Privacy Policy

Last Updated: September 7, 2023

Introduction

Jadu respects your privacy, and we are committed to protecting it through this Privacy Policy.

As used in this Privacy Policy, "Jadu", "we", "us", or "our" refer to Jadu AR Inc., and its subsidiaries.

This Privacy Policy describes the types of personal information we collect from you, that we may receive from third parties or your contacts or that you may provide when you use (a) Jadu's applications for mobile devices (the "Jadu Apps"), (b) Jadu's web domains and subdomains, including jadu.ar (our "Sites") and (iii) any function on the Jadu Apps or Sites for viewing and downloading 2D & 3D files and submitting grant proposals related to Jadu's Digital Collectibles. We refer to the content and functionality of the Jadu Apps and the Sites, as our "Service". We refer to the Jadu Apps and the Sites together as the "Platform."

Please familiarize yourself with our privacy practices and contact us as described below in Section XVI – Contacting Jadu if you have any questions.

This Privacy Policy applies to the personal information we collect:

  • Through the Service; and
  • By e-mail, text, and other communications between you and us and/or the Service.

It does not apply to information collected by any third party (including but not limited to our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Platform.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will handle your information. If you do not agree with our policies and practices, you agree not to use the Service.

Changes to Our Privacy Policy

This Privacy Policy may change from time to time so please check this Privacy Policy periodically for updates.

If we make material changes to how we treat our users' personal information, we will notify you through a notice in the Platform. The date this Privacy Policy was last updated is identified at the top of the first page of this Privacy Policy. You are responsible for ensuring you periodically visit this Privacy Policy to check for any changes.

I. Information We Collect and How We Collect It

Personal Information We Collect

When we talk about personal information (or personal data) we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance. The personal information we may collect and process about you within the last twelve (12) months include:

  • Registration Data/Identifiers : First name, last name, phone number or email address

  • Identity Data : date of birth; gender; country; nationality

  • Usage Data: Details of your visits to and actions on the Platform, including traffic data, location data, logs and other communication data, the resources that you access, and your use of the Platform.

  • Technical Data/Networking Activity: including:

    • Information about your computer or device and internet connection, including as applicable, your IP address through which you access the Platform, operating system, browser type, mobile network information, location, time zone and/or telephone number, the unique mobile device ID or virtual unique device identifier for any mobile device used to access your account;
    • Metadata and other information associated with files stored on your device;
    • Information about your internet connection, the device you use to access the Platform, and related usage details.
  • Profile Data: Interests and preferences

  • App Profile data: Your username, your avatar, your scores.

  • Your Connections data : You can use the contact upload feature and provide us, if permitted by applicable laws, with the phone numbers in your address book on a regular basis, including those of users of our Services and your other contacts.

  • Interactions data:

    • Records of your correspondence (including e-mail addresses and social media contact details), if you contact us.
    • Information that you provide by filling in forms on the Platform, for example to subscribe to our newsletter, respond to surveys or enter a contest or promotion, or to report an issue.
  • Transaction data:

    • Details of transactions you carry out through the Platform using in-game currency.
    • Payment information, collected and processed by our payment provider.
    • Your crypto wallet address.
  • Marketing and Communications data – marketing preferences; service communications preferences including any permission that you give to send you push notifications through our App.

How we collect your personal information

We may collect and receive your personal data using different methods:

  • Personal data you directly provide to us

You may give us your personal data directly, for example, when you use our Site or register to use our App, contact us with enquiries or feedback; or subscribe to receive our marketing communications.

  • Personal data received from third parties

We may receive personal data about you from third parties. Such third parties may include your contacts who have shared their contacts lists with us when using the App or third parties that provide technical services to us so that we can provide our Platform.

  • Automatic Data-Collection Technologies

When you access and use our Platform we will collect certain Usage data and Technical data.

