Tribally Games
Privacy and Online Notice

• Your privacy is important to us, so we have developed this Notice to explain how we manage and look after your personal information. In this Notice we will specify what data we collect, where does it come from and what rights do you have in relation to it.
• The EU General Data Protection Regulation (“GDPR”) provides individuals with several rights including right of access to their personal information, called a “Data Subject Access Request” (“DSAR”) as well as right to rectification, erasure (right to be forgotten) restriction, objection and data portability.
• We refer in this Notice to “personal information” and “personal data”. This refers to personal data as defined in GDPR, namely data that directly identifies an individual (for example, name, address and contact details, or also that which indirectly identifies an individual with less obvious identifiers, such as website cookies and internet protocol (IP) addresses, device ID or other online identifier). Tribally Games processes a wide range of personal data about its customers, players, agents, staff, suppliers and other third parties.
• Personal data we collect is processed in accordance with the law, only for specified, legally permitted purposes.
• We make every effort to ensure that the data collected by us is substantively correct and adequate in relation to the purposes for which it is processed and stored in a form that allows identification of persons to whom it relates, no longer than it is necessary to achieve the purpose of processing. We also maintain the security and confidentiality of the personal data collected.
• The data collected by us is processed, stored and may be transferred to any country within the European Union.

• Visiting and using our Website is associated with the need to collect and process your personal data.
• We process your personal data, in particular, the data you provide us with directly when setting up and verifying your account with us (this is the data you enter on the registration forms provided by us and the data contained within the documents you send to us) and the data you generate using our Services offered by through our Website (e.g. making purchase/ sale transactions/ placing orders etc).

• As part of the registration process, purchasers of Tokens are required to submit documents and personal information as described in our Know Your Client (KYC) Policy. The requirements are set out in more detail in the Policy, and may be subject to additional requests by us. However, by way of example, we may collect the following information from you:
  • Name;
  • Date of Birth;
  • Identification i.e. Passport Number/Driving License number;
  • Nationality and country of residence;
  • Full residential address;
  • Email address;
  • Telephone/mobile number;
  • Proof of address and photo ID; and
  • Your wallet address, any other cryptocurrency wallet address or bank account details and any related transaction details recorded by any blockchain on which the Tokens are based or utilised.
• We need to collect such a wide range of information not only to be able to provide our Services, but also to fulfil legal requirements regarding the obligation to identify the client, to monitor, combat and assess the risks of fraud, money laundering and financing terrorism. Therefore, if you do not provide the data requested during the registration and verification process, or if the data provided proves to be false or inaccurate, or if you object to its processing, we will not be able to continue to provide you with our Services.
• Due to the above-described obligations, in order to verify the accuracy of the data provided by you and to assess the risk of fraud, we also monitor your transaction history by analysing the course, volume, currency and type transactions.
• In addition, if you use our Website, we may collect additional information from you. This may include your personal information (including copies of your identity documents, your residential address and contact details) and your IP address.
• If you wish to use additional Services offered by us, we will process your data which we collect in order to provide our Services, in compliance with their description contained in the Terms and Conditions or provided to you separately. These Services may include among others: newsletters, contests, updates etc.
• We may also collect information that you voluntarily provide to us, such as when you communicate with us via email, on social media or via other channels, when you register for our updates and when you respond to our communication or requests for information. The information you provide may include your name, contact information, title and other personal information about you.

• By accessing our Website, we may also automatically collect certain data from your browser, including server log information (such as login details, IP address and details on the time spent on various pages on our Website) and device and browser information (such as the type of device, universally unique identifiers (‘UUID’), advertising identifiers (‘IDFA’), type of browser, operating system, hardware and processor information, plug- ins and add-ons).
• When you visit the Website, we place cookies on your device (e.g. computer hard drive, mobile phone). Cookies are small text files that are placed on your device by websites that you visit. They are widely used to makes websites work, or work more efficiently, as well as to provide information to the owners of the Website so they can improve its functionality and performance. For example, to enable the Website to load quickly, making it easier to move between different pages and remembering you have been shown a one-off message.
• We use Cookies to remember your preferences and settings, to remember information that you may enter online, to generate aggregate statistics about how people use our Services, to help you share content with others and to improve your experience of the Services.
• You can choose how Cookies are handled by your device through your browser or device settings, including refusing or deleting all Cookies. At any point you can change your cookie consent preference. If you choose not to receive Cookies, please be aware that some areas of our website may not function after you have changed your cookie preferences.
• Most browsers allow some control of most cookies through the browser setting. To find out more about cookies, including how to see what cookies have been set and hoe to manage and delete them, visit www.allaboutcookies.org.

