. Depending on the circumstances, Crypto Clubhouses may also aggregate and anonymize Personal Information that you have provided to create statistical data which Crypto Clubhouses may use for market research, to improve our Platform or services, examine trends and interests or train machine learning algorithms. Such statistical data does not include any Personal Information.
5. COOKIES AND OTHER SIMILAR TOOLS
We may use various tools to improve your experience on our Platform, to better understand our customers’ behaviour, and in connection with our marketing strategies. The following section is intended to give you more information about how we use these tools.Cookies, client-side storage technologies and web beacons. Crypto Clubhouses may use cookies and web beacons. In general cookies are small data files that are commonly stored on your device when you use websites and online services. On the other hand, web beacons are tiny images that we may place on our web pages or emails. They can be used, for example, to obtain anonymously the number of times a particular page has been visited by a user or whether an email has been read. As the name implies, web beacons are invisible in any part of our Platform. Unlike cookies, web beacons are not placed on your computer. For the purpose of this Policy, cookies, client-side storage technologies and web beacons are collectively referred to as “cookies”.
Cookies that we use. Crypto Clubhouses may use different types of cookies. As set forth below, some cookies are strictly necessary to the proper functioning of the Platform while others are used with you prior consent for functional, performance or advertising purposes.
Necessary Cookies: We use strictly necessary cookies to enable the proper functioning of our Platform, our security measures and those of third parties. Without these cookies, the services you have requested cannot be provided.
Functionality cookies (also known as “preference cookies”): These cookies are not essential to the provision of our services. They help personalize and enhance the user experience. For example, if you have consented to their use, such cookies will store your communication and language preferences.
Performance cookies (also known as “statistical cookies” or “analytical cookies”): These cookies are not essential to the provision of our services. If you have consented to their use, we use performance cookies to understand how you interact with our Platform. Our partners may also use this type of cookie to analyze your use of our Platform and provide us with information about it. These cookies are for statistical purposes only. For more information on our use of cookies, see the “Use of Analytics Tools” section.
Cookies for advertising purposes: These cookies are not essential to the provision of our services. If you have consented to their use, we use advertising cookies to present you with relevant content, including on social networks. Also, our partners may use these cookies to determine whether our advertisements were displayed to you and whether you interacted with them. In such cases, our partners share data with us, including statistics about the performance of our ads.
Social media features. Our Platform includes social media features such as the Discord, Instagram or Twitter share button or interactive mini-programs that run on our Platform. If you use these features, they collect your IP address, the page you visit on our Platform, and create a cookie to enable these features to function properly. These features may be hosted by a third party or directly on our Platform.
Deactivation of cookies to which you have consented. Except for strictly necessary cookies, we will only place cookies on your device if you consent to it, and such cookies will be kept for a maximum period of thirteen months from when they are placed on your device. At the end of this period, your consent will be required again.
You can also manage your cookie settings at any time by following the instructions below. However, if you choose to decline cookies, some pages or sections of our Platform may not display properly or some features may not be available. Furthermore, even if you choose not to receive ads targeted to your interests, it is still possible to see ads from Crypto Clubhouses. In this case, they will simply not be adapted to your real needs and may be displayed more frequently.
Set your preferences on your browser: You can manage your cookie settings by changing the settings on your browser or device. For details on how to set up your browser, please see the help centre for Chrome, Safari , Firefox , Internet Explorer , Edge or Opera .
Set your social networking selections If you want to change your settings for sharing cookies via social networks, we invite you to go directly to the sites of these social networks: Facebook , Linkedin , Twiiter
Deactivate Analytics. You can deactivate Google Analytics by installing this add-on.
6. HOW DO WE SHARE AND DISCLOSE YOUR PERSONAL INFORMATION?
Crypto Clubhouses does not rent nor sell any of your Personal Information to third parties and will not share it with third parties, other than expressly set out in this Policy, without your consent unless it is necessary to do so by law or for the Purposes as set forth below.With employees. In the course of their work, employees may need to access your Personal Information, for example, when you contact us or request support. Their access is limited to what is necessary to perform their duties.