The automatic data collection technologies we use to collect this data may include:

  • Cookies (or pixel tags and other similar technologies browser cookies). A cookie is a small file placed on the hard drive of your computer or device. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Platform.
  • Web Beacons. The Platform and our e-mails may use small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

You may also control the information that we collect through the settings in your browser or mobile device. You may configure your browser to reject cookies from Jadu and may adjust the settings of your mobile device to prevent the Platform from obtaining location information. However, please note that the Service may rely on cookies and location information to function properly and some parts of the Service may not be available if you disable cookies.

II. How We Use Your Personal Information

We use personal information that we collect about you or that you provide to us for the purposes set out in this section. If we wish to make any changes to these purposes, or if we wish to use your personal data for any purpose that is not listed in this section, we will notify you using the contact details we hold for you.

PART A: PROVISION OF THE SERVICE

Purpose: To provide our Site

DescriptionCategories of dataLegal bases
If you browse our Site: When you browse our Site, we collect and process your personal data to help us understand how you are using and navigating our Site.

We do this so that we can better understand which parts of our Site are more or less popular and improve the structure and navigation of our Site.
Usage Data

Technical Data/Networking Activity
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Services, or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to our Site in a secure and effective way and so that we can make improvements to our Site.
Website insight and analysis: We and our third-party partners use cookies to collect data from the devices that you use to access our Site.

We and our third-party partners use this data to analyse how you use our Site and our Services and the effectiveness of our Site and Services, including:
  • to analyze how you use, and the effectiveness of, our Site and Services;
  • to count users who have visited our Site and collect other types of information, including insights about visitor browsing habits, which helps us to improve our Site and Services;
  • to measure the effectiveness of our content;
  • to learn what parts of our Site are most attractive to our users, which parts of our Site are the most interesting and what kind of features and functionalities our visitors like to see;
  • to help us understand the type of marketing content that is most likely to appeal to our visitors and customers.
Usage Data

Technical Data/Networking Activity

Profile Data
Where we use personal data collected through the use of analytics cookies to analyse how you use our Site, it is in our legitimate interest to use your personal data in such a way to improve our Site and Services.

Purpose: To provide our App

DescriptionCategories of dataLegal bases
Provision of our App: When you use our App, we process your personal data so that we can provide our App to you, including to ensure that our App is working properly, to show you the correct notices and information, and to ensure that our App is kept secure. This data is sometimes automatically collected and transmitted to us.

When you use our App, we may also ask for your permission to send you push notifications. If you allow this feature, we may send you push notifications though our App, for example, reminders, alerts, updates and other information. You can configure and turn off push notifications via your device settings at any time.

Our App may also send us (or our IT suppliers) an error message in the event of a crash or other error (e.g. after the App has unexpectedly quit because of a program error or has stopped responding to your input). The error message contains Technical Data and information about which part of the App's software code has caused the error. This information helps us understand the cause of the error so that we can develop a fix to prevent that error from reoccurring and therefore improve the App for all users.
Technical Data/Networking Activity

Marketing and communications data
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to our App in a secure and effective way.

Our use of push notifications will be subject to the permissions that you provide and your system settings.
To manage your account registration and access to the App: You will be required to register an account with us in order to gain access to the App.

To register for an account, you will need to provide all required personal data and a password. We will use this data to process your registration and to identify you when you log in to your account and access the App.

We will also process certain Communications Data so that we can administer and contact you about your account, including by email or push notification.

We will also ask you for Your Connections in order for you to connect with your existing contacts on the App. If any of your contacts aren't yet using our Services, we'll manage this information for you in a way that ensures those contacts cannot be identified by us. We will also give you the option to 'invite' Your Connections to the App.

We will also take a scan of your room for the purposes of determining what features are available to you in the App. We will not process your image data when we do this.
Registration Data/Identifiers

App Profile Data

Marketing and Communications Data
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to our App in a secure and effective way.

Where we process Your Connections data, it is in our legitimate interest to use personal data in such a way to ensure that we provide access to our App in a secure and effective way.
To manage your App account profile and enable you to interact with other players: If you are a registered user of the App you can voluntarily submit and we will collect Profile Data as part of your App profile. Your App profile will be publicly available and we will use your personal data to provide you with App features such as the ability to challenge other players and be displayed in a leaderboard.

