Privacy Policy

Version 1.0

Effective as of December 23, 2022

At Acme, we are committed to protecting the privacy and security of our users. This Privacy Policy explains how we collect, use, and disclose information about you when you access our Acme Wallet or Acme Developer Platform ("Services"), visit our website at https://www.acmedao.com or any other site or mobile app where this Privacy Policy is posted ("Sites"), communicate with us, or otherwise engage with us. This Privacy Policy applies to all of our Services and all methods by which you may access our Sites and Services.


We may collect the following types of information about you:


  • Personal information, including but not limited to your username and avatar, email address, full name, date of birth, government-issued identification and facial biometrics.

  • Blockchain network addresses associated with your digital assets or gaming tokens (your "Wallet").

  • Payment details, including but not limited to your credit card information, Apple Pay information, and bank account information.

  • Content that you create, share, or submit using our Services.

  • Any information you provide in response to surveys or questionnaires.

  • Feedback and correspondence, such as emails, chat messages, or other communications you send to us via email or third-party social media websites.

  • Information received from other sources with your consent.

  • Information about the device you use to access the Services and Sites, including device model, device ID, IP address, browser type, operating system, platform (Android, iOS, web), and referring website.

  • Information about your use of the Services, including the pages and features you visit, the time you spend on those pages or features, the links you click on, and your in-app user settings, preferences, and in-app purchases.


We may also collect information from third-party sources, such as social media sites, when you link your account to those sites. This information may be used for marketing and communications purposes. Please be aware that third-party sites are governed by their own privacy policies, and you should review those policies before using those sites.


By using our Services and Sites, you acknowledge and agree that we may collect, use, and disclose your information as described in this Privacy Policy. If you have any questions or concerns about our privacy practices, please contact us at [email protected]. If you do not agree with our policies and practices, do not use our Services or Sites. We may change our policies and practices from time to time, in which case we will post the revised version on this page. Your continued use of our Services and Sites after any changes have been made will constitute your acceptance of those changes.


How We Use Personal Information


We collect and process your personal information in connection with our provision of Services, as well as to meet our legitimate interests. This includes using your:


  • Username for identification purposes within the Wallet

  • Email address to authenticate you, communicate with you, provide technical and customer support, and send updates about your participation in waitlists, contests, and surveys. With your consent, we may also send you promotional and other information or push notifications with game updates and promotions through our app. You can opt-out of the use of your information for these purposes at any time (see "Your Choices" below).

  • KYC information to provide additional security measures to access your Services and protect against unauthorized access or fraudulent activity.

  • Email address to display targeted advertisements to you on third-party social media platforms, such as Facebook, Twitter, Google, or LinkedIn. We may provide a hashed version of your email address or other information to the platform provider for these purposes. You can opt-out of the use of your information for these purposes at any time (see "Your Choices" below).

  • Content and biographical information in connection with our Developer Programs or campaigns if you sign up to participate.

  • Device and usage information to better understand who is using our Services and how, and to improve our Services.

  • IP address to provide you with appropriate content and block access to the Services from locations where we do not provide Services.

  • Network address associated with your Wallet to allow you to make transactions on the platform, including buying and selling digital assets such as gaming tokens.

  • Feedback and correspondence to respond to your requests, feedback, or inquiries and improve our products and services.

  • Payment information to process payments for digital assets you buy and sell on the platform.


We will not use your personal information for purposes other than those purposes we have disclosed to you without your prior consent. If you have any questions or concerns about our use of your personal information, please contact us at [email protected].


What Personal Information We Share


We do not sell, license, lease, or otherwise disclose personal information (including personal information relating to current or former customers) to any third party without your consent, except for the following purposes:


  • Providing access to personal information to our service providers who require it to perform their tasks and duties in the course of providing services on our behalf, such as payment processing, hosting data, providing advertising, marketing, and analytics services. We may also share personal information with third parties who have a legitimate purpose for accessing it, where permitted by applicable law. Our service providers may have access to or store personal information outside of the jurisdiction in which you reside, including in the United States.

  • Sharing your information with customer data and behavioral analytics platforms that help us understand how you use and interact with our Services.

  • Sharing your KYC information and payment information with payment processing services with which we partner to process payments for digital assets and blockchain transactions, at your request. These services may use your KYC information to verify your identity and comply with their own legal obligations. Please be aware that these third party crypto exchanges may have their own privacy policies that you should review and acknowledge before using their services. We will take reasonable steps to protect the security and confidentiality of your personal information when sharing it with third party crypto exchanges. If you do not agree to the collection, use, and sharing of your KYC information and payment information as described in this clause, you may not be able to purchase certain amounts of cryptocurrency using our Services.

