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3A DAO – PRIVACY POLICY

Date of the latest revision: August 24, 2023.


This document is part of the Terms available at https://3adao.org/terms (the “Terms”).


1  GENERAL INFORMATION


This Privacy Policy (the “Privacy Policy”) provides a comprehensive description of how 3A DAO, LLC. and its affiliates (“3A DAO”,” “we,” “our,” or “us”) collect, use, and share information about you in connection with the website at https://3adao.org/ as well as other related interfaces (https://app.3adao.org) (the “Interface”), and your rights and choices regarding such information. These terms apply to the Interface and any other online location that links to this Privacy Policy (collectively, the “Services”).

By using the Services, you agree to our collection, use, and disclosure practices, as well as any other activities described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you should immediately discontinue the use of the Services and refrain from accessing the Interface.

If you have any questions or wish to exercise your rights and choices, please contact us at the email or portal address set forth in the “Contact Us” section below. If you are a data subject in the European Economic Area or the United Kingdom, please see the additional disclosures at the end of this Privacy Policy.


2  PROCESSING OF PERSONAL DATA


2.1 Use of Cookies and Similar Technologies

The Interface is using cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies are typically stored on your computer's hard drive. Information collected from cookies is used by us to evaluate the effectiveness of the Interface and analyze trends. The information collected from cookies allows us to determine such things as which parts of the Interface are most visited and difficulties our visitors may experience in accessing the Interface. With this knowledge, we can improve the quality of your experience on the Interface by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties.

We may use third party service providers, to assist us in better understanding the use of the Interface. We, or our service providers, will place cookies on the hard drive of your computer (or use similar technologies) and will receive information that we select that will educate us on such things as how visitors navigate around the Interface. This information is aggregated to provide statistical data about our users' browsing actions and patterns, and does not personally identify individuals (however, see below information on Polygon wallet addresses). This information may include:
  • Computer or mobile device information,
  • Website usage information, such as: page views, account changes (i.e. connecting a wallet), button clicks, input form change and errors.
The information and analysis so collected will be used to assist us in better understanding our visitors' interests in our Interface and how to better serve those interests, as well as help ensure secure use of the Interface for all users. If you want to avoid using cookies altogether, you can disable cookies in your browser. However, disabling cookies might make it impossible for you to use certain features of the Interface. Your use of the Interface with a browser that is configured to accept cookies constitutes acceptance of our and third-party cookies.

2.2 Google

Google Analytics

The Interface uses Google Analytics, a web analytics service provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. You can deactivate Google Analytics with a browser plug-in. Google Analytics also uses cookies. These allow Google Analytics to analyze the use of the Interface. The information collected based on cookies about the use of the Interface (including your IP address) is usually transferred to a Google server in the USA and stored there. Google uses the collected information to evaluate the use of the Interface, to write reports for us in this regard and to provide other related services to us. You can learn more at support.google.com/analytics.

Google Tag Manager (GMT)

We use GTM to manage various third-party tags and scripts on our Website, which may collect certain non-personal information about your interactions with our Website. This information includes but is not limited to your IP address, browser type, device type, operating system, and website navigation behavior. GTM does not collect personal information directly; however, the tags managed through GTM may collect personal information based on your interactions with our Website.

2.2.1 Third-Party Tags:

We may use third-party tags through GTM to collect data for analytics, advertising, and other purposes. These tags may include, but are not limited to, Google Analytics,Yandex Metrica, and other tracking technologies. Each third-party tag has its own privacy policy and practices, which you should review for further information about their data collection and usage practices.


2.3 Public Polygon Addresses

We use and collect public Polygon addresses to identify and document a user’s journey through our products and historical use of the Interface and Services, as defined in the Terms.

We may group and analyse these user journeys and historical usage collectively in order to improve our product user experience. We may also use this data to facilitate individual access to the Interface, Services and linked third party websites, communicate with individuals regarding their use of the Services, and in other ways related to individual use of the Services and the Interface.

The legal basis for this processing is that it is necessary to fulfill a contract with you, as well as our legitimate interests, such as monitoring and improving the Interface, and the proper protection of the Interface against risks.


2.4 Blockchain Data

Note that we are not responsible for your use of the Polygon blockchain and your data processed in this decentralized and permissionless network.


2.5 Use of information

We do not anticipate using, but we may collect and use information for business purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information include:
  • Operating and managing the Services; performing services requested by you, such as responding to your comments, questions, and requests, and providing information support; sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages; detecting, preventing, and addressing fraud, breach of Terms, and threats, or harm; and compliance with legal and regulatory requirements.
  • Protecting the security and integrity of the Services; improving the Services and other websites, apps, products and services; conducting promotions, such as hack-a-thons, including to verify your eligibility and deliver prizes in connection with your entries; and fulfilling any other business purpose, with notice to you and your consent.

