This Privacy Policy (“Privacy Policy”) for P00LS Inc., and its relevant affiliates (“Company”, “we”, “us” “our”) describes how we collect, use and disclose information about visitors of the Company’s website p00ls.io (the “Website”), and any content, tools, features and functionality offered on or through our Website are collectively referred to herein as the “Services.” For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services whether as a Creator or a regular User. 

PLEASE READ THIS PRIVACY POLICY CAREFULLY. If you do not want information about you used as described in this Privacy Policy, please do not access or use the Services.    

1. UPDATING THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. The updated Privacy Policy will be effective as of the time of posting, or such later date as may be specified in the updated Privacy Policy. If we make material changes we will notify you and/or take other steps as required by applicable law. IF YOU DO NOT AGREE TO ANY UPDATES TO THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR CONTINUE TO USE THE SERVICES.

2. COMPANY’S COLLECTION AND USE OF INFORMATION

In order to provide you with the Services, we may ask you to provide us with certain details or information about you. Information that you submit through the Services are:

• Contact information: Name, email address, residential address, wallet address.  We collect basic contact details to communicate with you, provide you with the Services, administer your relationship with us, respond to your queries (including providing assistance, consulting services, and support), and perform our contract with you. We may use this information with your consent to personalize the Services for you and offer or send you promotions.
• Account information: Username, password, security questions. We collect this information to create, maintain and secure your account. We collect account information to maintain and secure your account with us, provide you with the Services (including providing assistance, consulting services, and support), enable you to request the Services according to your preferences, and administer your relationship with us. We also process this information in order to perform our contract with you.
• Demographic information: Country, city, and state/province. We collect demographic information to provide you with the Services and in order to perform our contract with you. We also use this information to personalize the Services for you, offer promotions, and advertise to you with your consent.
• Information about your use of the Services: Interaction and feedback regarding the Services, including features, search queries within the Services, and certain interactions you make via the Services. We collect this interaction and feedback to provide you with the Services, improve and enhance our Services, conduct research and analytics, and for security purposes in our legitimate interests.
• Any other information you provide: This includes pictures and any information you provide to us, for example, when communicating with us. We use this information to provide the Services, and communicate with you about our Services in order to perform our contract with you. We use this information to monitor and analyze trends in connection with the Services, conduct research and development, and for our legitimate interests and with your consent, offer promotions, personalize your experience and post on social media.

Our Services may require you to enter certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing some of the Services.

We may obtain information about you from the following third party sources:

• Social networking platforms: Your contact information and information you post on social networking platforms (e.g., Instagram) when you have a publicly-available profile containing information about yourself. We use this information to communicate with you and advertise to you. In addition, if you interact with us on such platforms, we will collect information about those interactions. 
• Other third parties: You may choose to elect that certain third parties share information with us, for example, when you choose to access the Services through another service, such as through Single Sign-on (e.g., Google, Twitter, or Facebook) or link any social media platforms to your account.

Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. See Section 6 below for more information.

We also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies, web beacons/clear gifs, and other tracking technologies (“Tracking Technologies”), including Google Analytics, to provide and enhance the performance of our Services, facilitate and enhance user experience, monitor and analyze trends, usage and activities in connection with the Services and conduct internal research and development. For further information about Google Analytics, please click here. We collect the following kinds of Usage Data:

• Device type, such as your phone, computer, or tablet;
• IP address;
• Screen resolution;
• Browser type;
• Date and time stamps, such as the date and time you first accessed the Services;
• Operating system;
• Log data;
• Number of visits;
• Language of device; 
• Geolocation; and
• Other information regarding your interaction with the Services, such as clickstream data.

We use the Usage Data we collect automatically to:

• Improve and provide the Services;
• Offer promotions;
• Run analytics; and
• Better understand user interaction with the Services.

In addition to the foregoing, we may use all of the above information to:

• Create anonymized and aggregated data sets that we may use for a variety of functions, including research, internal analysis, analytics, identify and communicate with you including providing newsletters and marketing materials and other functions;

• Comply with any applicable legal obligations; 
• Detect, investigate, and prevent activities that may violate our policies or be illegal; 

• Enforce any applicable terms of use; and
• Protect or defend the Services, our rights, the rights of our users or others.

3. HOW THE COMPANY SHARES INFORMATION ABOUT YOU

In certain circumstances, we may share information about you with third parties. Such circumstances may include:

•  With vendors or other service providers in our legitimate interests, or to perform a contract with you, such as:

1. Data analytics vendors;
2. Data storage providers;
3. Email vendors; 
4. Google analytics; and
5. Survey and marketing vendors.

• When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations.
• With our affiliates in our legitimate interests or otherwise within our corporate group, and as may be in our legitimate interests.
• To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
• In connection with an asset sale, merger, bankruptcy, or other business transaction in our legitimate interests.
• For legal and security reasons and to protect our services and business, in our legitimate interests or as required by law such as to enforce any applicable terms of service and ensure the safety and security of the Company and/or its users.
• When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations.
• With professional advisors, such as auditors, law firms, or accounting firms in our legitimate interests.
• With Creators of tokens within the Services (each creator, a “Creator” and each token, a “Creator Token”) with your consent will receive the categories of information listed in Section 2 of this Privacy Policy, to solely facilitate engagement and communication with you about that specific Creator’s events and offerings and provide updates to you if you are a holder of such Creator’s Creator Token. Creators will maintain the confidentiality and security of regular Users data and to not disclose any of these data other than its authorized agent.

