1. INTRODUCTION
Who are we?
Soccer Labs Holdings Ltd and Soccer Labs Publishing Ltd (“Soccerverse”, “we”, “us”, and “our”) are companies incorporated in the BVI with company numbers 2093993 and 2164774 respectively. Both companies have a registered office is c/o SHRM Trustees (BVI) Limited Trinity Chambers, P.O. Box 4301, Road Town, Tortola, British Virgin Islands. Where we decide the means or purpose of processing personal data, we are the “controller.”
What’s this policy about?
This policy explains how we process your personal data as a data controller when you visit our website at soccerverse.io or make use of the Soccerverse game (together, the “Services”). We update this policy from time to time so please check back in.
This policy is written in English. Any translated version is provided solely for your convenience. To the extent any translated version of this policy conflicts with the English version, the English version prevails.
How do you contact us?
(if you have questions about this policy or to exercise your rights)
Write to us at: [email protected]
If we can’t resolve your issue and you live in a European country or the UK, you can submit a complaint to the supervisory authority in your country.
What are your rights?
You have the following rights, although these rights may be limited in some circumstances:
- Ask us to send a copy of your data to you or someone else
- Ask us to restrict, stop processing, or delete your data
- Object to our processing of your data
- Object to use of your personal data for direct marketing
- Ask us to correct inaccuracies
If we rely on consent to process data, or send direct marketing, you can withdraw consent by email to the address above.
2. HOW WE USE PERSONAL DATA
- Game Data
We monitor transactions on the Ethereum blockchain including:
– sender and recipient wallet addresses; and
– the type and content of transactions (including what tokens are sent, how many, and meta data and messages attached to those transactions) which includes, without limitation, the username you choose for your account.How long we keep it
We only store this data temporarily while our server software is running, for as long as necessary to deliver our Services. The underlying data is however stored perpetually on the public Ethereum blockchain.
How we use it
These transactions, including details of the sender, recipient and their content (including what tokens are sent, how many, metadata & messages attached to transactions) are monitored and interpreted by our software.Our software treats transactions and the associated information as actions within a decentralised game. For example, wallets are interpreted as players, if a wallet sends a particular message to another wallet with a message attached, that message might be interpreted as meaning that the first player has agreed to send an in-game item to the second player.Our software gathers historical transaction data to calculate what the state of the game is at any time.When players connect to our software, it may send them information about the state of the game, so they can view it in their browser.We may also analyse this data to understand how users play the game, & how we can improve it.Our software may help you to carry out transactions, such as through MetaMask functionality enabling you to send tokens to a particular destination, where that transaction may later be interpreted by our software as you purchasing game items.
However, we are not a party to or in control of those transactions, we do not directly receive personal data about you when you carry out transactions, and instead we simply provide software which you can use to interact with the public blockchain.
Legal basis
We process this personal data to pursue our legitimate interests (and the legitimate interests of users) in delivering our online decentralised game, improving the game and fixing problems with our software.
Sources and recipients
Sources
We collect this information from the public Ethereum blockchain.
Recipients
We share the information with players who connect to our software.
- Enquiry Data
We collect the following categories of personal data to respond to enquiries relating to the Services:
– name;
– email address; and
– other personal data sent as part of enquiries.
How we use it
We process this information to respond to your enquiries (including, for example, to send you an invitation to join a beta).
Legal basis
We process this personal data:
– in accordance with the terms of our contract or to take steps at their request prior to entering a contract, where we need this information to provide the Services; and
– to pursue our legitimate interests in understanding how users use the Services and of improving our Services (for example by using your feedback about our Services to improve them).
Sources and recipients
Sources
We collect this information directly from you.
Recipients
None, we only process this information within our business.
- Marketing data
We process the following information about you to send you our newsletter and let you know about news and updates relating to us, our partners, products, services and content:
– name;
– contact information (such as email address); and
– your contact and profile information if you choose to use a social login service such as Facebook, Google, LinkedIn, Instagram or other similar services to create or access your account.
How we use it
We process this information to send you marketing communications by email.
Legal basis
We process your personal data for this purpose where we have your consent.
More Information
You can withdraw your consent at any time by dropping us a line or clicking on the unsubscribe link in our emails.
Sources and recipients
Sources
We collect this information from you.
Recipients
We may use third party services to deliver our email marketing campaigns (such as Aweber and Mailchimp).
- Analytics
(data about how you interact with our website which might (but may not always) be associated with a unique ID) including:
– browser type and version, IP address, approximate location and time zone, access logs, device type and settings, operating system, & other information provided by browser or device;
– use you make of our Services, including the URLs and content you visit, actions and clickstream to, through and from our website, date and time, page response times, errors, length of visits to website pages, interaction (such as scrolling, clicks and mouse-overs) data, details of the website which directed you to our website.
How long we keep it
After 26 months underlying data is deleted, but we may retain anonymous, aggregated statistics generated from that data.
How we use it
We use our Services and Google Analytics to collect data about visitors to our website, to understand how many people visit, where they come from, and how they interact with our Services and website, and to help us improve and maintain our website and Service.
Legal basis
We may process website analytics data which uses cookies or similar technologies with your consent (if you give it).
If we undertake analytics without storing or accessing information on your device (for example by reviewing log information on our servers which explain how our website or Service have been used) then we do this in pursuit of our legitimate interests in understanding how people use our Service and improving them.
More information
You can find out more about how Google uses data by reviewing their privacy policy here.
You can withdraw your consent for Google analytics by using the following link: Google Analytics.
Sources and recipients
Sources
We use Google’s services to collect this data and otherwise collect it from you.
Recipients
Google in the USA collects and process analytics data on our behalf.
Where explicit retention periods are not described above, we hold data for as long as necessary bearing in mind the purpose for which it was collected. To determine the appropriate period, we consider the amount, nature, and sensitivity of the data, the potential risk of unauthorised access, and legal requirements.
3. COOKIES, ANALYTICS AND SIMILAR TECHNOLOGIES
Cookies, pixels and other technologies store and access data on devices to help websites and apps work. This table explains their purpose, how long they last, and who else can access their data. We get consent to use them unless they are essential to the Services.
Most browsers allow control over cookies, for more information: Google Chrome | Microsoft Edge | Mozilla Firefox | Microsoft Internet Explorer | Opera | Apple Safari.
Cookie/data: Google Analytics
Duration: 2 years
Purpose: To track user behaviour on the website and improve site performance.
Access: We use Google Analytics. and you can access their privacy policy here.
4. TRANSFERS AND DISCLOSURE
Transfers
We share your personal data within our group. This will involve transferring your data outside the BVI.
Whenever we transfer your personal data out of the BVI we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented.
We use specific standard contractual terms approved for use in the EU which give the transferred personal data the same protection as it has in the BVI.
Where we use data processors outside the BVI or we transfer personal data to a country which does not provide an adequate level of protection, we use contracts approved by the Information Commissioner’s Office and/or European Commission which give personal data protection similar to that which it has in the BVI. For more information drop us a line using the contact details at the start of this policy.
Disclosure
Other than as set out above, we may disclose your personal data:
- Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies).
- With members of our corporate group, suppliers and subcontractors, as necessary for the purposes set out in this policy.
- If involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.