Last Updated October 2023
Tribally ("Tribally Studios Ltd”) understands the importance of protecting your personal information and is committed to being a responsible custodian of the information you provide to us and the information We collect.
This privacy and online notice (“Notice”) sets out how and why We collect and use your personal information and your rights in relation to your personal information, when you interact with us whether via the Tribally Games (whose domain names include but are not limited to www.tribally.games) Site accessible at www.tribally.games (“Website”), or any website of ours that links to this privacy notice through the use of our online services or platform, or otherwise.
In this Notice the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out under “Information collected through the use of cookies and similar technologies”, below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003; and
“Group Company” means the Company, its subsidiaries, affiliates or holding companies from time to time and any subsidiary of any holding company from time to time.
This Privacy Notice applies to all Personal Information processing activities carried out by Us across platforms, all websites, and departments of the company.
This Privacy Notice applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
To the extent that you are a client or user of Our services, this Privacy Notice applies together with any terms of business and other contractual documents, including but not limited to any agreements We may have with you.
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
We know how important privacy and safety are to you, that is why in this Notice We explain what rights you have, which of your data We collect and why, and how We use it, so you can be sure it is safe with Us. Please note that we collect your data primarily as part of the registration process of your user account and when you are visiting Our Website. We have created this Notice in order to explain to you the rules of using Our platform and Our Website. This Notice should be read in addition to our Terms & Conditions.
In some scenarios the Company any Group Company will be acting in the capacity of data controller and in others as data processor. This Notice applies when We act in the capacity of data controller of your personal information processed in connection with using Our Site, our online services or platform and through the offering of Tokens.
In addition, We may share your personal data within our group of companies, including Tribally Ltd and Tribally Games Limited (collectively known as “Tribally Affiliates”). This may also include parents and our ultimate holding companies, affiliates, subsidiaries, joint ventures, business units and other companies that We acquire in the future after they are made part of Tribally Affiliates, who will use your personal data for the purposes described in this Notice. Annex 1 contains details of Tribally Affiliates.
Please read the following carefully to understand our practices around your personal information. If you do not wish for your personal information to be used in the manner described within this Notice, you should not access our Website and all subdomains, utilise our services or participate in the offering of Tokens or otherwise provide Tribally Games with your personal information.
Please note the following:
Unless otherwise defined within this Notice, terms used have the same meaning as in the Terms & Conditions.
We do not knowingly collect or ask for data, including personal information, from people under the age of 18. If you are under the age of 18, please do not send us your data. We delete data that We learn is collected from a person under the age of 18 without verified parental approval.
Your privacy is important to us, so We have developed this Notice to explain how We manage and look after your personal information. In this Notice We will specify what data We collect, where does it come from and what rights do you have in relation to it.
The EU General Data Protection Regulation (“GDPR”) provides individuals with several rights including right of access to their personal information, called a “Data Subject Access Request” (“DSAR”) as well as right to rectification, erasure (right to be forgotten) restriction, objection and data portability.
We refer in this Notice to “personal information” and “personal data”. This refers to personal data as defined in GDPR, namely data that directly identifies an individual (for example, name, address and contact details, or also that which indirectly identifies an individual with less obvious identifiers, such as website cookies and internet protocol (IP) addresses, device ID or other online identifier). Tribally Games processes a wide range of personal data about its customers, players, agents, staff, suppliers and other third parties.
Personal data We collect is processed in accordance with the law, only for specified, legally permitted purposes.
We make every effort to ensure that the data collected by us is substantively correct and adequate in relation to the purposes for which it is processed and stored in a form that allows identification of persons to whom it relates, no longer than it is necessary to achieve the purpose of processing. We also maintain the security and confidentiality of the personal data collected.
The data collected by us is processed, stored and may be transferred to any country within the European Union.
Visiting and using our Site is associated with the need to collect and process your personal data.
