”) look after your personal data when using any of our services or applications (together the “Services
”) or when visiting or using our websites, https://www.kinguin.net/nft/collections
We are committed to safeguard the privacy of individuals with respect to your personal data. We assure that our policies and practices, and those adopted by our affiliated companies and agents in relation to the collection, use, retention, disclosure, transfer, security and access of your personal data comply with the requirements under the Personal Data (Privacy) Ordinance (Chapter 486) (the “Ordinance”) under the laws of Hong Kong, as well as the relevant code of practice and guidance issued by the Office of the Privacy Commissioner for Personal Data, Hong Kong. The meaning of the term "personal data" adopted in this Statement is defined in the Ordinance. In addition to the Ordinance od other Hong Kong laws, individuals located in the European Union (EU) may also have rights under the General Data Protection Regulation 2016/679 (GDPR).
Collection, processing and use of your information
HOW WE COLLECT PERSONAL INFORMATION
We collect personal information in a variety of ways, including:
- Directly: We collect personal information which you directly provide to us, including when you register on the NFT Marketplace, through the ‘contact us’ form on our websites or when you request our assistance via email, our online chat or over the telephone.
- Indirectly: We may collect personal information which you indirectly provide to us while interacting with us such as when you use any of our Sites, in emails, over the telephone and in your online enquiries.
We can collect, use or disclose your personal information without your consent for legal, security or certain processing reasons as required by law to deter fraud and money-laundering, or for other legal purposes.
The types of personal information we may collect about you include:
- your name;
- your contact details, including email address and name;
- your Ethereum (and/or other public blockchain) address and wallet;
- your credit card or payment details (through our third party payment processor);
- your preferences and/or opinions;
- information you provide to us through customer surveys;
- details of products and services we have provided to you and/or that you have enquired about, and our response to you, including any support requests and any bug reports;
- your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behavior;
- information about your access and use of our Services, including through the use of Internet cookies, your communications with our Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
- additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
- any other personal information requested by us and/or provided by you or a third party. We may collect these types of personal information directly from you or from third parties
COLLECTION AND USE OF PERSONAL INFORMATION
We may collect, hold, use and disclose personal information for the following purposes:
- to enable you to access and use our Services, Sites, associated applications and associated social media platforms;
- to enable you to perform transactions on the Services;
- to contact and communicate with you about our Services;
- for internal record keeping, administrative purposes, invoicing and billing purposes;
- for analytics, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms;
- to run promotions, competitions and/or offer additional benefits to you;
- for advertising and marketing, including to send you promotional information about our group’s products and services and information about third parties that we consider may be of interest to you;
- to comply with our legal obligations and resolve any disputes that we may have;
- if you have applied for employment with us, to consider your employment application; and
- if otherwise required or authorised by law.
DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
We may disclose personal information to:
- third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing providers, professional advisors and payment systems operators;
- our employees, contractors and/or related entities;
- our existing or potential agents or business partners;
- sponsors or promoters of any competition we run;
- anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
- credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
- courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
- third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of Hong Kong; and
- third parties to collect and process data, such as Google Analytics or other relevant businesses. This may include parties that store data outside of Hong Kong; and
- any other third parties as required or permitted by law, such as where we receive a subpoena.
Overseas disclosure: Where we disclose your personal information to third parties listed above, these third parties may store, transfer or access personal information outside of Hong Kong, including but not limited to, United States of America.
We will only disclose your personal information to countries with laws which protect your personal information in a way which is substantially similar to the Hong Kong privacy principles or we will take such steps as are reasonable in the circumstances to protect your personal information in accordance with the Ordinance and other Hong Kong laws.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our online Services.
We may use web beacons on our Site from time to time. Web beacons (also known as ClearGIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
We may use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time.
HOW WE KEEP YOUR INFORMATION SAFE
We protect your information using security standards such as firewalls and data encryption, physical access controls to our premises and information access authorization controls. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. We also authorize access to your information only for those employees or contractors who require it to fulfill their job or service responsibilities.
However, no security system is impenetrable and we cannot guarantee the security of our systems. In the event that any information under our custody and control is compromised as a result of a breach of security, we will take steps to investigate and remediate the situation and, in accordance with applicable laws and regulations, notify those individuals whose information may have been compromised.
You are responsible for the security of your digital wallet, and we urge you to take steps to ensure it is and remains secure. If you discover an issue related to your wallet, please contact your wallet provider.
Please note that transmission of data or information (including communications by e-mail) over the internet or other publicly accessible networks is not one hundred percent secure. Please note that we are not liable for the security of any data you are transmitting over the internet.
You may access, review, edit, correct, remove and delete your personal data at any time by contacting our support team. You may be requested by our team to provide the respective confirmation documents in case of your personal data information change. Where required by law, we will facilitate your exercise of your rights.
Under the Ordinance, you have the right to:
- Check whether we hold any of your personal data;
- Access your personal data held by us;
- Request us to correct any inaccurate personal data held by us; and
- Ascertain our policies and practices established (from time to time) in relation to personal data and the types of personal data held by us.
If you want to access and/or correct your personal data which you have given us via Customer Service.
European users have the right under applicable privacy laws to:
Objecting to processing: You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights and freedoms, in order to proceed with the processing of your personal information.
Restricting processing: You have the right to request that we restrict the processing of your personal information, if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.
Access, erasure and data portability: You may have the right to request details of the personal information we hold about you, or to request that we erase the personal information we hold about you, or that we transfer this information to a third party.
Rectification: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, incomplete, misleading or out of date.
Notwithstanding the above, we cannot edit or delete any information that is stored on a blockchain, for example the Ethereum blockchain, as we do not have custody or control over any blockchains. The information stored on the blockchain may include purchases, sales, and transfers related to your blockchain address and NFTs held at that address.