We will also use your personal data to store information about you and your preferences, allowing us to customize the Service according to your individual interests and recognize you when you return to the App.
Usage Data

Technical Data/Networking Activity

Profile Data
Any Profile Data that you submit is voluntary, although you are required to supply some Profile Data as a part of interacting with and using the App. It is in our legitimate interest to use your Profile Data, so that we can provide our App effectively.

Purpose: Customer feedback/enquiries

DescriptionCategories of dataLegal bases
If you have a general question or need help with any issue concerning our Platforms: There are various ways in which you are able to contact us with general enquiries and to provide feedback, including using the details set out in the Contacting Jadu section XVI, via support@jadu.ar and through any other 'contact us' or similar feature that we make available on our App.

When you make an enquiry or provide feedback, we will collect and process your personal data including any personal data you volunteer, that is relevant to your enquiry or feedback.

If you have a technical issue concerning our Online Services, we may also process Technical Data to help us diagnose and fix the technical issues you are experiencing.

We will use this information so that we can effectively manage and respond to your enquiry or feedback.
Registration

Data/IdentifiersProfile Data

Interactions Data

Technical Data/Networking Activity
It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry and provide a good standard of service.

PART B: ADVERTISING/MARKETING

DescriptionCategories of dataLegal bases
Online personalized marketing: We and our third party partners may use your personal data including data that is collected through your interactions with third party websites and services (including social media and other platforms) to provide you with, and analyse the effectiveness of, personalized ads when you visit other websites and/or use other services.

By "personalized ads", we mean advertisements for the App which we or our partners otherwise think you might be interested in based on your browsing habits. Note, our third party partners may also use the data that is collected to show personalized ads for products and services offered by third parties.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioural tracking). Contact us at general@jadu.ar for information on how you can opt out of behavioural tracking on the Platform and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioural tracking.
Usage Data

Technical Data/Networking Activity
Where your data is collected through the use of non-essential cookies, we and our third party partners generally rely on consent to collect your personal data and for the subsequent processing of it in this manner or it is otherwise in our legitimate interests to promote our Site and our Products and Services to you.

Our third party partners may rely on a different lawful basis in respect of their use of your personal data.
Email marketing: We use your to send you marketing communications by email. Our marketing will include press releases and information about us, our Platforms and Services, any events we may hold and the offers and promotions we offer from time to time.

Our marketing communications will include personalized and non-personalized marketing. Personalized marketing has been specifically tailored to you and will include content that we think is most relevant to you, based on what we know about you. Non-personalized marketing is marketing that is not tailored to you.
Registration Data/Identifiers

Marketing andCommunications Data

Personalized marketing:
Profile Data
App Profile Data
Transaction Data
Usage Data
It is in our legitimate interest to use your personal data for marketing purposes, for example to decide what marketing content we think may appeal to you.

However, we will only send marketing communications to you by email where you have consented to receive such content by email, or where we have another lawful right to send marketing to you using email. For example, in certain circumstances we may rely on our legitimate interest to send marketing by email to individuals who are users of our App.
Hosting and managing events: From time to time, we may organize and host events for the purpose of promoting our business or bringing our App users together. We may process your personal data to communicate with you about such events where you have specifically requested information about such events or where we have another lawful basis for sending that information to you.

If you attend one of our events, we may use your personal data to record your attendance at the event and for related record-keeping purposes and, if relevant, we may collect and process any dietary requirements you may have. You may also feature in photographs taken at our events and such photographs may appear in publications that we make available.
Registration Data/Identifiers

Profile Data

App Profile Data
It is necessary for us to use your personal data in this way to perform our obligations in accordance with any contract that we may have with you where you have signed up to attend an event, or it is in our legitimate interest or a third party's legitimate interest to use personal data in such a way to ensure that the event is operated in an effective way.

We may specifically ask your permission to use your photographs, quotes, testimonials, or other content that you make available or publish at the event. Where this is the case, our processing of your such personal data will be based on consent.
DescriptionCategories of dataLegal bases
Recruitment: We use your personal data for recruitment purposes, in particular, to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third-party recruitment agency on your behalf. We also use your personal data to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.