We process your personal data, in particular, the data you provide us with directly when setting up and verifying your account with us (this is the data you enter on the registration forms provided by us and the data contained within the documents you send to us) and the data you generate using our Services offered by through Our Site (e.g. creating your profile/ opening an account/creating your gaming profile etc).
Depending upon your use of Our Site, We may collect and hold some or all of the personal and non-personal information set out in the list below, using the methods also set out in the list. Please also see below for more information about Our use of Cookies and similar technologies. We do not collect any personal information relating to children.
We will gather information that you willingly provide to us when you sign up for our Services, express your interest in receiving information about Our products and services, engage in activities such as registering as a user of Our platform, or otherwise when you get in touch with us.
The Personal Information You provide about yourself: The type of personal data We gather varies depending on how you engage with us and Our services, the decisions you make, and the specific products and features you utilise. This personal data may include the following:
Our services provide you with the option to register and sign in as a user by using the credentials from your third-party social media accounts. This third-party social media account information may include any of the following;
As part of the Private Sale of Our Tokens You may be required to submit documents and personal information as part of Our Know Your Client (KYC) or Know Your Business (KYB) process. The requirements are set out in more detail in the process, and may be subject to additional requests by Us. However, by way of example, We may collect the following sensitive information from you:
We will exclusively use the information We receive for the specific purposes outlined in this privacy notice or as explicitly communicated to You within the relevant Services. It's important to recognise that we do not have authority over, nor accept responsibility for any alternative uses of your personal information by third-party social media providers. We strongly advise you to examine their privacy notice in order to gain insight into how they collect, employ, and distribute your personal information. Additionally, you should explore the options available to you for configuring your privacy preferences on their websites and applications.
The Non-personal information that We collect is based the the high-level methods as detailed in the below:
We need to collect such a wide range of information not only to be able to provide our Services, but also to fulfil legal requirements regarding the obligation to identify the client, to monitor, combat and assess the risks of fraud, money laundering and financing terrorism. Therefore, if you do not provide the data requested during the registration and verification process, or if the data provided proves to be false or inaccurate, or if you object to its processing, We will not be able to continue to provide you with our Services.
Due to the above-described obligations, in order to verify the accuracy of the data provided by you and to assess the risk of fraud, We also monitor your transaction history by analysing the course, volume, currency and type transactions.
In addition, if you use Our Website, We may collect additional information from you. This may include your personal information (including copies of your identity documents, your residential address and contact details) and your IP address.
If you wish to use additional Services offered by us, We will process your data which We collect in order to provide our Services, in compliance with their description contained in the Terms and Conditions or provided to you separately. These Services may include among others: newsletters, contests, updates , giveaways and
We may also collect information that you voluntarily provide to us, such as when you communicate with us via email, on social media or via other channels, when you register for our updates and when you respond to our communication or requests for information. The information you provide may include your name, contact information, title and other personal information about you.
By accessing our Website, we may also automatically collect certain data from your browser, including server log information (such as login details, IP address and details on the time spent on various pages on our Website) and device and browser information (such as the type of device, universally unique identifiers (‘UUID’), advertising identifiers (‘IDFA’), type of browser, operating system, hardware and processor information, plug-ins and add-ons).
When you visit Our Site, we place and access certain first-party Cookies on your device (e.g. computer hard drive, mobile phone). First-party Cookies are those placed directly by Us andare used only by Us and are small text files that are placed on your device by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the Website so they can improve its functionality and performance. For example, to enable the Website to load quickly, making it easier to move between different pages and remembering you have been shown a one-off message.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than Us. Third-party Cookies are used on Our Site for analytics purposes. For more details, please refer to the list below. These Cookies are not integral to the functioning of Our Site but your use and experience of Our Site may be impaired by refusing consent to them.
