Effective Date: 27-06-2023
1. Personal information we collect about you
Personal information (or personal data) means any information about you from which you can be identified. It does not include information where your identity has been removed (this is anonymous data).
FILT3R collects and processes information from and about you when you access and use the Website and the App. We may collect this information directly from you, automatically when you use the Website or the App, or from third-party sources.
We may collect information directly from you when you use specific features of the Website or the App, such as linking a digital wallet, making a purchase, or contacting our support team. This information includes:
- Contact Data: This includes your email address and other contact information you provide.
- Registration and Profile Data: This includes your username, password, account ID, additional information in open fields related to your user profile, and selected favorites.
- Digital Wallet Information: This includes your digital wallet address.
- Transaction Event Data: This includes relevant public IDs, transaction price information, and the date and time of the transaction.
- Content: This includes any content in messages you post on the Website or in the App or send to us. If you voluntarily provide additional information not requested by us, we have no control over the categories of information disclosed. Any such information is provided at your own risk.
- Primary Account Info: This comprises your email, username, account ID, and password. It is transmitted securely via HTTPS and stored in an encrypted manner.
- App User Data: The App collects limited user data necessary for its functionality and to provide access to FILT3R NFT/IP features.
- Ethereum Address and NFT Numbers: We collect and store the connected Ethereum address and associated NFT numbers in the Unity dashboard.
- Facial Data: The App does not collect or store facial data points. Facial tracking is handled locally on the user’s device using Apple’s TrueDepth technology.
1.1. We may collect the following information automatically:
- Service Use Data: Data related to the features you use, game play statistics, visited pages, viewed emails, products and services viewed and purchased.
- Device Data: Data about the type of device or browser you use, device operating software, internet service provider, device’s regional and language settings, and device identifiers such as IP address.
- Location Data: Imprecise location data derived from IP address or data indicating city or postal code level.
- App Technologies: Technologies embedded in our apps, such as SDKs, that send information about your app usage to a server. These technologies allow us to track content creation activities, and provide additional functionality like connecting the app with your social media account.
1.2 We may receive information from third-party sources, including:
- Service providers like Google and Apple, who provide data necessary for authenticating your log-in to the App.
2. How We Use Your Information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, for example (a) for the performance of our contract with you; (b) to comply with our legal and regulatory obligations; (c) for our legitimate interests or those of a third party; or (d) where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
Generally, we do not rely on consent as a legal basis for processing your personal information although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
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 explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the rules set out in this section, where this is required or permitted by law.
We will use your personal information for the following purposes and on the following grounds:
- on the basis of fulfilling our contract with you, in order to: register you as a new user and update our user records; process and deliver your order, including sending you updates and managing payments, fees and charges; manage your subscriptions and user accounts; authenticate you with the App; record your gameplay; provide applicable air drops; archive and backup content for the provision of our service on the Website and in the App; deal with and respond to requests, enquiries and complaints.
- on the basis of our legitimate interest, we will use your personal information for: allowing effective performance of our business; verifying your identity, and preventing and detecting fraud against you or us; collecting and recovering money you owed to us; asking you to provide feedback, leave a review or take a survey; sending you information about and enabling you to participate in events (including online events) organized by us (with or without another party); communicating with you and keeping you up-to-date on the latest developments to our services; promoting and making suggestions and recommendations to you (including by email or when you visit our website) about services that may be of interest to you; maintaining and improving the Website and the App and user experience; preventing unauthorised access and modifications to systems; carrying out and dealing with security-related tasks, such as troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data; and establishing, exercising and/or defending our legal rights.
3. Sharing Your Information with Third-Party Service Providers
We may share your personal information with service providers who perform services on our behalf. These third parties may assist in hosting the Website or operating the App or providing their functionality.
- Legal Purposes: We may disclose your information when necessary to enforce our rights, protect our property, ensure the safety of others, support external auditing and compliance functions, or comply with legal processes, subpoenas, regulations, or court orders. We may also share your information to pursue remedies or limit potential damages.
- User Content: Your NFT number will be visible to other users and viewers of your content. Content you post on social media via our platform (including the Website or the App) will be displayed and viewable by other users/viewers. We are not responsible for how other users use the available information, so please consider what you post and how you identify yourself on our platform.
- Blockchain technology: We blockchain technology when we provide services to you. When you engage in a transaction recorded on the blockchain, certain transaction-related information may be published on the blockchain and accessible to third parties beyond FILT3R’s control. Blockchain transactions are permanently recorded and difficult to delete. Combined with other data, blockchain data can potentially lead to deanonymization and unintentional disclosure of personal information.
- Consent: We may disclose your information with your permission. FILT3R does not share your information with third parties for their direct marketing purposes.
4. How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary to respond to any questions, complaints or claims made by you or on your behalf; to show that we treated you fairly; and to keep records required by law.
When it is no longer necessary to retain your personal information we will securely destroy your personal information in accordance with applicable laws and regulations. In some circumstances we will anonymise 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.
5. International transfers of your personal information
We do not generally transfer your personal information abroad.
If, to deliver our services to you, it is necessary for us to share or transfer your personal information outside the United Kingdom, then some additional safeguards will apply.
Where we need to make a transfer of this nature, we will only do so if such a transfer is safe and your personal information will be secure.
This means that when we transfer your personal information outside the UK we will only do so where (i) Binding Corporate Rules adopted under applicable data protection laws apply; or (ii) the country where are making the transfer to is a country deemed by the Information Commissioner’s Office to have an adequate level of protection in place for your personal information; or (iii) if there is no adequacy decision, where we have entered into an international data transfer agreement with the service provider containing protections for your personal information.
Please contact us if you want further information on the mechanisms used by us when transferring your personal information out of the UK.
6. Your Rights
Under the applicable data protection laws you have certain rights, as set out below:
- Right to access, rectify, or erase your personal data, the right to data portability, and the right to restrict or object to our processing of your personal data;
- Right to withdraw your consent at any time if we rely on your consent for processing;
- Right to erasure (or right to be forgotten) requesting us to delete your personal information;
- Right not to be subject to automated individual decision making; and
- Right to make a complaint about our processing of your personal information.
For further information on each of these rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation available via the following link
To exercise your rights, please contact us. We will respond to your request within 30 days, and we may ask for specific information to confirm your identity.
You will not have to pay a fee to access your data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
7. Keeping your personal information secure
FILT3R implements reasonable security measures to prevent unauthorized intrusion to the Website and App and the alteration, acquisition, or misuse of information that FILT3R directly controls. However, we cannot be held responsible for any loss, corruption, or unauthorized acquisition or misuse of information that you provide through the Website or the App and is stored by us. It is your responsibility to protect the security of your Digital Wallet Information.
How to complain
If you have a complaint about our use of your personal data or our response to your requests, you may submit a complaint to the data protection regulator in your jurisdiction. We encourage you to contact us first to address your concerns before involving a data protection regulator.
9. Your account information
You have the ability to access, update, or remove certain information you have provided to us through your account. This can be done by visiting your account settings. To confirm your identity, we may require additional information from you. Please be aware that we will retain and use information about you as required to fulfill our legal obligations, resolve disputes, and enforce our agreements.
10. Website/app Integration