Privacy Policy

Last updated: 15 February 2022

GENERAL TERMS

These terms apply to the use of the SOTA sp. z o.o. (“SOTA”) services and as further detailed below. Our registered office is at Warsaw, Srebrna 16 / 204, Poland, company number 5272939018

This privacy policy (“Privacy Policy”) applies and has effect in respect of our website and related content and our related services, activities and features (the “Services”, each a “Service”).

This Privacy Policy explains the basis on which personal data we collect from you will be processed by us or on our behalf. Where we decide the purpose and means for which personal data you supply through this Service is processed, we are the “controller” for the purposes of the General Data Protection Regulation 2016/679 (“EU GDPR”).

Please read this Privacy Policy carefully as it contains important information about the following:

  • What information we may collect about you;
  • How we will use information we collect about you;
  • Whether we will disclose your details to anyone else; and
  • Your choices and rights regarding the personal data we hold about you.

This Privacy Policy should be read in conjunction with our Terms as may be applicable in respect of the Service. Where Terms are applicable, they will be made available via the Service.

The Service may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal data that you submit or which is collected by cookies and other tracking technologies whilst using these services.

We do not accept any responsibility or liability for the privacy practices of such third-party services and your use of these is at your own risk. For information about our cookie practices, please see paragraph 4 and our Cookie Policy.

We may make changes to this Privacy Policy in the future, which will be made available here. You should check here from time to time to ensure you are aware of any changes. Where appropriate, we may notify you of changes by email or through the Service.

 

INFORMATION WE MAY COLLECT ABOUT YOU

We may collect and process the following personal data from you (the “Services Information”):

Information that may be provided by you when creating a Service account (“Submitted Information”)

  • Your Etherum (ETH) Wallet Address; and Technical Information relating to the wallet interface.

Information that may be provided by you when you contact us for support (“Support Information”)

  • Your full name; Your email address; and

Information about your activities (“Technical and Usage Data”)

We may collect technical and usage information about your use of our Service through tracking technologies and analytics collection in our Services. Personal data we may collect in this way includes:

  • IP address;
  • Geolocation information (i.e. longitude and latitude);
  • Service user ID (a unique ID that we generate which identifies Service users);
  • Device information (such as your device ID, operating system and version, device brand, device family, model and manufacturer);
  • Mobile network carrier (if applicable);
  • Country, market and region information;
  • Language;
  • Error and crash data (identifying a Service crash event);
  • Events related to your Service usage, such as achievement of a milestone and the occurrence of other events during your Service usage (such as virtual currency balance, session durations and your choices and progression for and in different parts of the Service).

Analytics and profile information (“Analytics and Behavioural Data”)

We may collect, or create by analysis of other Services Information, analytical information in connection with your Service usage including without limitation:

  • When you first launched / began using the Service;
  • Whether you use our free Services, or whether you use paid-for Services and how much you spend;
  • Whether you discovered our Service organically, or whether you discovered the Service through an advertising campaign;
  • What your Service usage habits are (for example, whether you use the Service in a particular way or only use a part of the Service and how often you use it); and o We may associate your account with a user segment group which we think have shared characteristics, such as perceived interest in a particular type of gameplay or particular parts of our Services.

 

WHY WE COLLECT INFORMATION ABOUT YOU

To provide the Service to you to attribute your ETH wallet to the correct account

We will process Submitted Information about you to provide our Service to you under the Terms agreed between us.

To prevent money-laundering and other illegal activity

We process your Submitted Information for the purpose of ensuring that the funds held in the ETH wallet do not present a risk of money-laundering.

To respond to your enquiries and requests for support

We may process certain of your Services Information (including your Support Information and certain other Services Information which might be relevant) so that we are able to properly respond to your enquiries and support requests, in accordance with the Terms of Use agreed between us.

 

COOKIES

A cookie is a text file placed onto your device when you access our Services. We use cookies in the following ways: authentication (to log you into our Service and keep you logged in); preferences (to remember information about your preferences such as your preferred language and configuration), analytics (to help us understand how you use our Services, such as how often, so we can improve Services and deliver a better experience and also for us to carry out research and statistical analysis to help us develop new products and services), advertising (to help
us deliver in-Service advertising to you (which may be served by, or facilitated by, third parties).

The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your device such as your advertiser ID, IP address, your browser and/or other internet log information, this will not usually identify you personally.

Please note that if you choose to disable cookies, or similar technologies, on your device you may be unable to make full use of our Services or may not have the same quality of experience.

