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FUNKI PRIVACY POLICY

Last Updated: April 15, 2024

The GIN Management Company Limited ("FUNKI," "we," "us," or "our") is a company incorporated under the laws of the British Virgin Islands. We value your privacy and are dedicated to maintaining the confidentiality and security of your personal information. This Privacy Policy outlines our practices regarding the collection, use, disclosure, and protection of personal information that may be gathered when you engage with our blockchain-related services, including but not limited to the FUNKI Protocol, FUNKI Gateway Interface, FUNKI NFT Service, and FUNKI Marketplace (together referred to as the "Services"), in accordance with the British Virgin Islands Data Protection Regulations, and, in respect of any EU data subjects, the EU General Data Protection Regulation.

We urge you to read this Privacy Policy in its entirety to gain a comprehensive understanding of how we handle your personal information in connection with our Services. By accessing or utilizing the Services, you are consenting to the practices and procedures described in this Privacy Policy. If, for any reason, you do not consent to the collection, use, and disclosure of your information as delineated herein, you should refrain from accessing or using the Services.

This Privacy Policy applies to information we collect through the Services, in email, text, and other electronic messages between you and the Services, and when you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy. It does not apply to information collected by us offline or through any other means, including on any other website operated by any third party, or by any third party, including through any application or content that may link to or be accessible from or on the Services.

This Privacy Policy is subject to change. We reserve the right to update and revise it at our discretion. We will post any changes to the Privacy Policy on this page, along with a notice at the top of the page indicating when the last revisions were made. Your continued use of our Services after any modification to the Privacy Policy will constitute your acceptance of such modification. We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices and the ways you can help protect your privacy.

1. INFORMATION WE COLLECT 

In the course of providing the Services, GIN Management Company Limited may collect and process various categories of information from and about users. This information enables us to deliver, personalize, and improve our Services. The types of information we may collect include, but are not limited to, the following:

  • Personal Information: This refers to information that can be used to identify you as an individual. When you register for an account, engage in transactions, or access certain - - - functionalities of the Services, we may collect personal identifiers such as your name, postal address, email address, telephone number, government identification number, and digital wallet addresses. Additionally, we may collect other related information that you voluntarily provide, such as your date of birth, transaction history, and payment details.
  • Usage Data: As you navigate through and interact with our Services, we may automatically collect data about your equipment, browsing actions, and usage patterns. This data may include information such as your Internet Protocol (IP) address, log files, web beacons, cookies, and other tracking technologies, device type, browser type, browser language, operating system, the pages or features of our Services that you browse and the time spent on those pages or features, the frequency with which you use the Services, the links you click on or use, and other statistics.
  • Information from Third Parties: We may receive information about you from third-party sources, such as blockchain analysis services, credit bureaus, identity verification services, and publicly available databases. This information may include additional personal information or details about your blockchain transactions that we combine with the information we have collected directly from you.
  • Please note that we may also collect, use, and share aggregated data such as statistical or demographic data for various purposes. Aggregated data may be derived

2. HOW WE USE YOUR INFORMATION 

The information we collect serves as a cornerstone for delivering and enhancing the Services we offer. FUNKI uses the information gathered from our users in a variety of ways, including but not limited to the following:

  • To Provide and Manage the Services: We use your information to operate, provide, maintain, and manage the Services you have requested or authorized. This includes using your information to facilitate the creation and security of your account, to process your transactions, to provide customer support, and to ensure the overall smooth operation of the Services.
  • To Communicate with You: We utilize your information to communicate with you regarding your account or transactions, to inform you about changes to our terms, conditions, and policies, and to send you alerts and other administrative messages. We may also use your information to respond to your comments, questions, and requests, provide customer service and support, and send you technical notices, updates, security alerts, and administrative messages.
  • For Marketing and Promotional Purposes: Your information allows us to provide you with news and information about products, services, offers, promotions, rewards, and events we believe may be of interest to you. We may also use your information to send you newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
  • To Personalize User Experience: We use your information to personalize the Services and to provide content, features, and advertisements tailored to your interests and preferences. This includes using your information to help us understand your preferences based on previous or current activity on the Services, which enables us to provide you with improved services.
  • For Research and Analytics: To better understand how users access and use our Services, both on an aggregated and individualized basis, we use your information to monitor and analyze trends, usage, and activities in connection with our Services. This helps us improve our Services and develop new products, services, and features.
  • To Ensure Security and Integrity: We use your information to detect, investigate, and prevent fraudulent transactions, abuse, security breaches, and other illegal activities and to protect the rights and property of FUNKI and others.
  • To Enforce Our Policies and Terms: We use your information to enforce our Terms of Service, including to protect our intellectual property rights. For Contests and Promotions: We may use your information to facilitate contests, sweepstakes, and promotions, and to process and deliver entries and rewards.
  • To Combine Information: We may link or combine information we collect from or about you with other information we obtain from third parties or information we already hold to help understand your needs and provide you with better service.
  • For Other Purposes: We may also use your information for other purposes described to you at the time the information was collected or as otherwise set forth in this Privacy Policy.

