Last updated: April 15, 2023
Welcome to the club3.xyz website (hereinafter referred to as "Club3" or "this website"). This website is provided by club3 Co. Ltd. (hereinafter referred to as "we" or "our").
This website is not intended for children, and we do not intentionally collect data related to children.
2.Who we are
Club3.xyz Ltd, registered in Singapore, is the data controller (we or our company). This means we are responsible for deciding how to hold and use the personal information you provide when interacting with the website and services.
The accuracy and timeliness of the personal data you provide is very important to us. If your personal data changes during our relationship, please inform us promptly.
"Digital Assets" means digital assets (also known as "virtual financial assets", "convertible virtual currencies", "cryptocurrencies", "virtual currencies", "digital currencies", or "digital NFT goods"), such as Bitcoin or Ethereum, which are based on cryptographic protocols of a computer network, which can be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value.
”Personal Data" means any information about an individual, either alone or in combination with other information, that can identify that person directly or indirectly, such as your name, email address, username, contact information, identification number, location data, online identifiers (such as IP address and device ID), or one or more factors specific to your physical, economic, cultural, or social identity.
4.We Collect Data About You
Personal Data or Personal Information means any information about an individual from which that person can be identified (personal data). It does not include data that has been deleted of identifying details (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data, including: Identity data includes:
User-related: Your wallet address;
Club creator-related: Your wallet address, your full name, your identification card or passport.
Contact data includes your name, email address, or phone number, which we may collect if you contact us at any time.
Transaction data includes your wallet address related to users and creators, which may be linked to personal data when you use our services, as well as any information about your purchases and sales.
Technical data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technical information about the device you use to access our website and/or services.
Profile data includes profile photos and/or banners of users and creators, as long as you decide to upload a photo of yourself.
Usage data includes information about how you use our website and services.
Marketing and communication data includes your marketing preferences and communication preferences, including those you receive from us and third parties.
We do not collect any special categories of personal data about you (including details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also do not collect any information about criminal convictions and offenses.
4.5.If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you at the time.
5.How is your personal data collected?
We collect information about you through various methods, including:
Direct interactions. You may provide us with your identity, contact, and transaction information, as well as personal profile data, by creating an account (Account) on our Services and using our Services to interact with us. This data is associated with your blockchain address when you connect your wallet to our Services. This includes personal data that you provide when you:
apply for our Services;
create an account on our website;
request to receive marketing materials;
give us feedback or contact us.
Third-party or publicly available sources.
We may receive personal data about you from various third-party and public sources, including:
as a user, we receive transaction data (i.e., your wallet address) from creators to allow you to purchase NFTs from their collections;
transaction data obtained from public blockchains.
6.How do we use your personal data?
We will only use your personal data where we are permitted to do so by law. The most common reasons we use your personal data include:
Where we need to perform a contract we are about to enter into or have entered into with you;
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
Where we need to comply with a legal obligation;
The purposes for which we will use your personal data.
We have listed all the ways we plan to use your personal data, and the legal bases we rely on to do so, in a table format. Where appropriate, we have also identified our legitimate interests.
Please note that we may carry out more than one lawful basis for processing your personal data depending on the specific purpose for which we are using your data. If there are multiple bases listed in the table below and you require further information about the specific legal basis we are relying on, please contact us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.
While you access Club3, we may use the industry practice of placing a small amount of data that will be saved by your browser (Cookies). This information can be placed on your computer or other devices used to visit Club3. This information help us recognize you as a customer, collect information about your use of Club3 to better customize our services and better your experience. We may also use the information collected to ensure compliance with our compliance program, and to ensure your account security has not been compromised by detecting irregular or suspicious account activities.
Most browsers are setup to accept cookies automatically. Some Cookies expire when you finalize the session and other Cookies remain on your computer or other devices until deleted or expired. You have the option to decline the use of our Cookies, but this may affect the functionality of Club3 services or your user experience.
Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to employees, agents, contractors, and other third parties who have a need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulatory authorities where we are legally required to do so.
How long will we keep your personal data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including satisfying any legal, regulatory, tax, accounting or reporting requirements. If we reasonably believe there is a prospect of litigation in respect of our relationship with you, we may retain your personal data for a longer period in the event of any such complaint.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9.Collection and Transfer of Data Outside of the European Economic Area
As mentioned above, we may collect personal data from customers located in the European Economic Area. In order for us to provide services to customers in the European Economic Area, we require explicit consent from customers to transfer personal data from the European Economic Area to outside that region. If you are an individual located in the European Economic Area and refuse to consent to such terms, you will no longer be able to use Club3 and our services. You will be able to withdraw your digital assets and fiat currency; however, all other functionalities will be disabled.
10.Access, Correction, and Deletion of Your Personal Data
You have the right to request a copy of your personal data and to determine whether the information we hold about you is accurate and up-to-date. If any of your personal data is inaccurate, you may request that we update your information. You may also request the deletion of your personal data, but we may refuse your deletion request in certain circumstances, such as for legal requirements or other legal purposes. For data access, correction, or deletion requests, please contact email@example.com with the subject line "Data Inquiry."
In order to respond to data access, correction, or deletion requests, we will verify the identity of the requester to ensure they have the legal right to make such requests. While our goal is to respond to these requests free of charge, we reserve the right to charge reasonable fees if your request is repetitive or onerous.
Customers may choose to opt-out of these marketing communications at any time. If you do not wish to receive these communications, please email firstname.lastname@example.org.
For important product-related information such as policy/terms updates and operational notifications, you will not be able to opt-out of receiving such information.
12.Contacting Club3 about Privacy Questions or Concerns
For EEA customers, you have the right to request that any unresolved questions regarding the collection, use, or disclosure of your personal information be compliant with the requirements of the supervisory authority applicable in your jurisdiction.