Privacy Policy
PRIVACY POLICY OF GREENART COIN
Last Updated: February 23, 2024
Welcome to Greenart Coin!
Greenart Coin Ltd is headquartered in London, United Kingdom. We conduct online
operations worldwide that help to create and provide some of users’ favorite products
and services, including the GAC token, our NFT platform, a dedicated app, and,
coming soon, a video game.
This Privacy Policy describes the various ways we may collect, use, and share
information about, through, or in connection with the Greenart Coin Services (see
“What are Greenart Coin Services?” below). If you have any questions, you can
always contact us as described below in the “Contact” section.
When we refer to “Greenart Coin” (or similar terms, such as “we” or “us”) in this
Privacy Policy, we mean the entity of Greenart Coin that controls and is responsible
for user data, including Greenart Coin Ltd and its affiliates that contribute to providing
and supporting the Greenart Coin Services. You can also find details about the data
controller for the personal data we collect through the various Greenart Coin Services
in the section “Contact” below.
1. WHAT ARE GREENART COIN SERVICES?
We use the term “Greenart Coin Services” to describe any Greenart Coin products
or servicest that directly connect to this Privacy Policy. These include, for example:
the Greenart Coin (GAC) token (also through our partner Bancor Trust Asset
Management sro); websites and applications such as www.greenartcoin.eu,
greenartcoin.eu/marketplace, as well as https://app.greenartcoin.eu/staking;
Please note that the use of Greenart Coin Services may also be subject to additional
terms and conditions. Please read the entire Privacy Policy. Before using such
products or services, you will also need to carefully review any other applicable
agreement for the Greenart Coin Services used, as well as confirm that you have
understood and accepted it.
2. WHAT DATA DO WE COLLECT?
The type of data we collect depends on how you interact with us. In general, we
collect data in three main ways: A) When you provide it to us, B) automatically when
you use Greenart Coin Services, and C) from service providers and third parties.
A. User-provided Data
You may provide us with various types of data depending on how you interact with
Greenart Coin Services. Sometimes, we will ask you to provide specific information,
such as when we need it to provide you with parts of Greenart Coin Services (e.g.,
asking you to provide your date of birth or complete an online registration process).
If we ask you to provide us with information in such cases and you choose not to
do so, you may not be able to access the relevant Greenart Coin Services, and/or
some features may not work as expected. For example, to make purchases on the
Greenart Coin marketplace and to use the app, you need a Greenart Coin account.
To create one, you will need to provide us with basic registration information, such
as your name, a publicly displayed name, a password, the country you live in, and
your email address. If you wish to make a purchase, we may ask you to provide
payment information (such as credit card number and expiration date) to complete
the transaction. Additionally, many of our services require your date of birth to
determine what features we can offer you and what settings to apply to your account
based on your age and location. We also collect data that you voluntarily provide to
us to subscribe to email notifications, use social features like forums or chat, gain
early access to our games, enable two-factor authentication, register for participating
in our events, respond to surveys, or contact us through customer service inquiries.
If you participate in a contest or competitive event, we will collect the data from your
application and any other information we may need to confirm your eligibility and
process payments. We collect any information you choose to provide us in these or
similar cases.
B. Automatically Collected Data
We automatically collect certain data when you visit, access, or use Greenart Coin
Services. This includes information about your use of the application, purchases,
rights, and other activities in Greenart Coin Services, typically associated with your
account (if you are logged into your Greenart Coin account or use a third-party
account to access Greenart Coin Services) or an identifier we have assigned to your
device or profile. While the specific types of data we automatically collect may vary,
they generally include: usage information and statistics on how you interact with
Greenart Coin Services, saved preferences, reports of abnormal stops, URLs of our
websites you have visited, referral and exit page URLs, page views, time spent on a
page, number of clicks, and platform type. Technical information about the computer,
device, hardware, or software you use to access our services, such as IP address,
device identifiers, internet service provider plugins, or other device identification or
transactional information (such as device brand and model, device operating system
and browser information, or other device or system-related specifications) and your
device’s general location, typically derived from your device’s IP address. Greenart
Coin Services use technologies such as cookies, log files, and web beacons to
automatically collect the types of data listed above. Some of these technologies may
create small files or recording tools that can be stored on your device. They help us,
our service providers, and third parties recognize your device and provide information
about how you use and interact with Greenart Coin Services. For example, they
support our ability to authenticate users, remember preferences, manage advertising,
personalize experiences, and conduct data analysis. We want to inform you that some
features of Greenart Coin Services are provided by third parties, who may also use
automated data collection processes and record information about the use of Greenart
Coin Services, their services, or other websites over time. For example, when you
use Greenart Coin Services that include payment gateways, such third-party providers
may collect information through their technology. These features are subject to the
privacy policies of such third parties.