We will process any personal data about you that you volunteer, including during any interview, when you apply for a position with us. We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees.

We also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.
Registration Data/Identifiers

Identity Data, details of your education, qualifications and employment history, any other personal data which appears in your curriculum vitae or application, any personal data that you volunteer during an interview or your interactions with us, or any personal data which is contained in any reference about you that we receive. Such information may also include special categories of personal data (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.
Where we use your personal data in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions.

We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
Receipt of service: If we have engaged an organization to provide us or our client with services (for example, IT support or financial advice), we will collect and process your personal data if you are a contact within the relevant organization in order to manage our relationship or our clients with the organization, to receive services from the organization and, where relevant, to provide our services to others including our customers.Registration Data/IdentifiersIt is necessary for us to use personal data in this way to perform our obligations in accordance with any contract that we may have with the organization, or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with the organization and are able to provide our services to others in an effective way. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Business administration, finance, and legal compliance: We may use an individual's personal data for the following business administration and legal compliance purposes:
  • to facilitate the operation or effective management of our group of businesses;
  • for financial, accounting and tax purposes;
  • to comply with our legal obligations;
  • to enforce or protect our legal rights;
  • to deal with complaints;
  • to protect the rights of third parties (including where health or security of an individual is endangered (e.g. a fire); and
  • in connection with a business transition or sale such as a merger, re-organization, acquisition by another company, or sale of all or a portion of our assets.
Registration Data/Identifiers

Transaction Data

Interactions Data
It is necessary for us to use personal data in this way to perform our obligations in accordance with any contract that we may have with the organization, or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with the organization and are able to provide our services to others in an effective way. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.

III. How Long We Keep Your Information

We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or, where applicable law provides for longer storage and retention periods, for the storage and retention period required by law. After that your personal information will be deleted.

In respect of personal data that we process in connection with the supply of our Services, we may retain your personal data for up to six years from the date of supply of the relevant Services and in compliance with our data protection obligations. We may then destroy such files without further notice or liability.

Where we process personal data in connection with the registration and use of an account on our App, we may retain your personal data for up to six years from the date that the relevant account is terminated (and in compliance with our data protection obligations). We may then destroy such files without further notice or liability.

Where we process any other personal data, we will retain relevant personal data for up to three years from the date of our last interaction with you (and in compliance with our data protection obligations). We may then destroy such files without further notice or liability.

If any personal data is only useful for a short period (e.g. for a specific activity, promotion or marketing campaign), we will not retain it for longer than the period for which it is used by us.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future. However, we will not use this personal data to send you further marketing unless you subsequently opt back in to receive such marketing.

IV. How We Share Your Information

We may disclose aggregated information about users, and information that does not identify any individual, without restriction.

We may also disclose personal information that we collect or you provide as described in this Privacy Policy:

  • To our subsidiaries and affiliates;
  • To contractors, service providers, and other third parties we use to support our business and/or the Service and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To third party post/email marketing and CRM specialists who assist us in managing our marketing database and sending out our email marketing communications and account related communications
  • To third party advertising partners when you use our Site. This data is used to provide you with, and measure the effectiveness of, online personalized advertising and for other advertising related activities.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Jadu's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Jadu about Platform users is among the assets transferred.
  • To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To auditors, lawyers, accountants and other professional advisers;
  • From time to time, to other third parties for any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including responding to any government or regulatory request.
  • To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, security or safety of Jadu, our customers, or others, or to address technical issues. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Service may then be inaccessible or not function properly.
  • Promotional Offers from Jadu. If you do not wish to have your contact information used by Jadu to promote our own or third parties' products or services, you can opt-out by sending us an e-mail stating your request to general@jadu.ar. If we have sent you a promotional e-mail, you may out by opt out by using the "unsubscribe" link in the email. This opt-out does not apply to information provided to Jadu as a result of a product purchase, warranty registration, product service experience or other transactions.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You may opt out of receiving targeted ads from members of the Network Advertising Initiative on their website.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

V. Children's Privacy

The Service is not intended for children under the age of thirteen (13). If you are under thirteen (13) years of age, do not use or provide any information on the Platform.