With any of our afilliated companies. Crypto Clubhouses may use different types of cookies. As set forth below, some cookies are strictly necessary to the proper functioning of the Platform while others are used with you prior consent for functional, performance or advertising purposes.
With strategic partners and third party service providers. Crypto Clubhouses may share your Personal Information with its partners to facilitate its business, such as service providers, developers and hosting service providers. In connection with these business operations, our service providers may have access to your Personal Information for a limited time in connection with these business activities. Where Crypto Clubhouses utilizes third parties for the processing of any Personal Information, Crypto Clubhouses strives to implement reasonable contractual and technical protections in order for such third parties to keep all Personal Information they process strictly confidential. Please note that these third parties may be located elsewhere than your location in which case, commercially reasonable measures are taken by Crypto Clubhouses as set forth below in the Section “Where is your Personal Information stored and transferred?”.
When required by applicable laws. We may also share your Personal Information if required to do so by law or in the good faith belief that such action is necessary to: (i) conform with the law; (ii) comply with the order of a competent judicial authority in any jurisdiction; (iii) comply with the legal process served on Crypto Clubhouses; (iv) protect and defend the rights or property of Crypto Clubhouses; (v) enforce or verify your compliance with any part of the agreements that you have entered into with Crypto Clubhouses, if any; (vi) prevent fraud or other illegal activity perpetrated through the Service; or (vii) act in urgent circumstances to protect the personal safety of users of our Platform, our services or the public at large.
During business transfer. We may share your Personal Information without your permission when our operations require it (in the event of a merger, acquisition, bankruptcy, or sale of assets, for example). As part of this kind of event, we may also share some or all of your Personal Information to the relevant third party (or its advisors) as part of a due diligence process.
For other purposes with your consent. Where you have expressly consented, your Personal Information may be shared with other third parties. For example, there may be specific instances where additional terms apply and, through these, we make clear that specific third parties process your Personal Information.
7. WHERE IS YOUR PERSONAL INFORMATION STORED AND TRANSFERRED?
Your Personal Information may be held by Crypto Clubhouses in locations other than your province, territory, state, or country of residence, including in Canada and the province of Quebec. Crypto Clubhouses may also subcontract processing to or share your Personal Information with third parties located elsewhere, including locations other than your province, territory, state, or country of residence. In such case, Crypto Clubhouses will ensure that your Personal Information is transferred to countries that have received an adequacy decision from the competent authority, or that your Personal Information is adequately protected by appropriate technical, organizational, contractual, or other lawful means. If you would like to obtain more information on these security measures, please contact us as set forth in the Section “How to contact us?”.
8. WHERE IS YOUR PERSONAL INFORMATION STORED AND TRANSFERRED?
Personal Information will be retained only as long as necessary for the fulfillment of the Purposes or as required by law. At the end of such period, we strive to destroy or anonymize this information. To determine the appropriate retention period for your Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the Purposes for which we process your Personal Information and whether we can achieve those Purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. If you would like more information on this subject, we invite you to contact us .
9. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
With necessary and appropriate security measures. Crypto Clubhouses has security measures in place to protect your Personal Information. The standard security measures we use will depend on the type of information collected. However, Crypto Clubhouses uses physical, electronic, and procedural safeguards that comply with applicable regulations to protect your Personal Information. We encourage you to be cautious when using the Internet. This includes not sharing your passwords. If you think an unauthorized account has been created using your name, please contact us as set forth in the Section “How to contact us?”.Children’s privacy. Our Platform and services are intented for adult audiences and are not directed at children. Crypto Clubhouses does not knowingly process any Personal Information from minors. If you believe that Personal Information has been collected a minor, or if you are a parent or legal guardian and think that your child has provided us with Personal Information, you may contact us as set forth in the Section “How to contact us?”.
10. WHAT ARE YOUR RIGHTS?
Depending on applicable laws, you might have different rights such as the right to be forgotten, the right to obtain access to, or rectification of your Personal Information, the right to withdraw your consent (if any), the right not to be discriminated against, the right to restrict and to object to the use and processing of your Personal Information by us, or the right to data portability by, namely, receiving a copy of all Personal Information that Crypto Clubhouses has about you in a structured, commonly used and machine-readable format. To exercise any of these rights (to the extent available), please contact us as set forth in the Section “How to contact us?”.