C.Data Collected from Other Sources
In some cases, we may also receive data about you from service providers and third
parties in connection with your use of Greenart Coin Services or your interactions
with us on other platforms. For example, some other developers allow you to use
your Greenart Coin account to access their service. And if you choose to link your
Greenart Coin account with your account on third-party social media platforms,
platforms, or other similar websites or services, or if you interact with an advertisement
for one of the Greenart Coin Services on an external website or service, the company
operating such website or service may share some information with Greenart Coin, in
accordance with that company’s privacy practices. Your privacy settings on that other
company’s website or service generally govern the specific types of data that can be
shared with Greenart Coin, so you should make sure to regularly review and update
those settings. Common examples of shared data for linked accounts may include the
displayed name and user ID of the third-party account, as well as device data and
associated device name, and email address. You may also purchase, download, or
access some Greenart Coin Services on or through third-party managed services. In
such cases, they may provide us with information to facilitate access to and use of
Greenart Coin Services. This typically includes data such as displayed name, user
ID, and device and region information. In this case, the company operating the
platform or service may share with us some information that contributes to purposes
such as user rights.
D. Fraud and Deception Prevention
Providing users with a good, balanced, and competitive experience on Greenart Coin
Services is extremely important to us. We strictly prohibit deceiving, hacking, account
theft, and any other unauthorized or fraudulent activities on Greenart Coin Services.
We use a variety of anti-fraud and fraud prevention technologies to help identify and
prevent harmful activities. These services may collect and analyze data about the
user’s computer and the software installed on the user’s computer in order to detect
fraud and may be provided by Greenart Coin or service providers.
3. HOW DO WE USE THE DATA?
In general, we use the data we collect (individually or in combination with other data
collected as described in this Privacy Policy) to help provide, improve, personalize,
analyze, and promote Greenart Coin Services. The foregoing includes use for purposes
such as:
• Creating, verifying, and managing user accounts and features.
• Providing Greenart Coin Services, as well as related support and assistance,
including responding to information requests, processing transactions or
requests, and communicating with users (e.g., sending messages and service
and account updates).
• Developing, delivering, and improving Greenart Coin Services and other
offerings, some of which may be provided in collaboration with other parties.
• Personalizing the user experience, including by presenting content or features
that are most suitable for the user or their interests or our deductions about
their interests.
• Promoting Greenart Coin Services, including managing, customizing, and
measuring the effectiveness of our advertisements, promotional offers, surveys,
and events.
• Managing alpha, beta, or early access tests (and collecting feedback).
• Conducting data analytics (e.g., analyzing how Greenart Coin Services are
used to better understand, improve, and personalize them).
• Fulfilling our legal or contractual obligations and enforcing our terms.
• Securing Greenart Coin Services, including, among other things, fraud detection
and other types of protection of Greenart Coin and other users from illegal or
harmful actions.
We may also process data that does not identify you as such, including aggregated
or anonymized data created or collected by us or other sources. Such data helps us
better understand larger user groups. If we combine such data with user-identifying
data, we will treat it as described in this Privacy Policy. However, you should be
aware that the Privacy Policy does not limit our ability to process data that does not
identify you, and we may use and disclose aggregated or anonymized data for any
purpose permitted by law.
4. HOW DO WE SHARE THE DATA?
We may share some of the data we collect to help operate and improve Greenart
Coin Services. Depending on how you interact with us, common examples may include
sharing:
• With distributor partners (e.g., to comply with regulatory obligations).
• With other software developers (e.g., to enable features that you purchase
through the Greenart Coin app).
