This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The GenesisPlayer is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Important information and who we are
VRATech Pte Ltd, of 60 Paya Lebar Road, 409051, Singapore is the controller and is responsible for your personal data (collectively referred to as “we”, “us” or “our” in this policy).
Our contact details are:
- Full name of legal entity: VRATech Pte Ltd
- Email address: email@example.com
- Postal address: 60 Paya Lebar Road, 409051, Singapore
You have the right to make a complaint at any time to your local supervisory authority for data protection issues.
The Data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data.
- Contact Data.
- Financial Data.
- Marketing and Communication Data.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How your Personal Data is collected
We will collect and process the following data about you:
- Information you give us. This is information (including Identity, Contact and Financial) you consent to giving us about you by filling in forms when using the GenesisPlayer. It includes information you provide when you claim tokens. If you contact us, we will keep a record of that correspondence.
How we use your Personal Data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract we are about to enter or have entered with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
Purposes for which we will use your Personal Data
|Purpose/activity||Type of data||Lawful basis for processing|
|To register you to enable you to receive tokens||IdentityContact
|To manage our relationship with you including notifying you of changes||IdentityContact
Marketing and Communications
|Your consentPerformance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ services)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
|To administer and protect our business including troubleshooting, data analysis and system testing||IdentityContact
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)|
|To deliver content and advertisements to youTo make recommendations to you about goods or services which may interest you
To measure and analyse the effectiveness of the advertising we serve you
Marketing and Communications
|ConsentNecessary for our legitimate interests (to develop our products/Services and grow our business)
Disclosures of your Personal Data
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table above:
- Internal Third Parties as set out below.
- External Third Parties as set out below.
Our external third parties may based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
All information you provide to us is stored on our secure servers.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
In some circumstances you can ask us to delete your data: see below for further information.
In the event that you do not use the GenesisPlayer for a period of 24 months then we will treat the account as expired and your personal data may be deleted.
Your Legal Rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at firstname.lastname@example.org.
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties Other companies in the Verasity Group.
External Third Parties Service providers who provide IT and system administration services.
Regulators and other authorities who require reporting of processing activities in certain circumstances.
Other ICO projects to which we licence the GenesisPlayer.
YOUR LEGAL RIGHTS
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
DESCRIPTION OF CATEGORIES OF PERSONAL DATA
- Identity Data: first name, last name.
- Contact Data: email address, Telegram handle.
- Financial Data: ERC-20 wallet address..
- Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties.