Privacy Policy
Effective Date: 17 May, 2024
1. INTRODUCTION
1.1. Welcome to the ZarGates Platform ("we," "our," "us") represented by ZarGates Limited, a company incorporated under the laws of Hong Kong, RM 1401, 14/F, CHUNG YING BUILDING, 20 CONNAUGHT RD WEST, SHEUNG WAN HONG KONG.
1.2. We are steadfast in our commitment to safeguarding your privacy and ensuring the confidentiality and security of your personal data. This Privacy Policy articulates the methods and purposes of our data collection, usage, disclosure, and protection practices when you engage with our platform and services.
2. PROJECT INFORMATION
2.1. Name of the Project: ZarGates Platform.
2.2. Description: ZarGates is a pioneering Web3 Platform, engineered for the distribution of both Web2 and Web3 games.
2.3. Blockchain Platform Utilized: IP-Shares, TON, Ethereum, Binance Smart Chain, Tron, Polygon.
3. DATA COLLECTION AND USAGE
3.1. Types of Data Collected: we collect an array of personal data, including but not limited to:
3.1.1. email addresses;
3.1.2. IP addresses;
3.1.3. crypto wallet addresses;
3.1.4. user activities on the platform;
3.1.5. transactions associated with platform smart contracts;
3.1.6. social media account data;
3.1.7. in-game user activity updates and data;
3.1.8. ownership details of NFTs and other virtual assets;
3.1.9. on-platform messages;
3.1.10. personal data (e.g., Date of birth, Name, Surname);
3.1.11. hashed authorization data;
3.1.12. referral data and social connections;
3.1.13. data and details as stipulated by third-party service providers (including Google Analytics).
3.2. Universal Privacy Policy Clauses Integrated.
3.2.1. Types of Information Collected: we collect various types of information based on your interactions with our products. This includes content, communications, metadata, and information from devices. Special categories of data, such as religious beliefs, political views, and health information, may be collected with your explicit consent and are subject to additional protections under applicable laws.
3.2.2. Information from Devices: we collect information from and about the devices you use to access our services, including hardware and software details, device operations, and identifiers.
3.2.3. Information from Partners: advertisers, app developers, and publishers may provide us with information about your activities off our products through our business tools and APIs. We require partners to have lawful rights to collect, use, and share your data.
3.3. Methods of Data Collection: our data collection methodologies encompass:
3.3.1. forms;
3.3.2. cookies;
3.3.3. blockchain transactions;
3.3.4. game providers;
3.3.5. user-generated content processes;
3.3.6. third-party service providers (including Google Analytics).
3.4. Purposes of Data Collection The personal data collected serves various purposes including, but not limited to:
3.4.1. transaction processing;
3.4.2. user authentication and session management;
3.4.3. web analytics;
3.4.4. marketing and communication;
3.4.5. security and compliance;
3.4.6. customized user experience;
3.4.7. rewards data aggregation;
3.4.8. commercial purposes, including the distribution of data for other services.
3.5. Marketing Purposes: we leverage user data for marketing initiatives. Users retain the right to opt-out of such communications.
3.6. Universal Privacy Policy Clauses Integrated:
3.7. Networks and Connections: we collect information about the people, accounts, hashtags, and Pages you are connected to and how you interact with them across our Products, such as the people you communicate with most frequently or the groups you are a member of. This includes collecting contact information if you choose to upload, sync, or import it from a device (such as an address book, call log, or SMS log history), which is used for purposes such as helping you and others find people you may know and for other purposes listed below.
3.8. Your Usage: we collect information about how you use our Products, including the types of content that you view or engage with, the features you use, the actions you take, the people or accounts you interact with, and the time, frequency, and duration of your activities. For example, we log when you are using and have last used our Products, and what posts, videos, and other content you view on our Products. We also collect information about how you use features such as our camera.
3.9. Information about Transactions Made on Our Products: we collect information about purchases or other financial transactions made using our Products (such as when you make a purchase in a game or make a donation). This includes payment information, such as your credit or debit card number and other card information, other account and authentication information, and billing, delivery, and contact details.
4. DATA SHARING AND DISCLOSURE
4.1. Third-Party Service Providers: we may share user data with third-party service providers, including but not limited to:4.1.1. google Analytics (collected data);
4.1.2. game developers (user identifiers to recognize players).
4.2. Circumstances for Data Disclosure: user data may be disclosed under the following circumstances:
4.2.1. compliance with legal requirements;
4.2.2. business transfers;
4.2.3. requests from official authorities;
4.3. Universal Privacy Policy Clauses Integrated.
4.3.1. With Other Users: your information may be shared with other users based on your privacy settings. This includes content you share and actions you take on our platforms.
4.3.2. With Third-Party Partners: we share information with third-party partners who assist us in providing and improving our services. This includes vendors, service providers, and researchers. Advertisers receive reports on ad performance, but personal identifiers are only shared with your explicit permission.
4.3.3. Legal Requests: we comply with legal requests and share information with law enforcement when required by law, or to protect against harmful activities, fraud, and security breaches.
4.4. Transparency and Blockchain Transactions : to maintain user privacy in the inherently transparent blockchain environment, we:
4.4.1. Minimize personal data stored on the blockchain
4.4.2. Store sensitive information off-chain in secure databases
4.4.3. Link on-chain transactions to off-chain data through cryptographic hashes or other secure methods
5. DATA SECURITY AND PROTECTION
5.1. Security Measures We employ robust security measures including:
5.1.1. encryption;
5.1.2. access controls;
5.1.3. secure storage solutions.