We may work with third parties who may also set cookies and equivalent technologies on our Services, for example: Google Analytics, Google AdWords, YouTube, Facebook, Twitter and LinkedIn, which we use to display video content, enable social networking functionality and sharing, and to monitor how visitors use our Services.

 

DATA SHARING

We will share your information with third parties only in the ways that are described in this Privacy Policy.

Group members, personnel, suppliers or subcontractors from time to time: We keep your information confidential but may disclose it to any member of our group, our personnel, our advertising and analytics service providers and our other suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information and have agreed to safeguard it.

Required by law: We may disclose your information to the extent that we are required to do so by law, in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights.

Third party suppliers: we will share your Submitted Information with third-party suppliers based in the UK, for the purposes of running checks to seek to prevent money- laundering and other  illegal activities.

 

AUTOMATED DECISION MAKING

We may use automated decision-making methods which do not involve human involvement to process your information and shall do so only in the ways that are described in this Privacy Policy.

 

MARKETING INFORMATION

In the event we wish to process your personal data for marketing purposes and where not otherwise detailed in this Privacy Policy, we will obtain your prior consent to process your personal data before doing that where we are required to do so by law. In each relevant instance, if you prefer that we do not process your personal data in that way, you can let us know by simply using the relevant consent options, buttons or similar choices we provide to you at the relevant time. You can also withdraw your consent (or, if applicable, ‘opt-out’) at any time by letting us know by email to team@bysota.com

 

YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

You have the following rights over the way we process personal data relating to you.

Ask for a copy of personal data we are processing about you and have inaccuracies corrected or request erasure. You have the right to request a copy of the personal data we hold about you and to have any inaccuracies corrected. You can request a copy by emailing team@bysota.com

Object to us processing personal data about you:

You can ask us to restrict, stop processing or delete your personal data if:

  • you consented to our processing the personal data and have withdrawn that consent;
  • we no longer need to process that personal data for the reason it was collected;
  • we are processing that personal data because it is in the public interest or it is in order to pursue our legitimate interest or the legitimate interest of a third party,
  • you don’t agree with that processing and there is no overriding legitimate interest for us to continue processing it;
  • the personal data was unlawfully processed;
  • you need the personal data to be deleted in order to comply with legal obligations; and/or
  • the personal data is processed in relation to the offer of a service to a child.

You can request account deletion by sending an email to team@bysota.com

Obtain a machine-readable copy of your personal data, which you can use with another service provider

If (i) we are processing personal data in order to perform our obligations to you or because you consented and (ii) that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.

If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

Make a complaint to a Supervisory Authority

If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.

If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority. Contact  information for the Information Commissioner’s Office, the Poland’s independent authority setup to uphold information rights, is available here: https://uodo.gov.pl/.

 

DATA RETENTION

In accordance with data protection laws and good commercial practice, we do not retain data in a form that permits identification of the person(s) to whom it relates for any longer than is necessary.

 

CHILDREN

We takes the protection of the personal data of children very seriously. In the event that we learn that we have collected personal data from a child other than as intended in accordance with this Privacy Policy, we will delete that information as quickly as possible.

 

SECURITY

We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Service, taking into account the likelihood and severity those risks might pose to your rights and freedoms.

Please be aware that, while we make the security of our Service and your personal data a high priority, no security system can prevent all security breaches.

Unfortunately, the transmission of information via the internet is not completely secure. We do our best to protect your personal data, but we cannot always guarantee the complete security of your data transmitted through our Service; subject to applicable law, the sharing of your personal data with us and any transmission of the data is at your own risk.

 

INTERNATIONAL TRANSFERS

The data we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff that operate outside the EEA and work for us or our suppliers. These staff may be engaged in the fulfilment of your orders, the processing of your payment details, the maintenance of the Service, and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Where your personal data is transferred outside of EEA to a territory not subject to an adequacy decision by the European Commission, we have agreements in place with the relevant parties which include either (i) standard data protection clauses adopted by the relevant data protection regulator and approved by the European Commission or (ii) standard data protection clauses adopted by the European Commission, to ensure that appropriate safeguards are used to protect your personal data, together with other appropriate safeguards to protect your personal data. If you require more information about these safeguards, you can contact us at team@bysota.com

 

CONTACT

All questions, comments or enquiries should be directed to us at team@bysota.com

We will endeavor to respond to any query or questions within a reasonable amount of time.

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