2.6 International Transfer

We are entitled to transfer your personal data to third parties abroad for the purposes of the data processing and external access by you of services provided by those third parties. As personal data processors, they are obliged to protect data privacy to the same extent as we ourselves. We choose the processors carefully to ensure compliance with applicable laws.


2.7 Sharing and Disclosure of Information

If we share or disclose information that we collect, we do so in accordance with the practices described in this Privacy Policy. The categories of parties with whom we may share information include:
  • Affiliates. We share information with our affiliates and related entities, including where they act as our service providers or for their own internal purposes.
  • Service Providers. We share information with third-party service providers for business purposes, including fraud detection and prevention, security threat detection, payment processing, customer support, data analytics, information technology, storage, and transaction monitoring. Any information shared with such service providers is subject to the terms of this Privacy Policy. All service providers that we engage with are restricted to only utilizing the information on our behalf and in accordance with our instructions.
  • Professional Advisors. We share information with our professional advisors for purposes of audits and compliance with our legal obligations.
  • Merger or Acquisition. We share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
  • Security and Compelled Disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
  • Facilitating Requests. We may share information about you at your request or direction.
  • Consent. We may share information about you with your consent. Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.

3  Duration of data processing


We will process your personal data only for the period necessary to achieve the purpose of the processing, or as required by applicable laws. After the period the personal data will be deleted.


4  DATA SECURITY


We use appropriate technical and organizational security measures to protect your personal data. Our security measures are continuously improved in line with technical developments. Please note that any data transmission on the Internet (e.g. communication by email) is generally not secure and we accept no liability for data transmitted to us via the Internet. Unfortunately, absolute protection is not technically possible. This information does not apply to the websites of third parties and the corresponding links given on the Interface. We assume no responsibility and liability for these.


5  YOUR RIGHTS AND CHOICES


You have the right to receive information at any time and free of charge about your stored personal data, its origin and recipients and the purpose of data processing. Moreover, you have the right to correct, block or delete this data.

For this purpose, as well as for further questions regarding personal data, you can contact us at any time at the address provided below.


6  AMENDMENTS TO THIS PRIVACY POLICY


We may amend this Privacy Policy at any time by posting the amended version on the Interface including the effective date of the amended version. The current version of the Privacy Policy, as published on the Interface, is applicable.


7  CONFLICT OR INCONSISTENCY


In the event of any conflict or inconsistency between this Privacy Policy and any non-English language translation thereof, the terms and provisions of this Privacy Policy shall control.


8  CONTACT US


If you have any questions about this privacy policy, please contact us via email at contact@3adao.org.


9  ADDITIONAL DISCLOSURES FOR DATA SUBJECTS IN THE EUROPEAN ECONOMIC AREA AND THE UNITED KINGDOM


9.1 Roles

The General Data Protection Regulations in the European Economic Area and the United Kingdom (“GDPR”) distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). We act as a controller with respect to personal data collected as you interact with the Services.


9.2 Lawful Basis for Processing

The GDPR requires a “lawful basis” for processing personal data. Our lawful bases include where: (i) you have given consent to the processing for one or more specific purposes, either to us or to our service providers or partners; (ii) processing is necessary for the performance of a contract with you; (iii) processing is necessary for compliance with a legal obligation; or (iv) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third parties subject to appropriate or suitable safeguards, such as standard contractual clauses.


9.3 Your Data Subject Rights

If you are a user in the European Economic Area or the United Kingdom, you maintain certain rights under the GDPR. These rights include the right to (i) request access and obtain a copy of your personal data; (ii) request rectification or erasure of your personal data; (iii) object to or restrict the processing of your personal data; and (iv) request portability of your personal data. Additionally, if we have collected and processed your personal data with your consent, you have the right to withdraw your consent at any time.

Notwithstanding the foregoing, we cannot edit or delete information that is stored on a particular blockchain. This information may include transaction data (i.e., purchases, sales, and transfers) related to your blockchain wallet address and any NFTs held by your wallet address.

To exercise any of these rights, please contact us via our email listed in the “Contact Us” section above and specify which right you are seeking to exercise. We will respond to your request within thirty (30) days. We may require specific information from you to help us confirm your identity and process your request. Please note that we retain information as necessary to fulfill the purpose for which it was collected and may continue to retain and use information even after a data subject request in accordance with our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

If you have any issues with our compliance, please contact us at contact@3adao.org. You also reserve the right to lodge a complaint with the data protection regulator in your jurisdiction.


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