PRIVACY POLICY

2. HOW WE COLLECT YOUR PERSONAL DATA

2.1 Your personal data may be collected in different ways. You may provide us with your data directly. This will generally happen when you:

2.1.1 filling out a form.

2.1.2 giving us written feedback.

2.1.3 communicating with us via third party social media sites.

2.1.4 communicating with us via the Site or the Game.

2.1.5 subscribing to our newsletters or notifications.

2.1.6 creating an account with us.

2.1.7 We may also receive personal information from third parties, when you sign up to services provided by BTS through a social network; in such occasions, we may receive the personal information you have made available to such third parties, and which you have allowed for them to relay via your privacy settings.

2.2 We can also collect your personal information automatically, using cookies and/or other similar tracking technologies. To learn more about cookies and similar technologies used, including how you can accept or refuse cookies, please see section 9 below.

3. Information We Collect

The personal information that BTS collects from you when you access the Site or use the Game generally may include:

3.1 Network information regarding transactions, including, among other things, the type of device you use, access times, hardware model, MAC address, IP address, operating system and version, and other unique device identifiers.

3.2. Information about plugins you might be using, included but not limited to those related to the management of cryptocurrency assets and any information provided by them., and your Ethereum public address.

3.3 We may receive network information from you as a result of your interaction with our Game.

3.4 When you complete a form online or subscribe to our newsletters or notifications on the Site:

3.4.1 name

3.4.2 email address

3.4.3 physical address

3.4.4 zip code

3.4.5 phone number/fax number

3.4.6 age

3.4.7 gender

3.5 Instant messaging usernames and social media handles.

4. THE PURPOSES FOR WHICH BTS USES YOUR PERSONAL INFORMATION

4.1 As with nearly all interactions that take place on the World Wide Web, our servers may receive information by virtue of your interaction with them, including but not limited to IP Addresses.

4.2 Some of the services in our Game require permissions that could potentially be used to access additional personal information. Such permissions are used for an extremely limited technical purpose for allowing the Game to properly interact with your browser. No additional information is obtained beyond what is necessary to provide the Game. No information received is shared with any third-party except those affiliated with BTS or as required for provision of the Game. This information can include, but is not limited to player email addresses, player name, and player address.

4.3 Any identifying information collected via Segment.io is controlled by Segment.io, Inc. This information can include, but is not limited to player email addresses, player name, and player address.

4.4 Public blockchains provide transparency into transactions and BTS is not responsible for preventing or managing information broadcasted on a blockchain.

4.5 Personal information collected for the creation and use of the Marketplace Account is used to allow the interaction of the Marketplace Account with the different top-up and withdrawal methods, operate the Marketplace Account with our third-party providers and comply with applicable KYC requirements.

4.6 BTS may use the information we collect in the following ways:

4.6.1 To analyze trends for how the Site and Game are being used;

4.6.2 To improve the Site and Game;

4.6.3 To help personalize your experience of the Site and Game;

4.6.4 To monitor web traffic; and

4.6.5 If you gave us your contact information, we may use that information to contact you to send you technical notices, updates, confirmations, security alerts, to provide support to you, to tell you about other products and services that we think might interest you, or to respond to your comments or questions. If you live in the EEA please refer to the marketing provision in section 7 below.

4.6.6 To comply with applicable KYC requirements.

4.6.7 Granting you access to our Discord channels and general management of our Discord channels and other social media accounts.

4.6.8 If you signed up through a supported social network account, we may share your accomplishments and goals achieved in the Game in the relevant social network.

4.6.9 Your username for the Marketplace Account will be used in the Game, and will be visible to other users of the Game.

4.7 The legal basis that we rely on for processing your personal data is one of the following:

4.7.1 to perform in terms of a contract where you are a party.

4.7.2 a legitimate business interest (that is not outweighed by interests you have to protect your data).

4.7.3 consent (which we will ask for before we process your data).

4.7.3 to comply with a legal obligation.

5. WHO WE SHARE YOUR PERSONAL INFORMATION WITH AND FOR WHAT PURPOSES

5.1 BTS may share the information we collect with third parties who need to access it in order to perform work on our behalf, including doing things like helping us make the Site or Game available, including without limitation payment services providers, anti-fraud services providers, or providing analytics services for us. We work hard to ensure that these third parties only access and use your information as necessary to perform their functions.

5.2 BTS may create aggregations and anonymizations that contain your information in a way that does not directly identify you. BTS may use and/or share those aggregations and anonymizations for a variety of purposes related to the Site, the Game, or our company and its business.

