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Last update: 8 February 2024
This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including when preparing to provide or providing our platforms to you, including Gods Unchained, our collectible digital card trading game that operates on the Ethereum blockchain, Guild of Guardians, our free to play mobile game, the Immutable X and zkEVM platforms, our marketplace that allows buyers and sellers to trade digital assets, our other downloadable applications and mobile applications, and our websites and other online products and services (Services). In this Privacy Policy we, us or our means Immutable Pty Ltd (ABN 89 626 193 351) and all subsidiaries and group companies of Immutable Pty Ltd.
This Privacy Policy takes into account the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles. In addition to the Australian laws, individuals located in the European Union (EU) and the United Kingdom (UK) may also have rights under the EU General Data Protection Regulation 2016/679 and the UK General Data Protection Regulation (collectively the GDPR). Appendix 1 outlines the details of the additional information and rights that individuals located in the EU and the UK have as well as information on how we process the personal information of individuals located in the EU and the UK. Appendix 2 contains additional information about our use of personal information from individuals who are not covered by the GDPR (i.e. individuals located in Australia, anywhere in the United States, and other locations outside of the UK and EU). Appendix 3 discloses additional information and data rights provided to individuals who reside in specific jurisdictions within the United States that have enacted their own applicable privacy laws.
"Personal information" as used in this Privacy Policy means information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable, and includes anything defined as personal information, personal data under the GDPR, personally identifiable information or similar terms under applicable law.
We do not knowingly collect, solicit, use, or disclose personal information from children under the age of 13. If you are under 13, please do not attempt to register for the Services or send any information about yourself to us. No one under age 13 may provide any personal information to us. If we learn that a child under 13 has provided personal information to us without verification of parental consent, we will delete that information immediately.
We remind and encourage all parents to check and monitor their children’s online activities. Under United States law, parents have the right to review and have deleted any personal information we may have inadvertently collected from their children, and refuse to permit further collection of that information. If you believe that we might have any information from or about a child under 13, please contact us at https://support.immutable.com/hc/en-us
We collect personal information in a variety of ways, including:
Directly:
Indirectly:
The types of personal information we may collect about you include:
We may collect these types of personal information directly from you or from third parties.
We may collect, hold, use and disclose personal information for the following purposes:
We may aggregate personal information for reporting, statistical and analysis purposes, and for business, product and service improvement purposes. This allows us to better inform ourselves and anticipate our users' preferences and requirements, and to monitor and improve the effectiveness of our business, products and services. We may also de-identify information for inclusion in such aggregated databases or reports.
If you are resident in the United Kingdom or the European Union, we have also set out below, in a table format, a description of all the ways we plan to use your Personal Information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process the same personal information for more than one lawful ground depending on the specific purpose for which we are using your data.
Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.
We may disclose personal information to:
or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
Overseas disclosure: Where we disclose your personal information to third parties listed above, or where their or our computer systems including IT servers and website hosts are located overseas, your personal information may be stored, transferred or accessed by those parties or by us outside of Australia, the EU and the UK, including but not limited to, United States of America, United Kingdom, Singapore, European Union (including Ireland, Greece and Italy), New Zealand, Canada, Indonesia and Brazil.
Where we remain responsible for the protection of your personal information, we will only disclose your personal information to countries with laws which protect your personal information in a way which is substantially similar to the Australian Privacy Principles or we will take such steps as are reasonable in the circumstances to protect your personal information in accordance with the Australian Privacy Principles. Where another party with their own relationship with you has collected and uses your personal information for their own purposes or as an 'independent controller' - for example, an app developer who has integrated our Services (such as Passport) into their own products and services, who may use your personal information on the basis of their own separate agreement with you - we are not in control of and will not be responsible for their actions and decisions with respect to your personal information, including whether they disclose it to third parties in countries that do not have substantially similar protection of your personal information as Australian privacy laws.
When transferring your personal information out of the European Economic Area (“EEA”) or the UK, we will use any relevant contractual agreement approved by the competent authorities as a basis for the transfer (e.g. the Standard Contractual Clauses for transfers from the EEA or the International Data Transfer Agreement for transfers from the UK). Where these contractual agreements are not sufficient to ensure an adequate level of data protection at the recipient, we will implement supplemental safeguards. Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the European Economic Area and/or the United Kingdom.
Your Choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and/or your use of our Services.
Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.
Restrict and unsubscribe: We may communicate with you by phone, email, SMS or push notifications, including to inform you about existing and new products and services that may be of interest to you. To object to processing for direct marketing/unsubscribe from our marketing database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication. You may decline marketing messages sent by push notifications by refusing the relevant permission in your device settings.
Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, incomplete, irrelevant or out of date. Please note, in some situations, we may be legally permitted to not correct your personal information.
Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. You also have the right to contact the relevant privacy authority.
Please see Appendix 1 for additional rights and other information available to individuals based in the EU or the UK, and Appendix 2 for additional rights and other information available to individuals based in the United States.
We will take reasonable steps to ensure that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we
take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be accessed or disclosed in a manner that is inconsistent with this Privacy Policy.
We may use cookies on our online Services from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personal information. However, they do recognise you when you return to our online Services and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online Services with personal information, this information may be linked to the data stored in the cookie and that information could potentially be used to identify you. It may be possible for us to identify you from information collected automatically from your visit(s) to our Services, for example, we will be able to identify you through your user name and password when you log into our Services. Further, if you access our Services via links in an email we have sent you, we will be able to identify you.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our online Services. At this time, our websites do not respond to “do not track” signals, if received.