  • Disclosing information to third parties about your account or transactions you make if you give us your written permission.

  • Transferring any information we have about you as an asset in connection with a proposed or completed merger, acquisition, or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Acme Labs DMCC, or as part of a corporate reorganization or other change in corporate control.

  • Sharing your information with law enforcement or officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, where required or permitted by applicable law, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate a violation of any of our terms and conditions or any other applicable policies. We may also disclose your personal information in order to comply with applicable laws and regulatory requirements, as well as legal process; respond to mandatory legal or governmental requests or demands for information (which may include a lawful access request by United States or other courts, law enforcement, or governmental agencies); enforce our agreements, policies, procedures, and terms of use; and protect ourselves, our users, Account Holders, or the general public from illegal activities.

  • Disclosing personal information to another organization for the purposes of investigating a breach of an agreement or contravention of law, detecting, suppressing, or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S., or other law or legal process, which may include lawful access by US or foreign courts, law enforcement, or other government authorities.


Third-Party Websites


Our website may contain links to third-party websites. These websites have their own privacy policies, which we do not control. We encourage you to review the privacy policies of all third-party websites you visit.


Use of Cookies and Other Website Information


We collect IP addresses and other related information, such as page requests, browser type, operating system, and average time spent on our website, to help us understand website activity and improve our website and services.


We use cookies to provide better service, facilitate the use of our website, track usage of the website, collect data, and address certain security issues. When you access our website, we send cookies to your computer, phone, or mobile device. Your device stores the cookie in a file located inside your web browser. The cookies help us keep track of your visits to our website and your activity on the website, and understand how you interact with us. We may link the information collected through cookies with other information we collect from you in accordance with this Privacy Policy, and use the combined information to better understand user behavior and improve our products. Similarly, third parties that serve cookies on our website may link your name or email address to other information they collect, including past online purchases or your online usage information.


You can generally activate or deactivate the use of cookies through a functionality built into your web browser. To learn more about cookies, or how to control, disable, or delete them, please visit this site for detailed guidance. Some third-party advertising networks, including Google, also allow users to opt out of or customize preferences related to internet browsing. To learn more about this feature from Google, click here. Please note that if you choose not to accept cookies from our website, you may not be able to use all the features available on our website.

We also use analytics providers, such as Google Analytics, to help us gather and analyze information about areas visited on our website (such as the most read pages, time spent, search terms, and other engagement data) in order to evaluate and improve the user experience and the website. The following link explains how Google uses data when you use its partners' websites and applications:


www.google.com/policies/privacy/partners/.


To prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link:


https://tools.google.com/dlpage/gaoptout?hl=en.


You can also obtain additional information on Google Analytics' data privacy and security at the following links:


https://policies.google.com/technologies/partner-sites and https://support.google.com/analytics/topic/2919631.


By using our website, you consent to us storing and accessing cookies and other information on your computer or phone and to the use of Google Analytics in connection with such activities. Please read the information provided so you understand what you are consenting to.


App Usage Information & Analytics


Certain limited data is required for the app to function on your device, including the type of device hardware and operating system, unique device identifier, IP address, language settings, and the date and time the app accesses our servers. We use this information to understand activity on our app, improve our app, and tailor your in-app experience. We may also use third-party service providers to collect analytical information about your use of the app, such as the app features used and time spent on the app, to tailor your in-app experience, improve our products and the quality of our app, and manage and analyze data to better understand our users.


Security


We strive to ensure that our systems are secure and meet industry standards. We implement physical, administrative, and electronic safeguards to protect personal information in our custody and control against theft, loss, and unauthorized access, use, modification, and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require it to fulfill their job requirements. We also seek to engage third-party service providers that have confidentiality and security policies when they have access to personal information and are not authorized to use it for their own purposes. While we make efforts to secure our systems, no security system is foolproof and we cannot guarantee that our systems will be completely secure.


Your Rights


Under applicable law, you may have the following data protection rights:


  • The right to access, correct, update, or request the deletion of your personal information. You can do so at any time by emailing [email protected]. If you delete your account, only your username will remain on the website for ranking purposes, and your personal information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.

  • The right to object to the processing of your personal information, request the restriction of the processing of your personal information, or request the portability of your personal information. You can exercise these rights by emailing [email protected].

  • If we have collected and processed your personal information with your consent, you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent where permitted under applicable law.

  • The right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. To find contact details for authorities in the European Union, click here. To find contact details for privacy regulatory authorities in the UAE, click here. We will respond to all requests from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.