You acknowledge that such sharing of information may occur in all of the aforementioned circumstances and is permitted by and subject to this Privacy Policy and applicable law.

4. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH

We may share certain categories of your personal information with Creators on our platform to facilitate better engagement and provide updates on the creator's events and offerings. This sharing is based on your explicit consent, which we will request at the point of collection or before the sharing takes place. You have the right to withdraw this consent at any time. The Creators are obligated to protect your personal information and use it only for the specific purposes for which it was shared, as outlined in our agreement with them.

Additionally, in order to provide our Services, the Company engages Technical Providers listed in the table below. A Technical Provider is a third-party engaged by the Company and its affiliates, to process data in order for us to provide our Services.

List of Technical Providers and how we use their services: 

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Please note, that the Company is not responsible for the handling of your data by these Technical Providers.

5. WHERE WE STORE YOUR INFORMATION

Personal information may be exported outside of the jurisdiction in which you reside. Under those circumstances, the governments, courts, law enforcement or regulatory agencies of that country or those countries may be able to obtain access to your personal information through foreign laws. You need to be aware that the privacy standards of those countries may be lower than those of the jurisdiction in which you reside. You are not obliged to give your personal information to us, but if you choose not to do so, we may not be able to provide our services, or your access to our Services may be limited.

For any transfers of data outside the EEA or the UK, we will take appropriate measures in accordance with the GDPR to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy. These measures may include: entry into European Commission and UK Government approved standard contractual arrangements (“Model Clauses”). Please contact should you wish to examine a copy of the Model Clauses.

6. COOKIES AND OTHER TRACKING TECHNOLOGIES

Do Not Track Signals

Your browser settings may also allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our Services are not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

Cookies 

We use Google Analytics cookies to collect information about your browsing activities on our Website. Google Analytics is a web analytics tool that helps us understand how users engage with the website. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. For more information on Google Analytics, see here.  You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.

You can find more information about cookies and how to manage them through your browser settings.

You may control the way in which your devices permit the use of cookies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including general functionality, to work incorrectly. Most browsers accept cookies automatically.

7. USER GENERATED CONTENT

The Services enable you to upload certain information, for example, you may submit photos (“User-Generated Content” or “UGC”). We or others may store, display, reproduce, publish, or otherwise use UGC, and may or may not attribute it to you. Others may also have access to UGC and may have the ability to share it with third parties. If you choose to submit UGC to any public area of the Services, your UGC will be considered “public” and will be accessible by anyone, including the Company.

Please note that we do not control who will have access to the information that you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure.  We are not responsible for the privacy or security of any information that you make publicly available on the features permitting creation of UGC or what others do with information you share with them on such platforms. We are not responsible for the accuracy, use or misuse of any UGC that you disclose or receive from third parties through the forums or email lists.

8. HOW LONG DO WE STORE YOUR PERSONAL INFORMATION

We will retain your personal information as follows:

• your account data for as long as you keep your account open or as needed to provide you with our Services;
• if you contact us, we will keep your data for 24  months after you contact us; 
• your technical usage information for 24 months; and
• data on your use of our Website and our Services is retained for 24 months.

We will also retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes and enforce our terms and conditions, other applicable terms of service, and our policies. If you stop using our Services, we may store your information in an aggregated and anonymized format; we may use this information indefinitely without further notice to you.

9. THIRD PARTY WEBSITES AND LINKS

Our Services may contain links to other websites and/or online platforms operated by third parties. We do not control such other online platforms and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook or Twitter) may also be viewable by other users of the Website and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed in the Services. We expressly disclaim any and all liability for the actions of third parties, including but not limited to actions relating to the use and/or disclosure of personal information by third parties. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

10. YOUR RIGHTS

Depending on where you are located you may have certain rights in relation to your personal information:

• Access: You have the right to access personal information we hold about you, how we use it, and who we share it with.
• Portability: You have the right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
• Correction: You have the right to correct any of your personal information we hold that is inaccurate.
• Erasure: In certain circumstances, you have the right to delete the personal information we hold about you.
• Restriction of processing to storage only: You have the right to require us to stop processing the personal information we hold about you, other than for storage purposes, in certain circumstances.
• Objection: You have the right to object to our processing of your personal information.
• Objection to marketing: You can object to marketing at any time by opting-out using the unsubscribe/ opt-out function displayed in our communications to you.
• Withdrawal of consent: Where we rely on consent to process your personal information, you have the right to withdraw this consent at any time by emailing us at support@P00LS.io.

Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. 

11. DATA SECURITY

Please note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Any information you send us through any means is transmitted at your own risk.

12. COMPLAINTS

If you are an EEA or UK resident and think we have infringed data protection laws, you can file a claim with the data protection supervisory authority in the EEA country in which you live or work or where you think we have infringed data protection laws, or with the UK Information Commissioner’s Office, as applicable to you. 

13. HOW TO CONTACT US

If you would like to reach out to ask questions regarding information about you that we collect or other questions about this Privacy Policy or your rights, you can email us at: 

P00LS Inc.

990 Biscayne Blvd. Suite #701

Miami, FL 33132

support@p00ls.io

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