We may use web beacons on our Site from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
We may use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time. If you do not want your Site visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout.
Our Services may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.
We may revise this Privacy Policy from time to time. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. If you do not agree with our changes, please do not use the Services. Your continued use of our Services following the posting of changes to this Privacy Policy and the conclusion of any legally required notice period means you accept those changes.
For any questions or notices, please contact us at: Immutable Pty Ltd (ABN 89 626 193 351)
Contact: https://support.immutable.com/hc/en-us/requests/new
Under the GDPR individuals located in the EU or the UK have certain additional rights which apply to their personal information. Personal information under the GDPR is often referred to as personal data and is defined as information relating to an identified or identifiable natural person (individual). This Appendix sets out the additional rights we give to individuals located in the EU and the UK, including how we process personal information lawfully, transparently and fairly. Please read the Privacy Policy above and this Appendix carefully and contact us at the details at the end of the Privacy Policy if you have any questions.
This Appendix applies to the personal information set out in the Privacy Policy above. This includes any sensitive information also listed in the Privacy Policy above which is known as ‘special categories of data’ under the GDPR.
Your personal information will:
We will only use your Personal Information when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:
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 or by clicking on the unsubscription link in each marketing email you receive from 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 we will explain the legal basis which allows us to do so.
If you refuse to provide us with certain Personal Information or if you provide us with incomplete or inaccurate information required for the performance of the contract or for compliance with a legal obligation, please be aware that we may not be able to provide or deliver to you all or parts of the service that you require.
We only collect Special Categories of Personal Data where you have given your explicit consent, it is necessary to protect your vital interests or those of other people or where you have deliberately made it public.
See above in the main section of this Privacy Policy (under 'Purposes for which we will use your personal information - UK and EU') to find out more about the types of lawful basis that we will rely on to process your Personal Information.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for,
including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see ‘Your legal rights’ below for further information.
In some circumstances we may anonymise your personal information (so that it can no longer be associated with you) for analytics, research or statistical purposes in which case we may use this anonymised information indefinitely without further notice to you.
We may transfer your personal data to third parties located outside of the European Economic Area and the United Kingdom. We will provide appropriate safeguards for such transfers.
When transferring personal data out of the European Economic Area or the United Kingdom, we will use either the "Standard Contractual Clauses” as approved by the European Commission or the United Kingdom Government (as applicable) or any other contractual agreement approved by the competent authorities as a basis for the transfer.
Where these contractual agreements are not sufficient to ensure an adequate level of data protection at the recipient, we will implement supplemental safeguards.
Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the European Economic Area and/or the United Kingdom.
Under certain circumstances, you have rights under data protection laws in relation to your personal information.
You have the right to:
If you wish to exercise any of the rights set out above, please contact us using the following details:
Contact: https://support.immutable.com/hc/en-us/requests/new
You will not have to pay a fee to access your personal information (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.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
This section provides additional information to the main section of the Privacy Policy, and is applicable to individuals outside of the EU/UK, such as for individuals located in Australia, the United States, and other locations outside of the UK and EU.
In addition to the ways set out in the main section of the Privacy Policy, we may also collect Personal Information which you directly or indirectly provide to us while interacting with us, such as when you use any of our websites or Services (including Gods Unchained, Guild of Guardians and Immutable Protocol).
In addition to the information set out in the main section of the Privacy Policy, the types of information we may collect about you when you visit or use the Services may also include (as described in the Cookies Policy):
In addition to the information set out in the main section of the Privacy Policy, we may also collect, hold, use and disclose Personal Information for the following purposes:
The California Consumer Privacy Rights Act provides California residents with specific rights regarding their personal information. This Appendix sets out additional rights granted to residents of California, as well as to residents of other US jurisdictions such as Virginia and Colorado, as and when those jurisdictions enact applicable privacy legislation from time to time.
We do not “sell” or “share” your personal information, as the term is defined in the California Privacy Rights Act.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see below in this Appendix for further information.
In some circumstances we may anonymise your personal information (so that it can no longer be associated with you) for analytics, research or statistical purposes in which case we may use this anonymised information indefinitely without further notice to you.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and validate your request, we will include a list of your personal information that may have been disclosed and the categories of third parties the information may have been disclosed to.
You may request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive your request and confirm your identity, we will review your request. We may deny your deletion request if retaining the information is proper and necessary or if an exception allowing us to retain the information applies.
You may also request that we correct any of your personal information that has become outdated or needs correction for any reason.
If your request is approved, we will delete, correct, or deidentify the relevant information and will direct our service providers to take similar action.
California residents, and residents of other US jurisdictions that enact applicable privacy laws from time to time, may exercise their rights to know, delete or correct described above by emailing us at privacy@immutable.com. Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You may only submit a request to know twice within a 12-month period. We endeavor to substantively respond to a Verifiable Consumer Request within forty-five (45) days of its receipt, unless we require an extension. If we reasonably require an extension we will inform you of the reason and extension period.
Non-Discrimination
We will not discriminate against you for exercising any of your data subject rights.
We do not charge a fee to process or respond to your Verifiable Consumer Request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
California Civil Code Section 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of the information you provide through the Services to third parties for their direct marketing purposes. To make such a request, please contact us by email at privacy@immutable.com.
Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one Shine the Light request per consumer each year, and we are not required to respond to requests made by means other than through the e-mail address or mailing address provided in this Policy.
We will notify you in the event we offer any financial incentive for the use of your personal information. Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms.