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 oriFUNKIal purpose.

3. SHARING OF YOUR INFORMATION 

FUNKI recognizes the importance of safeguarding your personal information and restricts the sharing of your details to specific circumstances and with particular third parties, as outlined below:

  • Service Providers: We may share your information with third-party service providers, contractors, and agents who perform services for us or on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. These service providers are given access to your information as is reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.
  • Business Transfers: In the event that FUNKI is involved in a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of FUNKI's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, your personal information may be transferred to the buyer or other successor entity.
  • Legal Obligations and Rights: We may disclose your information if we believe it is necessary to comply with a legal obligation, such as responding to a subpoena, court order, or other governmental request, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
  • Protection of Rights: We may also share your information to enforce our terms and conditions, to protect the security or integrity of our Services, and to protect the property, legal rights, or safety of FUNKI, our users, or others, as permitted or required by law.
  • With Consent: We may disclose your personal information to any other third party with your prior consent to do so. This may include sharing information with other parties for their own marketing purposes as permitted by law.
  • Blockchain Analysis Providers: To ensure compliance with legal, regulatory, and law enforcement requirements, we may share your information with blockchain analysis providers. This is to monitor and analyze blockchain transactions and to prevent prohibited conduct, such as fraudulent activities and money laundering. Aggregated or Anonymized Data: We may share aggregated or anonymized information that does not directly identify you with third parties for research, marketing, analytics, and other purposes.

Please note that the Services may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Services, we encourage you to read the privacy policy of every website you visit.

We may also share your personal information with other third parties when you explicitly direct us to do so or when you use our Services to interact with third-party products or services.

4. DATA SECURITY

FUNKI is committed to the protection of your personal information and has instituted a range of security measures aimed at safeguarding your data from accidental loss and from unauthorized access, use, alteration, and disclosure. These measures include, but are not limited to, encryption technologies, firewalls, and secure server facilities. Our security protocols are designed to protect the confidentiality, integrity, and availability of your personal information during storage, processing, and transmission.

Despite our efforts to provide a secure and reliable environment for your personal information, it is important to acknowledge that no system of transmission over the Internet, or method of electronic storage, is 100% secure. Similarly, while the blockchain provides unique security features, it is not impervious to all security threats. Therefore, we cannot guarantee absolute security for your personal information transmitted to or through our Services, nor can we ensure or warrant the security of any information you transmit to us over the Internet, including the use of email.

To further enhance data security, we also take measures to ensure that our service providers who may have access to your personal information are contractually obligated to keep such information confidential and secure, and they are not permitted to use it for any purpose other than to carry out the services they are performing for FUNKI.

We encourage you to take steps to protect against unauthorized access to your account and personal information by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity.

Please be aware that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose an account password of sufficient length and complexity, to not reveal this password to any third parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account. In the unfortunate event that your personal information is compromised, we will notify you and any applicable regulator of a breach where we are legally required to do so.

5. YOUR CHOICES

We acknowledge your right to control your personal information and provide you with choices regarding the collection, use, and sharing of your information:

  • Account Information: You have the ability to review, update, correct, or delete your personal information at any time. To do so, simply log into your account on our Services and navigate to the account settings page, where you can make the desired changes to your account information. It is important to keep your personal information accurate and up-to-date, and we encourage you to review your information regularly to ensure that it reflects your current preferences and circumstances.
  • Communication Preferences: If you no longer wish to receive promotional communications from us, you have the option to opt out by following the unsubscribe instructions provided in those communications. Please note that this opt-out does not apply to non-promotional communications, such as those about your account, transactions, servicing, or FUNKI's ongoing business relations.
  • Cookies and Tracking Technologies: Cookies consist of small data files that may include an anonymous unique identifier. These files are sent to your browser from a website and stored on your device. In addition to cookies, we utilize various tracking technologies, including beacons, tags, and scripts, to collect and track information, thereby enhancing and analyzing Services. You have the option to instruct your browser to refuse all cookies or to notify you when a cookie is being sent. However, please note that if you do not accept cookies, you may not be able to utilize certain portions of the Services.

Please be aware that if you choose to delete your information or opt out of the collection and use of your information, certain features and functionalities of the Services may no longer be available to you.

We respect your privacy and give you an opportunity to opt out of receiving announcements of certain information.

6. CONTACT US

Should you have any inquiries, concerns, or comments regarding this Privacy Policy, or if you need further assistance with respect to our privacy practices, please do not hesitate to reach out to us. You can contact GIN Management Company Limited by sending an email to legal@ginprotocol.com.

We are dedicated to addressing your questions and concerns and will make every effort to respond to your requests in a timely and transparent manner. Your feedback is valuable to us as it helps us improve our privacy measures and the Services we offer.

Please note that email communications are not always secure, so please do not include sensitive information in your emails to us.

Your privacy is of utmost importance to us, and we are committed to protecting your personal information and respecting your choices concerning its use. We welcome the opportunity to discuss our privacy practices with you and to provide any additional information or clarification you may require.