PRIVACY AND COOKIE POLICY

(Last updated January 2024)

INTRODUCTION

Who are we?

Soccerverse Limited (“Soccerverse”, “we”, “us”, and “our”) is a company incorporated in the United Kingdom with company number 13940239 and registered office 71 QUEEN VICTORIA STREET, LONDON, EC4V 4BE. Where we decide the means or purpose of processing personal data, we are the "controller."

What’s this policy about?

This policy explains how we process your personal data as a data controller when you visit our website at soccerverse.io or make use of the Soccerverse game (together, the “Services”). We update this policy from time to time so please check back in.

How do you contact us?

(if you have questions about this policy or to exercise your rights)

Write to us at: [email protected]

If we can’t resolve your issue, you can also get in touch with the Information Commissioner’s Office: https://ico.org.uk/concerns(or if you live in a European country outside the UK, you can submit a complaint to the supervisory authority in your country).

What are your rights?

You have the following rights, although these rights may be limited in some circumstances:

  • Ask us to send a copy of your data to you or someone else
  • Ask us to restrict, stop processing, or delete your data
  • Object to our processing of your data
  • Object to use of your personal data for direct marketing
  • Ask us to correct inaccuracies
  • If we rely on consent to process data, or send direct marketing, you can withdraw consent by email to the address above.

    2. HOW WE USE PERSONAL DATA

    2.1 Personal data

    Beta Registration Data

    Our Services may be offered as a closed or open beta, in which case only certain players can participate. To control access to the beta, we may ask you to register an account with us, in which case we may collect:

  • name;
  • email address; and
  • your wallet address.
  • How long we keep it

    We store this data for up to 6 years after our relationship with you ends. However, data published to the Ethereum blockchain will be available perpetually.

    How we use it

    We process this information to control who can participate in our beta Services.

    In particular, we collect name and email addresses to send invitations to the beta. If you are accepted, we include your wallet address in a public “whitelist” on the blockchain which is then used by our software to decide which wallets are treated as players in the game.

    Legal basis

    We process this information in accordance with the terms of our contract with you (where we need this information to provide you Services under a contract) or to take steps at your request prior to entering into a contract.

    We also use this information to pursue our legitimate interests in monitoring and controlling access to our beta and other in-development Services.

    More information

    You may be required to provide us with certain information in order to participate in beta projects

    Sources and recipients

    Sources

  • We collect this information from you
  • Recipients

  • We may store your wallet address on a public blockchain.
  • 2.2 Personal data

    Game Data

    We monitor transactions on the Ethereum blockchain including:

  • sender and recipient wallet addresses; and
  • the type and content of transactions (including what tokens are sent, how many, and meta data and messages attached to those transactions) which includes, without limitation, the username you choose for your account..
  • How long we keep it

    We only store this data temporarily while our server software is running, for as long as necessary to deliver our Services. The underlying data is however stored perpetually on the public Ethereum blockchain.

    How we use it

    These transactions, including details of the sender, recipient and their content (including what tokens are sent, how many, metadata & messages attached to transactions) are monitored and interpreted by our software.

    Our software treats transactions and the associated information as actions within a decentralised game. For example, wallets are interpreted as players, if a wallet sends a particular message to another wallet with a message attached, that message might be interpreted as meaning that the first player has agreed to send an in-game item to the second player.

    Our software gathers historical transaction data to calculate what the state of the game is at any particular time.

    When players connect to our software, it may send them information about the state of the game, so they can view it in their browser.

    We may also analyse this data to understand how users play the game, & how we can improve it.

    Our software may help you to carry out transactions, such as through metamask functionality enabling you to send tokens to a particular destination, where that transaction may later be interpreted by our software as you purchasing game items.

    However, we are not a party to or in control of those transactions, we do not directly receive personal data about you when you carry out transactions, and instead we simply provide software which you can use to interact with the public blockchain.

    Legal basis

    We process this personal data to pursue our legitimate interests (and the legitimate interests of users) in delivering our online decentralised game, improving the game and fixing problems with our software.

    Sources and recipients

    Sources

    None, we only process this information within our business.

    2.5 Personal data

    Analytics

    (data about how you interact with our website which might (but may not always) be associated with a unique ID) including:

    • browser type and version, IP address, approximate location and time zone, access logs, device type and settings, operating system, & other information provided by browser or device; use you make of our Services, including the URLs and content you visit, actions and clickstream to, through and from our website, date and time, page response times, errors, length of visits to website pages, interaction (such as scrolling, clicks and mouse-overs) data, details of the website which directed you to our website.
    • use you make of our Services, including the URLs and content you visit, actions and clickstream to, through and from our website, date and time, page response times, errors, length of visits to website pages, interaction (such as scrolling, clicks and mouse-overs) data, details of the website which directed you to our website.

    How long we keep it

    After 26 months underlying data is deleted, but we may retain anonymous, aggregated statistics generated from that data.

    How we use it

    We use our Services and Google Analytics to collect data about visitors to our website, to understand how many people visit, where they come from, and how they interact with our Services and website, and to help us improve and maintain our website and Service.

    Marketing data

    Sources and recipients

    Legal basis

    Legal basisWe may process website analytics data which uses cookies or similar technologies with your consent (if you give it).

    If we undertake analytics without storing or accessing information on your device (for example by reviewing log information on our servers which explain how our website or Service have been used) then we do this in pursuit of our legitimate interests in understanding how people use our Service, and improving them.

    More information

    You can find out more about how Google uses data by reviewing their privacy policy here.

    You can withdraw your consent for Google analytics by using the following link: Google Analytics.

    Sources

    We use Google’s services to collect this data and otherwise collect it from you.

    Recipients

    Google in the USA collects and process analytics data on our behalf.

    Where explicit retention periods are not described above, we hold data for as long as necessary bearing in mind the purpose for which it was collected. To determine the appropriate period, we consider the amount, nature, and sensitivity of the data, the potential risk of unauthorised access, and legal requirements

    3. COOKIES, ANALYTICS AND SIMILAR TECH

    Cookies, pixels and other technologies store and access data on devices to help websites and apps work. This table explains their purpose, how long they last, and who else can access their data. We get consent to use them unless they are essential to the Services.

    Most browsers allow control over cookies, for more information: Google Chrome | Microsoft Edge | Mozilla Firefox | Microsoft Internet Explorer | Opera | Apple Safari.

    Cookie/data: Google Analytics Duration: 8 hours

    Purpose: To track user behaviour on the website and improve site performance.

    Access: We use Google Analytics. and you can access their privacy policy here.

    4. TRANSFERS AND DISCLOSURE

    Transfers

    Your data is generally stored by us in the UK or European Economic Area. Where we use data processors outside the UK and European Economic Area and transfer personal data to a country which does not provide an adequate level of protection, we use contracts approved by the Information Commissioner’s Office and/or European Commission which give personal data protection similar to that which it has in the UK or Europe. For more information drop us a line using the contact details at the start of this policy.

    Disclosure

    Other than as set out above, we may disclose your personal data:

    • Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies).
    • With members of our corporate group, suppliers and subcontractors, as necessary for the purposes set out in this policy.
    • With members involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.ers of our corporate group, suppliers and subcontractors, as necessary for the purposes set out in this policy.

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