If we learn we have collected or received personal information from a child under thirteen (13) without verification of prior parental consent, we will delete that information. If you believe we may possess or have received any information from or about a child under thirteen (13) without such prior parental consent, please immediately contact us at general@jadu.ar.

In one or more countries outside the United States, the applicable age is fourteen (14) years of age, rather than thirteen (13) years of age.

California residents under sixteen (16) years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights below for more information.

VI. How We Protect Your Information

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, theft, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have issued you (or you have chosen) a password for access to certain parts of our Service, you are responsible for keeping your password confidential. Please do not share your password with anyone.

We do not and will not, at any time, request your credit card information, your login information or other identification in a non-secure or unsolicited communication (such as e-mail).

Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or on our Service. Any transmission of personal information is at your own risk. You assume this risk by using any part of the Service. We are not responsible for circumvention of any of our privacy settings or security measures, and/or any damages resulting from such circumvention.

VII. How You May Change, Remove, Or Export Your Information

Accessing and Correcting Your Information

You can review and change your personal information by sending us an e-mail at general@jadu.arto request access to, object to, correct or delete any personal information that you have provided to us.

We may not accommodate a request to change information if we believe the change would violate any law or legal requirement, or cause the information to be incorrect.

If you delete your user content, copies of your user content may remain viewable in cached and archived pages, or might have been copied or stored by other users. Proper access to and use of information, including without limitation user content, is governed by our Terms of Service.

You may e-mail us at general@jadu.ar to request that we delete your personal information from our database. For such requests, please write "delete my personal information" in the subject line, and include your first and last name and e-mail address in the body of the message. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for administrative purposes.

Please note that we will store communications you may send through the Service, as well as any comments you may post, and they may not be subject to modification or deletion.

Please note, similar rights will apply in the UK, EEA and Switzerland. Please see the Privacy section for users from the EEA. UK and Switzerland for further information.

The Service may contain links to other websites and online services, including third-party advertisements. If you choose to click through to one of these other websites or online services, please note that any information you may provide will be subject to the privacy policy and other terms and conditions of that website or service, and not to this Privacy Policy. We do not control third-party websites or services, and fact that a link to such a website or service appears in the Service does not mean that we endorse its or its provider, or have approved the provider's policies or practices related to user information.

Before providing any information to any third-party website or service, please review the privacy policy and other terms and conditions of that website or service. You agree that Jadu will have no liability for any matters relating to a third-party website or service that you provide information to, including their collection and/or handling of that information.

IX. Non-U.S. Users

When we refer to the term "GDPR" in this Privacy Policy we mean the European Union General Data Protection Regulation. Information that you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. If you are located outside the United States, you understand that we may transfer personal information to and process it in the United States. If you are located in the UK, EEA or Switzerland please note that your personal information may be transferred outside of the UK, EEA or Switzerland. Your consent to this Privacy Policy together with your submission of personal information constitute your agreement to these transfers. Please see the Privacy section for users from the EEA, UK and Switzerland for further information.

X. Privacy section for users from the UK, EEA and Switzerland

By continuing to use our Platform you acknowledge that your data will be processed in accordance with this Privacy Policy.

A. Data Controller

For the purposes of this Privacy Policy, Jadu AR Inc is the Data Controller of your personal information.

B. International transfers of personal data

Non-UK/EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. However, when transferring your personal data (that originates from the UK, EEA or Switzerland) outside the UK, EEA or Switzerland, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.

When transferring your personal data outside the UK, EEA or Switzerland, we will, where required by applicable law, implement at least one of the safeguards set out below. Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK, EEA or Switzerland.

  • Adequacy decisions: We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and/or the UK/Swiss Government (as applicable).
  • Model clauses: Where we use certain service providers, we may use specific standard contractual clauses approved by the European Commission and/or the UK/Swiss Government which give personal data the same protection it has in Europe, Switzerland and/or the UK.