5.2. Data Transmission and Storage Security: we utilize Transport Layer Security (TLS) or Secure Sockets Layer (SSL) protocols to encrypt data during transmission. All API endpoints are secured with HTTPS to protect against eavesdropping and man-in-the-middle attacks.
5.3. Procedures in Case of Data Breach: in the event of a data breach, we implement a comprehensive incident response plan designed to mitigate impact, address the breach swiftly, and ensure compliance with all legal and regulatory requirements. Users will be promptly notified via email if their data is compromised.
6. USER RIGHTS AND CONTROL
6.1. Access, Update, or Delete Personal Data Users can access, update, or delete their personal data through our user interface or by contacting us at support@zargates.com.
6.2. User Controls Users are endowed with rights including:
6.2.1. data portability;
6.2.2. right to be forgotten.
6.3. User Consent Explicit user consent is obtained prior to data collection and processing. Users must actively opt-in by acknowledging that they have read the linked document presented in our visual interface.
6.4. Universal Privacy Policy Clauses Integrated.
6.4.1. Access and Control: you have the right to access, rectify, and delete your data. Tools are available within our settings to manage your information. Data is retained as long as necessary to provide our services or until your account is deleted.
6.4.2. Account Deletion: upon deletion of your account, we remove your posted content. Information shared by others about you remains unaffected. You can deactivate your account temporarily if you do not wish to delete it permanently.
6.5. Managing Consent Preferences Users are required to accept the entirety of the document to gain access to the platform.
7. COMPLIANCE AND GOVERNANCE
7.1. Compliance with Data Protection Regulations We adhere to pertinent data protection regulations including:7.1.1. General Data Protection Regulation (GDPR);
7.1.2. California Consumer Privacy Act (CCPA).
7.2. Universal Privacy Policy Clauses Integrated:
7.2.1. GDPR: we meticulously map and maintain all user data, allowing users to update and delete personal data within regulatory timeframes. Users are immediately notified in the event of a data risk.
7.2.2. CCPA: users are clearly informed about data collection, storage, and usage practices. Opt-out requests are handled automatically. Disclosure of data is strictly to the rightful owner, ensured through robust security protocols.
7.3. Internal Data Privacy and Security Policies: we maintain stringent internal policies encompassing:
7.3.1. Data Collection and Use: clearly defining data collection purposes and usage while limiting data collection to essential information.
7.3.2. User Consent: explicitly obtaining user consent prior to data collection, processing, or sharing, with clear options for managing consent preferences.
7.3.3. Data Minimization: ensuring data collection is restricted to necessary information, regularly reviewing practices to uphold data minimization principles.
7.3.4. Data Retention: defining data retention periods based on legal, regulatory, and business requirements, securely deleting or anonymizing data when no longer needed.
7.4. Staff Training on Data Protection Our staff undergo comprehensive training including:
7.4.1. initial training during onboarding;
7.4.2. ongoing education through workshops and webinars;
7.4.3. regular monitoring to ensure adherence to data protection practices.
8. TOKEN AND TRANSACTION SPECIFICS
8.1. Data Related to Tokens We collect and process specific data related to tokens including:
8.1.1. transaction history;
8.1.2. staking details;
8.1.3. wallet addresses.
8.2. Privacy of Token Transactions: users bear full responsibility for the wallets used to authenticate transactions.
8.3. Anonymity and Pseudonymity: we implement measures to prevent the deanonymization of users within our platform.
9. PRIVACY ENHANCING TECHNOLOGIES
9.1. Usage of Privacy-Enhancing Technologies: at present, we do not employ specific privacy-enhancing technologies such as mixnets or zk-SNARKs.
10. UPDATES AND CHANGES
10.1. Informing Users About Updates Users will be notified of updates or changes to this Privacy Policy via:
10.1.1. email;
10.1.2. notifications upon login.
10.2. Universal Privacy Policy Clauses Integrated.
10.2.1. Policy Changes: we will notify you of any changes to this policy and provide an opportunity to review the revised policy before continuing to use our products.
10.2.2. Contact Information: for any questions regarding this policy, you can contact us online or by mail at the provided address.
10.2.3. Review and Update Frequency: this Privacy Policy is reviewed and updated with each significant change to the platform, typically on a quarterly basis.
11. INTEGRATION WITH BOT AND MINI APP STANDARD PRIVACY POLICY
11.1. These Privacy Policy rules shall apply in conjunction with the Bot and Mini App Standard Privacy Policy (hereinafter referred to as the "Standard Policy"). In the event of any inconsistencies, conflicts, or contradictions between the provisions of this Privacy Policy and the Standard Policy, the provisions of the Standard Policy shall prevail and take precedence.
11.2. Users are encouraged to review both this Privacy Policy and the Standard Policy to fully understand their rights and obligations regarding data collection, usage, and protection. By using the ZarGates Platform, you acknowledge and agree to the application of both policies in accordance with the terms outlined above.
11.3. For clarity, the integration of these policies ensures comprehensive coverage of privacy practices across all aspects of the platform, including interactions with bots and mini-apps, while maintaining the primacy of the Standard Policy in resolving any discrepancies.
12. CONTACT INFORMATION
12.1. For Questions or Concerns Users may contact us with any questions or concerns about their privacy by emailing support@zargates.com.