• With other users (if you use social features).
• With the public (e.g., your displayed name, in the case of attribution or prize
winnings related to public initiatives, as proof of winner identification)
• With service providers operating on our behalf to assist with Greenart Coin
Services support in accordance with our instructions (e.g., cloud storage
providers, payment processors, or marketing and advertising partners).
• With Greenart Coin or others when we believe it is necessary to share data
to comply with the law or protect you (e.g., in response to a court order or
injunction, as part of an investigation into fraud or other illegal activity, or the
violation of our terms or policies, or where necessary to protect others from
death or serious harm to people or property).
• In connection with certain types of extraordinary corporate transactions (such
as in the case of a restructuring)
• We may also share data that does not identify you with third parties, including
aggregated or anonymized data.
Mobile phone numbers provided to Greenart Coin for security reasons will not be
shared with third parties or affiliates for marketing/promotional purposes. Third parties
you interact with through the Greenart Coin Services may have privacy practices that
differ from those of Greenart Coin, so please review your privacy policies before
sharing your data with those third parties.
5. MINORS’ PRIVACY
We design Greenart Coin Services to welcome users of all ages worldwide. This
means we collect age information from users, and some of our services will provide
a different experience based on what we know about a user’s age and where they
live. The information below allows parents and guardians to understand our privacy
practices regarding minors (under 16 years of age or the digital consent age in the
user’s region, whichever is higher).
When a user indicates they are a minor, they are placed in a “Limited Account” until
they are no longer a minor as defined above or until the parent or guardian provides
further privacy authorization and enables parental controls. Limited Accounts can view
Greenart Coin services, but functions such as real-money purchases are disabled.
Greenart Coin collects limited personal data from Limited Accounts to manage them,
in each case in accordance with applicable privacy and youth protection laws:
• Date of birth and country to determine age and apply appropriate settings
• Parent or guardian’s email address to provide notification and request consent
for additional features (which is deleted if the parent does not respond within
14 days)
• User’s email address for access (which is stored only in a non-readable hashed
form)
• Persistent identifiers such as IP address, gaming platform account IDs,
necessary website tracking technologies, and device identifiers to provide and
maintain Greenart Coin Services (including analytics to improve them), protect
user security and integrity, ensure legal and regulatory compliance, and facilitate
service customization.
6. USER CHOICES AND CONTROLS
We strive to provide users with meaningful choices regarding the personal data we
collect. The specific options available to you often vary depending on the exact nature
of the relationship you have with us, such as the Greenart Coin Services you use.
Common examples include:
• You can request access, correction, or deletion of personal data we have
collected from you. You can submit requests for access, modification, or
deletion of personal data associated with your Greenart Coin account by
contacting us as described in the “Contact” section. Please note that we may
ask for additional information to help verify your identity before completing your
request.
• You can change your email marketing preferences at any time, for example,
using the opt-out mechanism provided in our marketing emails, updating your
Greenart Coin account settings, or forwarding your request to us (see the
“Contact” section). You can change privacy settings on third-party websites
(such as social networks) or platforms (such as console providers) to limit the
data they can share with us.
• You can change browser or mobile device settings to block, manage, delete,
or limit tracking technologies such as cookies. In some cases, after blocking
or disabling cookies, Greenart Coin Services may not function as expected,
and some features may not be available.
• If you are under 18 years old and have a Greenart Coin account, you can
ask us to remove or anonymize some content you have provided on Greenart
Coin Services. Please direct requests for help with deletion or modification of
content on Greenart Coin Services as described in the “Contact” section.
Some places in the world provide individuals with specific options regarding their
personal data under rights conferred by local law.
7. OUR GLOBAL OPERATIONS
Greenart Coin Ltd is based in the United Kingdom but operates globally to help
provide users worldwide with a better experience on Greenart Coin Services. We have
service providers and partners worldwide to support these operations in various ways.
This means that Greenart Coin may process the data we collect about your use of
Greenart Coin Services in locations outside your region of residence.