11. EUROPEAN UNION DATA
This Section only applies to Personal Information that is collected or processed on an individual located in the territory of the European Union at the time of such collection.a) Right to erasure. With some restrictions applicable, in accordance with the international application of the General Data Protection Regulation, you will be entitled to obtain from Crypto Clubhouses the prompt deletion of your Personal Information and Crypto Clubhouses is required to delete such Personal Information as soon as possible, where any of the following reasons apply:
- the Personal Information is no longer necessary for the purposes for which it was collected or otherwise processed;
- you withdraw the consent on which the processing is based and there is no other legal basis for the processing;
- you object to the Processing and there is no compelling legitimate reason for the Processing;
- the Personal Information has been unlawfully processed;
- the Personal Information must be deleted to comply with a legal obligation to which Crypto Clubhouses is subject;
- the Personal Information was collected as part of an offer of services normally provided for remuneration, remotely, electronically and at the individual request of a recipient of services.
Where Crypto Clubhouses has made the Personal Information public and is required to delete it, Crypto Clubhouses, taking into account the available technologies and the costs of implementation, will take reasonable steps, including technical measures, to inform the data controller who processes such Personal Information that you have requested that such data controller delete any link to or copy or reproduce such Personal Information.
b) Right to restrict processing. You will be entitled to obtain from Crypto Clubhouses a restriction to process when any of the following applies:
- for a period of time that allows Crypto Clubhouses to verify the accuracy of the Personal Information while you dispute the accuracy of the Personal Information;
- the processing is unlawful and you object to the deletion of Personal Information and instead require a restriction to process by limiting the Personal Information use;
- Crypto Clubhouses no longer requires the Personal Information for the purposes of the processing, but it is still necessary for you to establish, exercise or defend legal rights;
- you object to the processing during a verification as to whether the legitimate grounds pursued by Crypto Clubhouses prevail over your own.
c) Right to Data Portability. You will be entitled to receive the Personal Information you have provided to Crypto Clubhouses, in a structured, commonly used and machine-readable format, and you will be entitled to transmit such Personal Information to a third party without Crypto Clubhouses impeding it where the processing is based on your consent and the processing is carried out using automated processes.
d) Right to Object. You may object, at any time, for reasons relating to your particular situation, to the processing of your Personal Information which is necessary for the legitimate interests pursued by Crypto Clubhouses or by a third party or for the performance of a task carried out in the public interest or in the exercise of a public authority vested in Crypto Clubhouses, including profiling. Crypto Clubhouses will no longer process Personal Information unless we demonstrate that there are compelling legitimate reasons for the processing that prevail over your interests, rights and freedoms or for the establishment, exercise or defence of legal rights.
e) Automated Individual Decision-Making, Including Profiling. You may not be the subject of a decision based exclusively on automated processing, including profiling, that produces legal effects concerning you or significantly affects you in a similar manner, unless the decision is:
- necessary for the conclusion or performance of a contract between you and Crypto Clubhouses;
- authorized by the law to which Crypto Clubhouses is subject and which also provides for appropriate measures to safeguard your rights, freedoms and legitimate interests;
- based on your explicit consent.
To learn more about your rights or the steps to follow to make such request, please communicate with us to the following address: privacy@retromodding.com . Note that we will not discriminate against you for the exercise of these rights.
12. HOW TO CONTACT US?
If you have any questions about any aspect of this Policy, wish to send a comment, make a complaint or exercise any of the rights made available to you according to applicable laws, please contact our Data Protection Officer as follows:
Data Protection Officer
Crypto Clubhouses
[Address]
[Email]
Your request may be accepted or denied by Crypto Clubhouses based on the applicable laws. Crypto Clubhouses will take prompt corrective action when it learns of any failure to comply with this Policy. Crypto Clubhouses shall not be liable for any indirect, incidental, consequential or punitive damages relating to this Policy. You may file a complaint with the competent authority at any time if you believe that Crypto Clubhouses is not processing your Personal Information in a manner that is compliant with this Policy or with the applicable laws.