C. Rights of EEA Residents

If you are accessing or using the Platform from within the UK, EEA or Switzerland you may have the following rights under the GDPR (as well as other rights). If you wish to exercise any of these rights, you may do so by contacting us as provided (a) in the "Contact" link below, (b) in Section XIV below, or (c) otherwise in this Privacy Policy.

  • Right of Access: You have the right to obtain confirmation from us as to whether or not we process personal information from you and you also have the right to at any time obtain access to your personal information stored by us.
  • Right to Correction of your Personal Information: If we process your personal information, we use reasonable measures to ensure that your personal information is accurate and up-to-date for the purposes for which your personal information was collected. If your personal information is inaccurate or incomplete, you have the right to require us to correct it.
  • Right to Deletion of your Personal Information or Right to Restriction of Processing: You may have the right to require us to delete your personal information or to restrict of processing of your personal information.
  • Right to Withdraw your Consent: If you have given your consent to the processing of your personal information, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on the consent before the withdrawal.
  • Right to Data Portability: You may have the right to receive the personal information concerning you and which you have provided to us, in a structured, commonly used and machine-readable format or to transmit this data to another controller.
  • Right to Object: You may have the right to object to the processing of your personal information as further specified in this Privacy Policy.
  • Right not to be subject to automated decision making and profiling: You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
  • Right to Lodge a Complaint with Supervisory Authority: You have the right to lodge a complaint with your relevant data protection supervisory authority located in the European Union. If you are located in the EEA, further information about how to contact your local data protection authority is available at the website of the European Commission. If you are located in the UK the regulatory authority is the Information Commissioner's Office ("ICO"). Contact details for the ICO can be found on its website at https://ico.org.uk.

D. If you fail to provide your personal data

Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the Services you have requested from us or to process an application to register an account. In these circumstances, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.

XI. Your California Privacy Rights

A. Shine the Light

If you are a resident of California, USA resident and user of the Service, you have specific rights regarding our handling of your "personal information" as specifically defined in California's "Shine the Light" law (Cal. Civil Code Section § 1798.83). This law permits users of our Service who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to general@jadu.ar or write us at: Jadu AR Inc., c/o Gamma Law, PO Box 136, San Francisco, California 94104-0136.

Within thirty (30) days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for such third parties' direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. A request may be made no more than once per calendar year and we are not required to respond to requests made by means other than through the e-mail address and mailing address above.

B. Your Rights Concerning California Personal Information

You have certain rights in connection with the collection of your personal information as a resident of California. You may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

  1. The right to know the categories and specific pieces of personal information we collect, use, and disclose about you; the categories of sources from which we collected personal information about you; our purposes for collecting or selling personal information about you; the categories of personal data about you that we have either sold or disclosed for a business purpose; and the categories of third parties with which we have shared personal data.

  2. The right to request deletion of your personal information we have collected and retained about you. We may deny your request for deletion if retaining the information is necessary for us or our affiliates to:

    1. Complete the transaction for which we collected the personal information and provide the service that you requested;
    2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for such activities;
    3. Comply with legal obligations; or
    4. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  3. The right to correct inaccurate personal information. Upon verifying the validity of a verifiable consumer correction request, we will use commercially reasonable efforts to correct your personal information as directed, taking into account the nature of the personal information and the purposes of maintaining your personal information.

  4. The right to opt-out of the sale of your personal information. As the terms are defined under the California Privacy Rights Act (the "CPRA"), we do not sell your personal data.

  5. The right To Opt-out of sharing of your personal information. As the terms are defined under the CPRA, we do not share your personal information for cross-context behavioral advertising purposes.

To make such a request, please send an e-mail to general@jadu.ar or write us at: Jadu AR Inc., c/o Gamma Law, PO Box 136, San Francisco, California 94104-0136.

We will not discriminate against you for exercising any of these rights above.

You may designate an authorized agent to submit requests on your behalf by designating such an agent in writing. We may require the agent to provide us with proof that you have authorized the agent to make requests on your behalf prior to accepting requests from the agent.

We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.