5.3 BTS may disclose your personal information to our subsidiaries, affiliated companies, agents, businesses, or service providers who process your personal information on our behalf in providing the Site and Game to you. Our agreements with these service providers limit the kinds of information they can use or process and ensure they use reasonable efforts to keep your personal information secure.

5.4 BTS also reserves the right to disclose personal information that BTS believes, in good faith, is appropriate or necessary to enforce our Terms of Use, take precautions against liability or harm, to investigate and respond to third-party claims or allegations, to respond to court orders or official requests, to protect the security or integrity of our Game, and to protect the rights, property, or safety of BTS, our users or others.

5.5 BTS reserves the right to transfer your information in the event that BTS is involved in a merger, acquisition, joint venture, sale, bankruptcy, insolvency, reorganization, receivership, assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, or other change of control. If such event happens, BTS may disclose your information to another entity related to such event.

5.6 The personal data we collect may be also transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations. In the event of such transfer, we ensure that BTS will use reasonable effort to ensure that any transferred information is treated in a manner consistent with this Privacy Policy. Where you reside in the EEA, and we transfer your personal information outside the EEA, please see the provisions in section 6 below.

6. DATA TRANSFERS

If your information is collected within the European Economic Area (“EEA”), your information may be transferred outside of the EEA. Where we transfer your personal data outside the EEA we ensure that appropriate safeguards are in place by using appropriate data transfer mechanisms such as the European Commission adequacy decision or the EU Standard Contractual Clauses.

7. MARKETING

7.1 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

7.1.1 Promotional offers from us

(a) We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

7.1.2 You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

7.1.3 Third-party marketing

(a) We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

8. YOUR CHOICE

BTS will process your personal information in accordance with this Privacy Policy, and as part of that you will have limited or no opportunity to otherwise modify how your information is used by BTS.

Should you reside in the EEA, this section 8 will not apply to you. Please see section 13 below which sets out your privacy rights.

9. COOKIES

Our Site uses “Cookies”, which are text files placed on your computer which help BTS analyze how users use the Site, and similar technologies (e.g. web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device on, off and across different devices and our Site, as well as to improve the Site, to improve marketing, analytics or functionality. The use of Cookies is standard on the internet. Although most web browsers automatically accept cookies, the decision of whether to accept or not is yours. You may adjust your browser settings to prevent the use of cookies, or to provide notification whenever a cookie is sent to you. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to access the full functionality of our Site.

10. CHILDREN'S PERSONAL INFORMATION

The Game is not intended for children under 13, and BTS does not knowingly solicit or collect personal information from children under the age of 16. If we become aware that we have collected personal information from a child under 16, we will promptly delete that information. If you believe a child under such age may have provided us with personal information, please contact us using the contact details set out at the end of this Privacy Policy.

11. INFORMATION SECURITY

Whilst neither we, nor any other organization, can guarantee the security of information processed online, we do have appropriate security measures in place to protect your personal information. For example, we store the personal information you provide on computer systems with limited access, encryption, or both.

All personal data that BTS internally collects will be stored by BTS' cloud hosting provider in the United States. Any data stored in the cloud will be stored in secure servers to ensure that your data is protected.

All information related to credit cards, debit cards, bank accounts and wallets is stored by our payment service provider, Circle.

All information relating to KYC processes is stored by Jumio, our KYC services provider.

12. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

12.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

12.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

13. PRIVACY RIGHTS

13.1 Subject to applicable law, you may have some or all of the following rights in respect of your personal information:

13.1.1 to obtain a copy of your personal information together with information about how and on what basis that personal information is processed;

13.1.2 to rectify inaccurate personal information (including the right to have incomplete personal information completed);

13.1.3 to erase your personal information (in limited circumstances, where it is no longer necessary in relation to the purposes for which it was collected or processed);

13.1.4 to restrict processing of your personal information where:

a. the accuracy of the personal information is contested;

b. the processing is unlawful but you object to the erasure of the personal information; or

c. we no longer require the personal information but it is still required for the establishment, exercise or defense of a legal claim;

13.1.5 to challenge processing which we have justified on the basis of a legitimate interest (as opposed to your consent, or to perform a contract with you);

13.1.6 to prevent us from sending you direct marketing;

13.1.7 to withdraw your consent to our processing of your personal information (where that processing is based on your consent);

13.1.8 to object to decisions which are based solely on automated processing or profiling;

13.1.9 in addition to the above, you have the right to file a complaint with the supervisory authority.