Your Choices


You can unsubscribe at any time by clicking the "unsubscribe" link at the bottom of each email. Alternatively, you can opt out of receiving email marketing communications by contacting us at the information provided in the "Contact Us" section below or adjusting your preferences in your account settings. Please note that you may continue to receive transactional or account-related communications from us.


You can turn off push notifications for the app within the notifications settings of the app.


Legal Basis for Processing Personal Information (EU Residents)


We will only collect and use your personal information where we have a legal basis for doing so. This may include where:

  • We need to use your personal information to perform a contract with you, such as to provide the Services to you.

  • The processing is in our legitimate interests and is not overridden by your rights or interests. For example, we may have a legitimate interest in operating our Services and communicating with you as necessary to provide these Services, for example when responding to your queries, improving our Platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities.

  • We have your consent to do so. We will make it clear to you when we are collecting your personal information and seek your consent where required by law.


Retention of Personal Information


We will retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy. This may include retaining your personal information for as long as you continue to use the Services or for a period of time that is consistent with applicable law, applicable statute of limitations, or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to collect fees owed, to resolve disputes, to address problems with our services, to assist with investigations, to enforce our Terms or other applicable agreements or policies, or to take any other actions consistent with applicable law.


For non-EEA residents and where permitted by law, we may continue to index information regarding your public network address from the Ethereum blockchain for account resurrection purposes.


Please note that we may need to retain certain information for recordkeeping purposes or to comply with legal obligations. In such cases, we will securely store your personal information and isolate it from any further processing until deletion is possible.


Minors Under 13


Our Services are not intended for Children under the age of 13 and we do not knowingly collect personal information from Children in violation of the Children's Online Privacy Protection Act. If you believe that your child under the age of 13 has accessed our Services without your permission, you may request the deletion of their personal information by contacting us at [email protected]. If we learn that we have collected personal information from a child under the age of 13, we will take steps to delete that information as soon as possible. We have implemented measures to prevent Children under the age of 13 from using our Services and do not market products or services for purchase by Children.


"Do Not Track" Policy


We are required by California law to inform you of how we respond to web browser "Do Not Track" (DNT) signals. At this time, there is no industry or legal standard for recognizing or honoring DNT signals. As a result, we do not respond to DNT signals at this time. This policy may change as the privacy community and industry develop best practices for responding to DNT signals.


NOTICE TO CALIFORNIA RESIDENTS - YOUR CALIFORNIA PRIVACY RIGHTS (AS PROVIDED BY CALIFORNIA CIVIL CODE SECTION 1798.83)


If you are a California resident and have established a business relationship with us for personal, family, or household purposes, you have the right to request information about whether we have disclosed your personal information to any third parties for their direct marketing purposes. If we have made such a disclosure, you have the right to request a list of the categories of personal information that was disclosed and the names and addresses of the third parties to whom the personal information was disclosed. You may make such a request by emailing us at [email protected]. Please note that we are only required to respond to one request per California resident per year and we are not required to respond to requests made by means other than through this email address.


International Data Transfers


Acme may transfer personal information to countries outside of the country in which the data was originally collected. This may include transferring personal information to servers located in the United States or United Arab Emirates (UAE), or to other countries where we or our service providers are located. These countries may have different data protection laws than the country in which you initially provided the information. When we transfer your personal information to other countries, we will ensure that it is protected in accordance with this Privacy Policy and applicable laws.


Changes to This Policy


Acme reserves the right to make changes to this Privacy Policy at any time. We encourage you to review our Privacy Policy periodically to stay informed about how we are protecting your personal information. If we make material changes to this Privacy Policy, we will post the revised policy on our website at www.acmedao.com/privacy and either note on our website that material changes have been made or notify our users by email. The date of the most recent update to our Privacy Policy will be listed in the header of the policy.


How to Contact Us About This Policy


If you have any questions or concerns regarding this Privacy Policy or our handling of your personal information, or if you would like to submit a complaint, please contact our Privacy Officer at [email protected]. You may also submit a complaint to the data protection regulator in your jurisdiction.


In the European Union, you can find contact details for privacy regulatory authorities on the website of the European Data Protection Supervisor (EDPS). You can also visit the website of the European Data Protection Board (EDPB) for more information about data protection in the EU.


In the United States, you can file a complaint with the Federal Trade Commission (FTC) if you believe that your privacy rights have been violated. You can also contact your state attorney general's office or the office of the Privacy Commissioner of Canada for more information about privacy regulatory authorities in the US and Canada.


In the UAE, you can contact the Telecommunications and Digital Government Regulatory Authority (TDRA) to submit a complaint or for more information about privacy regulatory authorities.