A. Data Transfers
When you use Greenart Coin Services, your data may be transferred or stored in the
United Kingdom or other countries where we or our service providers operate. The
data protection laws and regulations of these countries may differ from those of your
country of residence. Where applicable, we rely on various legal mechanisms to help
legitimize data transfers outside the country of collection. If permitted by local laws,
by using Greenart Coin Services, you authorize Greenart Coin to process your data
in any location where we operate (including the United States).
For more information on the Greenart Coin entity responsible for managing the
Greenart Coin Services you use, see the “Contact” section.
B. California Residents
The California Consumer Privacy Act or “CCPA” provides California residents with
certain rights regarding their personal data. If you are a California resident, you may
have the right to: (1) request more information about the categories and specific
personal data we collect, use, and disclose; (2) request the deletion of your personal
data; (3) opt-out of the sale of your personal data; and (4) not be discriminated
against for exercising these rights.
You or your authorized representative may make these requests by contacting us as
described in the “Contact” section. Please note that we may ask for additional
information to help verify your identity before completing your request. If we receive
the request from your authorized representative, we may ask you to provide proof
that you have empowered that person to make requests to exercise rights on your
behalf. We will not discriminate against you if you exercise your rights under the
CCPA.
We collect the following categories of personal information, as described in the CCPA:
• Identifiers (e.g., email addresses).
• Demographic information (such as age).
• Commercial information (including purchase rights or history). Internet or
electronic network activity (e.g., gaming details or website usage).
• Audio, electronic, visual, or similar information (such as voice chat).
• Geolocation information (as may be inferred from your IP address or included
in your billing data).
• Other “personal data” as defined by California law (such as your credit or debit
card data);
• Inferences drawn from any of these categories (e.g., about the types of games
you prefer based on your purchase history).
For detailed information about the data collected under each listed point and the
categories of sources from which we obtained such data, please refer to the “What
data do we collect?” section above. We collect personal data for the business and
commercial purposes described in the “How do we use the data?” section above.
Greenart Coin does not sell or share (as those terms are defined in the CCPA) the
personal data we collect. However, we disclose personal data as described in this
Policy (see the “How do we share the data?” section above). In the last 12 months,
we have disclosed personal data to the following categories of recipients:
• Business partners (e.g., if you ask us to share your email address with a
game developer you purchase on Greenart Coin).
• Other Greenart Coin entities (such as subsidiaries that may help support
certain Greenart Coin Services).
• Other users (e.g., if you use chat or social features on Greenart Coin
Services).
• Service providers (as described in the “How do we share the data?” section
above).
• Operating systems and platforms; and Government entities or other third
parties in response to a legitimate request.
C. Residents of the European Economic Area and Switzerland
If you are located in the European Economic Area (EEA), the United Kingdom (UK),
or Switzerland, you have certain rights regarding how your personal data is processed.
Data Subject Rights
You may have the right to access, correct, or delete the personal data we have
collected about you through Greenart Coin Services. Additionally, you may have the
right to receive a transferable copy of the personal data you have provided, as well
as to object to or limit the processing of your personal data, such as for direct
marketing. Where you have provided consent to the processing of data, you have the
right to revoke it.
You also have the right to lodge a complaint against us by contacting the local data
protection authority (if one exists in your country). However, we would appreciate the
opportunity to address your concerns before resorting to the data protection authority,
so we ask you to first bring your complaint to our attention.
You can refer to the “Contact” section below for further information on how to
contact Greenart Coin regarding any relevant issues. You can find more details
about the local data protection supervisory authority on the following pages:
EEA: https://edpb.europa.eu/about-edpb/board/members_en
UK: https://ico.org.uk/global/contact-us/
Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
Legal Bases for Processing
The legal bases on which we rely to process your personal data depend on the
Greenart Coin Services you use and how you interact with them. They mainly include:
• Contractual necessity: We process personal data to perform the Greenart Coin
Services you have requested based on our Terms of Service or other similar
contractual agreements with you. For example, we process personal data to
set up and maintain your account; process your purchases; authenticate users;
provide user experience-related features (such as saving your preferences);
monitor and analyze Greenart Coin Services; detect and prevent fraud,
deception, or similar abuses; facilitate functions like cross-progression that allow
you to play a game on one platform and carry over your progress to another,
which may require sharing your data with external partners; and contact you
regarding your account, transactions, or other updates. We also rely on the
performance of a contract to manage our relationship with you, which includes
responding to your support requests or general inquiries and notifying you of
changes to our applicable terms or policies.
