Privacy

This is the Privacy & Cookies Policy (the 'Policy') of Playmint Limited('Playmint'). This Policy describes the ways in which Playmint collects and uses information about you when you visit Playmint's website at www.playmint.com or any website in connection with any of its games (each a 'Game'), including at https://downstream.game/ (each a 'Website' and together the 'Websites'). This Policy also describes the ways in which Playmint collects and uses information about you when you play any Game.

Playmint may change this Policy at any time and when this happens we will notify you of any changes to this Policy by [noting this on the applicable Website]. The changes will apply to your use of such Website and the applicable Game after we have notified you. If you do not wish to accept the new Policy you should stop using such Website and playing such Game. If you continue to use such Website and play such Game after the changes, your continued use of that Website and your continued playing of that Game shows us your agreement to be bound by the new Policy.

For the purposes of data protection legislation, Playmint is the controller for the processing of your personal data. Playmint has notified the Information Commissioner's Office (“ICO”) of its processing of personal data. The notification indicates what data is processed by Playmint and for what purpose, and to which persons or entities the data will be provided. Playmint's registration number is pending.

1. What Personal Data is and Who this Policy applies to: Personal Data means information that identifies, relates to, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household, including identifiers such as a real name, alias, a device identification number, location data, an online identifier, commercial information (including products or services purchased), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, or as further defined under the General Data Protection Regulation ('GDPR') and the California Consumer Privacy Act ('CCPA') (as applicable). We indicate in this Policy the information we collect from you.

2. Visitors to any of the Websites: The Game's Website collects information from you using cookies for the limited purposes set out in TABLE ONE below to collect certain analytical/technical information. Playmint relies on consent to collect this information, such consent obtained via you clicking to agree to such cookies being placed when you first visit such Website. Playmint's Website does not utilise any cookies.

3. People who play a Game: Playmint will collect the following information from you when you play any Game:

a. your Usage Data;
b. loot token number, being the unique number used to identify your Loot NFT (as defined in our Terms of Service); and
c. your Ethereum address.

Your 'Usage Data' can include your approximate location, your browser type and version, the pages you visit, time and date of your visit, time spent on each page, unique device identifiers and other diagnostic data.

4. Grounds for processing: Playmint relies on the contractual necessity processing ground to collect the information in 3(b) and (c) above (as you cannot play a Game without providing this information), and the legitimate interests processing ground to collect the information set out in paragraph 3(a) above. Playmint uses such information for the purposes of providing access to, and allowing you to play, the Game in question. Where Playmint relies on legitimate interests, it is in Playmint's legitimate interests to do so as such data is minimal in nature, is required in order for Playmint to analyse and improve its Games and the collection of such information does not outweigh an individual's rights and freedoms in doing so.

5. Sharing information with third parties: Playmint will not pass your information to third parties other than as described in this paragraph. Playmint may, subject to its obligations to comply with applicable data protection legislation, share your information with third parties including:

a. its server providers, such as [];
b. the third parties who assist Playmint in collecting the Usage Data being Google Analytics (as listed below) and Big Query;
c. in relation to the sale of some or all Playmint's business, or its assets, to any third party, or as part of any business restructuring or reorganisation, but Playmint will take steps with the aim of ensuring that your privacy rights continue to be protected;
d. in anonymised form with data aggregators and service providers as part of an analysis; or
e. with law enforcement agencies in compliance with law enforcement.

6. Security, Storage and Data Retention: Playmint has implemented technology and policies to safeguard your privacy from unauthorised access and improper use. Playmint's physical servers are operated by third party cloud service providers and are located worldwide including in the EEA and USA. Where such information is transferred outside the EEA, Playmint has taken steps to ensure that its agreements with such third party providers contain provisions ensuring the adequacy of such transfer. Playmint ensures that it does not retain such data for longer than is reasonable in line with the purposes for which it was originally collected.

7. Contact details: If at any time you would like to contact Playmint about your views on this Policy or any enquiry relating to your personal information, including but not limited to your rights under the GDPR and/or CCPA (as applicable), you can do so by sending an e-mail to us at privacy@playmint.com or write to us at 36 Frederick Place, Third Floor, Brighton, England, BN1 4EA. This is Playmint's registered address and we are a company incorporated in England and Wales with company number 13481541. You also have the right to make a complaint to the ICO by contacting them here at any time.

8. Exercising your rights: You can contact us using the details set out in paragraph 12 above if you wish to: (i) access a copy of the personal data that we hold about you including what categories of personal data we have collected or sold about you; the categories of sources from which the personal data is collected by us; the business or commercial purpose for collecting or disclosing the personal data; the categories of third parties with whom we share your personal data; and the specific pieces of personal data that we have collected about you); (ii) correct any items of personal data that we hold about you; (iii) have any items of personal data that we hold about you erased or object to our processing of such items of personal data; and/or (iv) if applicable pursuant to the CCPA, receive a free copy of your personal data within 45 days of your verifiable request in a structured, commonly used and machine-readable or commonly used electronic format on request.

Playmint may ask you to verify your identity before Playmint responds to such requests. Please note that under the CCPA, Playmint is not required to delete information that is necessary to perform certain actions as outlined in the CCPA (e.g. to complete a transaction for which the information was collected or to provide the goods or services requested by you). You will not be discriminated against in retaliation for exercising the above rights and rights under the CCPA.

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