XII. Your Virginia Privacy Rights

If you are a Virginia resident, you have certain rights under the Virginia Consumer Data Protection Act (the "VCDPA"). These include the right to (i) confirm whether or not a controller is processing the personal information and to access such personal information; (ii) correct inaccuracies in the personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information; (iii) deletion of personal information; (iv) obtain a copy of the personal information that previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means; and (v) opt out of the processing of the personal information for purposes of targeted advertising, the sale of personal information, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

If you wish to exercise your rights under the VCDPA, please contact us by email at the email address provided in the "Contacting Jadu" Section XVI below. If we refuse to take action on the request, you may appeal by sending an email to us at the email address above. You may submit a complaint to the Attorney General at https://www.oag.state.va.us/consumercomplaintform.

We will not discriminate against you for exercising any of these rights under the VCDPA above.

XII. Your Connecticut Privacy Rights

If you are a Connecticut resident, you have certain rights under the Connecticut Data Privacy Act (the "CTDPA"). These include the right to (i) know and see what personal information we have collected; (ii)request that we delete the personal information we have collected, subject to applicable legal exceptions; (iii)request that we correct inaccurate personal information; and (iv) opt-out of targeted advertising and the sale of personal information as defined under the CTDPA.

As the terms are defined under the CTDPA, we do not sell personal information.

If you wish to exercise your rights under the CTDPA, please contact us by email at the email address provided in the "Contacting Jadu" Section XIV below. If we refuse to take action on the request, you may appeal by sending an email to us at the email address above.

You may designate an authorized agent to submit requests on your behalf by designating such an agent in writing. We may require the agent to provide us with proof that you have authorized the agent to make requests on your behalf prior to accepting requests from the agent.

XIV. Your Colorado Privacy Rights

If you are a Colorado resident, you have certain rights under the Colorado Privacy Act (the "CPA"). These include the right to (i) know and see what personal information we have collected; (ii)request that we delete the personal information we have collected, subject to applicable legal exceptions; (iii)request that we correct inaccurate personal information; and (iv) opt-out of targeted advertising and the sale of your personal information as defined under the CPA.

As the terms are defined under the CPA, we do not sell personal information.

If you wish to exercise your rights under the CPA, please contact us by email at the email address provided in the "Contacting Jadu" Section XVI below. If we refuse to take action on the request, you may appeal by sending an email to us at the email address above.

You may designate an authorized agent to submit requests on your behalf by designating such an agent in writing. We may require the agent to provide us with proof that you have authorized the agent to make requests on your behalf prior to accepting requests from the agent.

XV. Disclosure Of User Account and Crypto Wallet Information

YOU ACKNOWLEDGE AND AGREE THAT YOUR PERSONAL INFORMATION, USER ACCOUNT INFORMATION, AND RELATED CRYPTO WALLET ADDRESS MAY BE SHARED WITH AND/OR SOLD TO THIRD PARTIES, MADE PUBLICLY VISIBLE AND/OR APPEAR AS PART OF ETHEREUM OR ANY OTHER APPLICABLE BLOCKCHAIN NETWORK WHEN YOU ENGAGE IN NFT SALES, ACTIVITIES AND/OR TRANSACTIONS THROUGH THE SERVICE. THE FOREGOING DISCLOSURES MAY BE MADE FOR PURPOSES RELATED TO FACILITATING THOSE ACTIVITIES AND/OR TRANSACTIONS, INCLUDING WITHOUT LIMITATION MAKING PAYMENTS TO JADU. TO THE FULLEST EXTENT ALLOWED BY LAW: (A) YOU ASSUME ALL RISK RELATED TO YOUR NFT ACTIVITIES AND/OR TRANSACTIONS; AND (B) JADU WILL NOT BE LIABLE TO YOU FOR ANY LOSSES OR LIABILITIES RELATED TO THE FOREGOING USES AND DISCLOSURES.

XVI. Contacting Jadu

If you have any questions, inquires, requests, comments or complaints concerning this Privacy Policy or our information practices, please contact us at general@jadu.ar or by regular mail at the following address: Privacy Officer, Jadu AR Inc., c/o Gamma Law, PO Box 136, San Francisco, California 94104-0136.