Otherside Townhall Privacy Policy

This Privacy Policy is designed to help you understand how Yuga Labs, Inc. (“Yuga Labs”, “we,” “us,” and “our”) collects, uses, and shares your information and to help you understand and exercise your privacy rights.

1. SCOPE
2. CHANGES TO OUR PRIVACY POLICY
3. PERSONAL INFORMATION WE COLLECT
4. HOW WE USE YOUR PERSONAL INFORMATION
5. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
6. YOUR PRIVACY CHOICES AND RIGHTS
7. SECURITY OF YOUR PERSONAL INFORMATION
8. INTERNATIONAL DATA TRANSFERS
9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
11. CHILDREN’S INFORMATION
12. THIRD-PARTY’S WEBSITES/APPLICATIONS
13. SUPERVISORY AUTHORITY
14. CONTACT US

1. SCOPE

This Privacy Policy applies to personal information processed by us in connection with Yuga Labs’ “Otherside Townhall” experience (the “Experience”) via the website located at https://launch.otherside.xyz/, and any site you are directed to from such site (the “Site”).

The Site will be hosted by third-party server host and development partner, Improbable Worlds Limited (“Improbable”). For more information on how Improbable processes data collected on our behalf, please review Improbable’s Privacy Policy at https://www.improbable.io/privacy-policy.

This Privacy Policy does not apply to other Yuga Labs websites, mobile applications, and any other online or offline offerings owned or controlled by Yuga Labs that post a link to the Yuga Labs Privacy Policy, located at https://yuga.com/privacy.

2. CHANGES TO OUR PRIVACY POLICY

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Experience on our Site after the new Privacy Policy takes effect.

3. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, the Experience on our Site, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Site, and information from other sources such as third-party services and organizations, as described below.

A. Personal Information You Provide to Us Directly

We may collect the following personal information that you provide to us.

• Account Creation.

  We may collect personal information when you create an account with us or our service providers (e.g., Shopify), such as name, phone number, time zone, and email address. We may also collect additional personal information, such as your shipping address if you purchase merchandise from us.

• Purchases, Wallet and Transaction Information.

  In order to engage in certain transactions or purchases on the Services, you may need to provide us or our third-party payment processors with your payment information and allow us to connect to your digital wallet by providing us with your public wallet address. We will never ask you or collect your private keys. We do not directly collect or store any payment card information entered through our Services or access your digital wallet, but we may receive from our third-party payment processing providers information associated with your payment card information (e.g., your billing details). We may also collect your name, the name of the recipient, email address, the currency and the date as part of the transactions taking place on the Services.

• Supplemental Identity Verification Information.

  In order to support Yuga’s legal and regulatory compliance efforts, Yuga may engage third-party identity verification vendors (such as Quadrata and Persona) in order to verify your identity. These vendors may ask you to submit or request access to your mobile device’s camera to collect photographs and/or videos, government-issued identity documents, e.g. passport, driver’s license, or state identification card, Social Security number, employment information (e.g. company name), or proof of residency, including visa information, and may also perform a live facial scan and capture other biometric information generated based on photos or videos.

• Any collection of biometric information or identifiers is handled by our vendors, and we do not collect, access or store any biometric information or identifiers through our Services. We may receive the results of identity verification checks from our vendors, but these results do not contain any biometric information or identifiers. For more information about Quadrata’s or Persona’s collection, process, and retention of your personal information (including biometric information and identifiers, please review their respective policies: https://quadrata.com/privacy and https://withpersona.com/legal/privacy-policy. You may withdraw your consent and ask for your biometric information to be deleted by Quadrata by sending a request to [email protected], or to Persona at [email protected], or as otherwise specified in Quadrata’s and Persona’s privacy policies.

• Voice Information

  When participating in the Experience, you will have the option of commenting live on the Site. As long as your username does not include any personal information, we will not have any way of using your voice to identify you.

• Your Communications with Us

  We may collect personal information, such as email address when you request information about our Site or otherwise communicate with us regarding the Experience.

• Interactive Features

  We and others who use our Site may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, and blogs). Any information you provide using the public sharing features of the Experience or the Site will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.

• Social Media Platforms

  Our Site may contain social media buttons, such as Discord, Twitter, and Instagram, which might include widgets such as the “share this” button or other interactive mini programs. These features may collect your IP address and which page you are visiting on our Site and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

B. Personal Information Collected Automatically

• Automatic Collection of Personal Information

  We may collect certain information automatically when you use our Site, such as your IP address, browser or device information, and location information (including approximate location derived from IP address). We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.

• Usage Information

  We (or our third-party server host, Improbable Worlds Limited (“Improbable”)) may also automatically collect information regarding your use of our Site, such as the types of content you interact with on our Site, the frequency and duration of your activities, and other information about how you use our Site.

• Crash Reports

  If you provide crash reports, we may collect personal information related to such crash reports, including detailed diagnostic information about your device and the activities that led to the crash.

• Cookies and Other Technologies.

  We, as well as third parties that provide content or other functionality on our Services, may use cookies, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.

• Analytics.