We use Cookies to remember your preferences and settings, to remember information that you may enter online, to generate aggregate statistics about how people use our Services, to help you share content with others and to improve your experience of the Services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
Before Cookies are placed on your computer or device, you will be shown a pop up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however the features of Our Site may not function fully and you may not be able to continue using Our Site as intended.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the list below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following first-party Cookies may be placed on your computer or device:
Name of Cookie | Purpose | Strictly Necessary |
---|---|---|
_ga | Google Analytics | Yes |
_gid | Google Analytics | Yes |
and the following third-party Cookies may be placed on your computer or device:
Name of Cookie | Provider | Purpose |
---|---|---|
bm_sz | Mailchimp | Functionality Cookie placed by Mailchimp |
ak_bmsc | Mailchimp | Functionality Cookie placed by Mailchimp |
_abck | Mailchimp | Functionality Cookie placed by Mailchimp |
You can choose how Cookies are handled by your device through your browser or device settings, including refusing or deleting all Cookies. At any point you can choose not to remain on Our Site therefore not providing your cookie consent. If you choose not to receive Cookies, please be aware that some areas of our website may not function after you have changed or chose not to remain Our site therefore you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
Our Site may place and access certain first-party Cookies on your computer or device. First- party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. By using Our Site you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than Us. Third-party Cookies are used on Our Site for all necessary site functionality.
Most browsers allow some control of most cookies through the browser setting. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
We may process your data when you've granted us explicit permission (referred to as express consent) in order to utilise your personal information for a particular purpose, or in cases where your consent can be reasonably inferred (referred to as implied consent). You have the option to retract your consent at any point.
In certain exceptional circumstances, we may be legally authorised, in accordance with applicable laws, to process your information without requiring your explicit consent. These situations include, but are not limited to:
The above are the purposes for which We process your personal information. In most cases the legal basis for the processing is that it is in the Company interests which is not overridden by your rights and freedoms – We refer to this as “Tribally Games legitimate business interests”. In some cases, the legal basis is that the processing is necessary to perform a contract with you or to comply with a legal or regulatory obligation.
We will only use your personal information 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 We need to use your personal information for an unrelated purpose, We will notify you and will explain the legal basis which allows us to do so.
We may also aggregate personal and other data captured through Our Site so that the data is no longer capable of identifying an individual. We reserve the right to use this aggregated information for the purposes of improving and enhancing our services, generating insights, for use in marketing to other users and current and potential partners and otherwise for the purposes of our business. Provided that such aggregated data does not directly or indirectly identify you as an individual, this data is not considered to be personal information for the purpose of this Notice.
Our services provide the option for you to register and sign in using your third-party social media account credentials, such as your Facebook or Twitter login. If you opt for this method, we will receive specific profile details about you from your social media provider. The exact profile information we obtain can vary based on the particular social media provider in question, but it typically includes your name, email address, list of friends, profile picture, and any other information you have chosen to make public on the respective social media platform.
We will exclusively use the data we receive for the specific purposes outlined in this privacy notice or those that are explicitly communicated to you through the relevant services. It's essential to understand that we have no authority over, nor do we bear responsibility for, any alternative applications of your personal information by third-party social media providers. We strongly advise you to examine their privacy notices to gain insight into their procedures for gathering, employing, and disclosing your personal information, as well as to learn how you can configure your privacy preferences on their websites and applications.
We may share your personal information We collect with Tribally Affiliates, as explained at the beginning of this Notice.
Other than the third parties listed below, Tribally Games and any Group Company will not disclose your personal information to any third party unless either We have your permission to do so, or Tribally Games is, or consider itself to be, under a legal or regulatory obligation to do so.
Your personal information may be disclosed to the following recipients, though Tribally Games will use its reasonable endeavours to control the use of your personal information.
Tribally Games and any Group Company understands the importance of ensuring its systems are secure from unauthorised access, use or disclosure so that emails and forms that contain your personal information are safe. We have administrative, technical and physical safeguards designed to comply with applicable legal requirements and to safeguard the information We collect. We also have internal policies, procedures and controls in place to ensure this, of both a technical and organisational nature.