• Legitimate interests: We process personal data as necessary for Greenart
Coin’s business purposes, weighing the potential impact on your privacy rights.
This includes many common purposes that you might reasonably expect, such
as: communicating with you, responding to your requests or providing you with
updates and information; better understanding our users and their preferences;
personalizing your experience, saving your preferences, authenticating our
users, and providing similar user experience functionalities; developing,
delivering, and improving Greenart Coin Services and other offerings (some of
which may be offered in collaboration with other parties); managing and
personalizing advertising or promotional offers; managing purchases (within
games); ensuring and protecting Greenart Coin Services; preventing fraud and
illegal activities; and supporting internal purposes such as data review and
analysis. To support these operational purposes, we may use machine learning
technologies to help identify harmful, toxic, or fraudulent content in our services.
Content identified by these technologies will be subject to human review.
• Legal obligations: We process personal data when necessary to comply with
legal obligations, such as responding to legitimate requests from law
enforcement or other government officials in accordance with relevant legal
processes or processing date of birth to facilitate compliance with applicable
child protection laws.
• Consent: We process personal data when you provide your consent for us to
do so. You are not obligated to provide your consent if you do not want your
personal data to be processed for the requested purposes, and you may revoke
your consent at any time.
Retention
Since the specific personal data we process and our reasons for doing so often vary
depending on how you use Greenart Coin Services, the duration of their retention
may also vary. Generally, we retain personal data for as long as we reasonably need
it for the purposes described in this Policy (e.g., to fulfill our legal obligations, manage
internal records, enforce our terms, and resolve disputes), unless a longer retention
period is required or permitted by law.
The primary criteria we consider in determining specific retention periods often include
the minimum requirements mandated by applicable law, relevant industry standards,
the types of data involved (such as their sensitivity level), their relevance to potential
disputes or similar proceedings (e.g., to defend against legal claims), and whether the
data is necessary to prevent fraud or similar abuses of Greenart Coin Services
(including enforcing bans against deception and other unauthorized behaviors). For
example, if you create a Greenart Coin account, we generally retain the personal data
associated with your Greenart Coin account for the time necessary to maintain your
account, provide the Greenart Coin Services you requested, enforce the terms
governing your use of Greenart Coin Services, and maintain appropriate records to
reflect how we provide Greenart Coin Services to you.
To learn more about how to request deletion of your personal data from Greenart
Coin, refer to the “User Choices and Controls” and “Data Subject Rights” sections.
8. SECURITY
We maintain administrative, technical, and physical systems adequate to protect
personal data from accidental, unlawful, or unauthorized destruction, loss, alteration,
access, disclosure, or use, and other unlawful forms of processing. In some
circumstances, your data is available once you access a feature we offer. In such
cases, it is necessary for you to safeguard the confidentiality and security of your
user credentials and password to protect your data. If we become aware of
unauthorized disclosure of your personal data, we will inform you as required by law
and take measures to help protect your information.
9. UPDATES
We will update this Policy from time to time to reflect changes in our practices or
relevant laws. When we do, we will change the date noted at the beginning of the
Policy. In some cases, we may also notify you of the relevant changes via email or
within Greenart Coin Services. We encourage you to review this Policy regularly to
ensure you understand your relationship with Greenart Coin and the ways in which
we may collect, use, and share information in connection with Greenart Coin Services.
10. CONTACTS
For questions or concerns about Greenart Coin Services (e.g., game-related issues,
problems accessing your Greenart Coin account, bugs or other technical issues,
payment issues, or content and rights-related problems), please contact the Support
team. You can find more information on submitting support requests for products and
services to:
Greenart Coin: [email protected]
Bancor Trust Asset Management: [email protected]
If you would like to learn more about our privacy practices or this Policy, you can
email us your inquiries about products and services to:
[email protected]
You can also contact us by mail by sending correspondence (addressed to “Attn:
Legal Department”) to Greenart Coin Ltd, located at 27 Old Gloucester Street –
London, WC1N 3AX United Kingdom.