  We may use tools to process analytics information on our Services. These technologies allow us to process usage data to better understand how our Services are used, and to continually improve our Services.

• Social Media Platforms.

  Our Services may contain social media buttons, such as Discord, Instagram, and Twitter, which might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address and which page you are visiting on our Services and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs may not be effective on mobile applications.

C. Personal Information Collected from Other Sources

• Third-Party Sources.

  We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Site through a third-party application, such as a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings for such third-party application.

4. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a number of business purposes, including to provide our Site and the Experience, for administrative purposes, as you may consent from time to time, and in de-identified and/or aggregated form, each as described below.

A. Provide Our Site

We use your personal information to provide you with our Site and enable you to participate in the Experience, such as (but not limited to):

• Managing your information;

• Providing access to certain areas, functionalities, and features of our Site;

• Answering requests for customer or technical support;

• Communicating with you about activities on our Site, and policy changes;

• Allowing you to register for events.

B. Administrative Purposes

We use your information for our legitimate interests, such as:

• Research and game development, network and information security, and fraud prevention;

• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

• Measuring interest and engagement in our Site;

• Improving, upgrading or enhancing our Site;

• Developing new products and services on the Site;

• Ensuring internal quality control and safety;

• Debugging to identify and repair errors with our Site;

• Auditing relating to interactions, transfers and other compliance activities;

• Sharing information with third parties as needed to provide the Site;

• Enforcing our agreements and policies; and

• Other uses as required to comply with our legal obligations.

C. With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

D. Other Purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

• De-identified and Aggregated Information.

  We (or Improbable) may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified location information, information about the device from which you access our Site, or other analyses we (or Improbable) create.

5. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your information to third parties for a variety of business purposes, including to provide our Site, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, each as, and as otherwise, described below.

A. Disclosures to Provide our Site

The categories of third parties your information may be shared are described below.

• Other Users of the Experience and Parties You Transact With.

  Some of your personal information may be visible to other users of the Experience (e.g., if you choose to share a personally identifiable username).

• Third Party Websites and Applications.

  You may choose to share personal information or interact with third-party websites and/or third-party applications, including, but not limited to, social media sites and third-party electronic wallet extensions. Once your personal information has been shared with a third-party website or a third-party application, it will also be subject to such third party’s privacy policy. We encourage you to closely read each third-party website or third-party application privacy policy before sharing your personal information or otherwise interacting with them. Please note that we do not control, and we are not responsible for the third-party website’s or the third-party application’s processing of your personal information.

• Service Providers

  We may share your personal information with our third-party service providers who use that information to help us provide the Experience, such as Improbable. This includes service providers that provide us with IT support, hosting, customer service, content moderation, and related services.

• Business Partners

  We may share your personal information with business partners to provide you with the Experience and other related products and services. We may also share your personal information to business partners with whom we jointly offer products or services.

• Affiliates

  We may share your personal information with members of our corporate family.

• APIs/SDKs

  We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Site. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosures to Protect Us or Others

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, or a due diligence process related to any of the foregoing, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

6. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Rights. In accordance with applicable law, you may have the right to:

• Access Personal Information

  about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; or (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (aka the right of data portability);

• Request Correction

  of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;

• Request Deletion of your personal information;

• Request Restriction of or Object

  to ours or our service providers’ processing of your personal information,including where the processing of your personal information is based on our legitimate interest; and

• Withdraw Your Consent

  to our processing of your personal information.Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests to the extent required by applicable laws.

7. SECURITY OF YOUR PERSONAL INFORMATION

We take steps designed to ensure that your information is treated securely and in accordance with this Privacy Policy.Unfortunately, no system is 100% secure, and we cannot ensure the security of any information you provide to us. To the fullest extent permitted by applicable law, we expressly do not represent, warrant or other guarantee the security of any information you provide to us, and disclaimer all liability for unauthorized disclosure.

By using our Site or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Site, by mail or by sending an email to you.

8. INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. Without limiting Section 7, we endeavor to safeguard your information consistent with the requirements of applicable laws.

9. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use our Site or as necessary to fulfill the purpose(s) for which it was collected, provide our Site, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

10. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Yuga Labs has collected about them and whether Yuga Labs disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information we Collect” and “How We Use Your Information” above, respectively.

“Sales” of Personal Information under the CCPA. For purposes of the CCPA, Yuga Labs does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Additional Privacy Rights for California Residents

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth in “Contact Us” below.

Verification. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the email address associated with any personal information we have about you. If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

11. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us as set forth in “Contact Us” below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

12. CHILDREN’S INFORMATION

The Experience and the Site are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information without your consent, you may contact us as set forth in “Contact Us” below. If we learn that a child has provided us with personal information in violation of applicable law, we will promptly take steps to delete such information, unless we have a legal obligation to keep it.

13. THIRD-PARTY’S WEBSITES/APPLICATIONS

The Site may contain links to other websites/applications and other websites/applications may reference or link to our Site. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

14. SUPERVISORY AUTHORITY

If you are located in the European Economic Area, Switzerland, or the United Kingdom you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

15. CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at [email protected].