• We may receive information about you from other sources, including third parties that help us update, expand, and analyse our records, prevent or detect fraud or other suspicious activities and process payments. In addition, our Website also includes integrated content or links to content provided by third parties (such as live chat, social media content, plug-ins and applications).

• We may use the information collected in the following way:
  • To identify you and conduct KYC and Anti-Money Laundering and other sanctions checks (or to verify those carried out by third party sources);
  • to provide you with our Services and other services that you request including, as applicable, supplying, and processing your payment for Tokens and any other services to be provided to you;
  • to respond to your enquiries or to any problems that may arise (such as difficulties in purchasing Tokens, navigating our Website or accessing certain services or features);
  • to inform you of important changes or developments to our Services or policies and to provide you with technical, support or administrative notifications;
  • to make payments to you;
  • with your specific consent, to send you marketing communications, and other information or materials that may be of interest to you or which you have expressed an interest in receiving (and subject to your ability to opt-out from receiving those communications);
  • to maintain our list of contacts;
  • to understand how customers, use our Website, including by generating and analysing statistics and user trends, and to evaluate, administer, maintain and improve our Website and other services;
  • for internal development of new products or services;
  • for our internal business purposes such as helping to compile statistical data analysis of the pages of the Website you visit;
  • to administer any services we provide such as, invoicing and detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement; and
  • as we believe reasonably necessary, advisable or appropriate to comply with our legal or regulatory obligations.
• The above are the purposes for which we process your personal information. In most cases the legal basis for the processing is that it is in Tribally Games interests which is not overridden by your rights and freedoms – we refer to this as “Tribally Games legitimate business interests”. In some cases, the legal basis is that the processing is necessary to perform a contract with you or to comply with a legal or regulatory obligation.
• We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do so.
• We may also aggregate personal and other data captured through our website so that the data is no longer capable of identifying an individual. We reserve the right to use this aggregated information for the purposes of improving and enhancing our services, generating insights, for use in marketing to other users and current and potential partners and otherwise for the purposes of our business. Provided that such aggregated data does not directly or indirectly identify you as an individual, this data is not considered to be personal information for the purpose of this Notice.
• When you close your account with us, all the data entered is deleted from our data base.

• We may share your personal information we collect with Tribally Affiliates, as explained at the beginning of this Notice.?
• Other than the third parties listed below, Tribally Games will not disclose your personal information to any third party unless either we have your permission to do so, or Tribally Games is, or consider itself to be, under a legal or regulatory obligation to do so.

Your personal information may be disclosed to the following recipients, though Tribally Games will use its reasonable endeavours to control the use of your personal information.

• To our partners and Third-party service providers for the purposes of carrying out services on our behalf (including those used by Tribally Games to complete your orders for products and/or services);
• Any person to whom Tribally Games proposes to transfer any of its rights and obligations under any agreement Tribally Games has with you;
• To financial institutions or service providers who may request the information in connection with providing services to us, including banking services;
• To law enforcement or other legal or regulatory bodies as may be permitted or required by the laws of any jurisdiction that may apply to us as;
• To our employees where required or necessary for the performance of their duties and in line with the reasons for processing;
• To advisors and Tribally Games Agents; and
• To our professional advisers and external auditors.

• We do not sell, rent, or otherwise share personal information that reasonably identifies you with unaffiliated entities for their independent use except as expressly described in this Notice or with your prior permission. We may share information that does not reasonably identify you as permitted by applicable law.

• Necessity for performance of a contract – We may need to collect and use your personal information to enter into a contract with you or to perform a contract that you have with us, for example, when you purchase Tokens;
• Legal obligation – we may process your personal information as we may be required to comply with any legal or regulatory obligations that may apply to us, for example under Anti-Money Laundering requirements;
• Legitimate Interests - We may use your personal information for our legitimate business interests to improve our Services; and
• Consent – Where required by applicable laws, we will reply on your consent for direct marketing and to collect information from your device or computer.