We may store the information We collect on our servers both cloud based or in servers located in countries where our third-party service providers have facilities. To facilitate our global operations, Tribally Games may transfer your personal information outside of the European Economic Area (“EEA”), UK and Switzerland. The EEA includes the European Union countries as well as Iceland, Liechtenstein, and Norway. Transfers outside of the EEA are sometimes referred to as “third country transfers”. We may transfer information to countries outside of your residence which may have different data protection laws and regulations that differ from those in your country.
For the purposes outlined in this Notice, Tribally Games and any Group Company may send your personal information (which includes transfers to other Tribally Affiliates) internationally, including to countries outside the EEA. However, your personal information will only be transferred to or from countries outside the EEA as long as those countries have compatible data protection laws and measures in place or where We have put in place adequate safeguards as approved by the European Commission, details of which will be made available on request.
We will retain your data primarily to meet statutory and regulatory obligations and for the duration necessary to fulfil the purposes outlined in this privacy notice, except when a longer retention period is mandated or allowed by the law. None of the purposes mentioned in this notice will necessitate the preservation of your personal information for more than twelve (12) months beyond when you close your account with Us.
Your data is retained to enable Us to pursue Our legitimate business interests to our clients, current and future requirements
Where there is no ongoing legitimate business need to process your personal information, we will take one of the following actions: either delete or anonymize the information, or, if these options are not feasible (e.g., when personal information is archived for backup purposes), we will securely store your personal information and isolate it from any further processing until it can be deleted.
GDPR gives you a number of rights regarding your personal information that is processed by us:
To withdraw your consent to the use of your information as described in this Notice, you can contact us through the stated methods below. Please note that in some circumstances this may mean that We can no longer provide our Services to you.
California Civil Code Section 1798.83, referred to as the “Shine The Light“ law, grants California residents using Our services the right to request, once a year and at no cost, information regarding the categories of personal information, if any, that we have disclosed to third parties for direct marketing purposes. It also allows them to obtain the names and addresses of all third parties with whom we shared their personal information in the preceding calendar year. If you are a California resident and wish to make such a request, kindly send a written request to us using the contact details provided below.
If you are under 18 years old, residing in California, and have a registered account for Our services, you possess the right to request the removal of any unwanted data that you have publicly posted on our platform. To initiate the removal process, please get in touch with us using the contact information below. Include your account's associated email address and confirm your California residency. While we will ensure that the data is no longer publicly displayed on Our services, please be aware that it may not be entirely removed from all our systems, including backups, among others.
It is important that any personal information We hold on you is accurate and up-to-date. Please keep us informed if your personal information changes or needs updating or if you believe that any information We have collected on you is inaccurate or out of date.
You can also request to see what personal information We hold on you and request to erase any personal information if it is no longer required. You may also inform us if you object to our use of your personal information.
From time to time, We issue email communications about service updates, operational and product information, and industry news. The electronic marketing communications We send to you also contain opt-out mechanisms that allow you to opt-out from receiving those communications, update your contract information or change your preferences at any time. We will only send you the email communications you have registered for. You may also opt back in to receive these email communications at any time.
If you no longer wish to receive marketing communication from us, you can let us know via the stated methods below.
This privacy Notice does not provide exhaustive detail of all aspects of the Company processing of personal information. However, We shall aim to provide any additional information or explanation needed, if requested.
We try to meet the highest standards when processing personal information. For this reason, We take any complaints We receive about this very seriously. We encourage people to bring it to Our attention if they think that the collection or use of information is unfair, misleading or inappropriate.
If you would like to exercise any of these choices, need further details or information, have a query or have a complaint about our use of your personal information, please contact:
We review and change this Notice from time to time as our business evolves. This may be necessary, for example, if the law changes, or if We change Our business in a way that affects personal data protection.
Any changes shall be posted on Our Site and you will be deemed to have accepted the terms of the Privacy Notice on your first use of Our Site following the alterations. Where the Notice has been updated and this results in a change to this Notice, this will be clearly identified by reference to the date of this Notice above. Unless stated otherwise, our current Privacy Notice applies to all information that We have about you and your account. We recommend that you check this page regularly to keep up-to-date.
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