• Our Website may include integrated content or links to content provided by third parties (i.e. video materials, social media content, plug-ins).
• This Notice does not cover links within the Website to other third-party websites. Tribally Games is not responsible for the use of any personal information including without limitation cookies which you give directly to such third parties, or which third party websites may collect about you (using cookies or otherwise) while you visit pages hosted by them. Please refer to these third-party websites’ respective privacy policies for information about their use of your personal information and their use of cookies.

• Tribally Games understands the importance of ensuring its systems are secure from unauthorised access, use or disclosure so that emails and forms that contain your personal information are safe. We have administrative, technical and physical safeguards designed to comply with applicable legal requirements and to safeguard the information we collect. We also have internal policies, procedures and controls in place to ensure this, of both a technical and organisational nature.
• We may store the information we collect on our servers both cloud based or in servers located in countries where our third-party service providers have facilities. To facilitate our global operations, Tribally Games may transfer your personal information outside of the European Economic Area (“EEA”), UK and Switzerland. The EEA includes the European Union countries as well as Iceland, Liechtenstein, and Norway. Transfers outside of the EEA are sometimes referred to as “third country transfers”. We may transfer information to countries outside of your residence which may have different data protection laws and regulations that differ from those in your country.
• For the purposes outlined in this Notice, Tribally Games may send your personal information (which includes transfers to other Tribally Affiliates) internationally, including to countries outside the EEA. However, your personal information will only be transferred to or from countries outside the EEA as long as those countries have compatible data protection laws and measures in place or where we have put in place adequate safeguards as approved by the European Commission, details of which will be made available on request.
• We retain your data primarily to meet statutory and regulatory obligations. Secondly, your data is retained to enable us to pursue our legitimate business interests to our clients, current and future requirements.

• GDPR gives you a number of rights regarding your personal information that is processed by us:

• The right to be informed: our obligation to provide fair processing information;
• The right of access: allows you to be aware of and verify the lawfulness of the processing;
• The right to rectification: allows you to request the data is rectified if it is inaccurate or incomplete;
• The right to erasure: allows you to request the deletion or removal of personal data where there is no compelling reason for its continued processing;
• The right to restrict processing: allows you to ‘block’ or suppress processing of personal data in certain circumstances;
• The right to data portability: allows you to obtain and reuse your personal data for your own purposes across different services; and
• The right to object: you must have an objection on grounds relating to your particular situation.

• To withdraw your consent to the use of your information as described in this Notice, you can contact us through the stated methods below. Please note that in some circumstances this may mean that we can no longer provide our Services to you.

• It is important that any personal information we hold on you is accurate and up-to-date. Please keep us informed if your personal information changes or needs updating or if you believe that any information we have collected on you is inaccurate or out of date.
• You can also request to see what personal information we hold on you and request to erase any personal information it if is no longer required. You may also inform us if you object to our use of your personal information.

• From time to time, we issue email communications about service updates, operational and product information, and industry news. The electronic marketing communications we send to you also contain opt-out mechanisms that allow you to opt-out from receiving those communications, update your contract information or change your preferences at any time. We will only send you the email communications you have registered for. You may also opt back in to receive these email communications at any time.
• If you no longer wish to receive marketing communication from us, you can let us know via the stated methods below.

• This privacy Notice does not provide exhaustive detail of all aspects of Tribally Games processing of personal information. However, Tribally Games will to provide any additional information or explanation needed, if requested.
• Tribally Games tries to meet the highest standards when processing personal information. For this reason, we take any complaints we receive about this very seriously. Tribally Games encourages people to bring it to its attention if they think that its collection or use of information is unfair, misleading or inappropriate.
• If you would like to exercise any of these choices, need further details or information, have a query or have a compliant about our use of your personal information, please contact:

• By E-mail: support@tribally.games

• We review our Notice regularly as our business evolves and where the Notice has been updated and this results in a change to this Notice, this will be clearly identified by reference to the date of this Notice above. Unless stated otherwise, our current Privacy Notice applies to all information that we have about you and your account.

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