Privacy Policy

Last Updated: July 31st, 2022

Chainge Games Ireland Ltd, d/b/a Daoing (“Daoing,” “we”, “us”, or “our”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect, use, and share in connection with the Daoing website, mobile app, and other software provided on or in connection with our services, as described in our Terms of Service (collectively, the “Service”). “NFT” in this Privacy Policy means a non-fungible token or similar digital item implemented on a blockchain (such as the Ethereum blockchain), which uses smart contracts to link to or otherwise be associated with certain content or data.

We hereby agree to submit to the jurisdiction of the Irish Courts and the Irish Data Protection Commission on all matters relating to data protection. As such, the appropriate supervisory authority under the General Data Protection Regulations (GDPR) is the Irish Data Protection Commission (www.dataprotection.ie).

Daoing endeavours to comply with the General Data Protection Regulation, Data Protection Acts, ePrivacy Regulation and data protection best practices. This policy informs individuals how Daoing processes personal data in accordance with the principles of data protection identified in data protection legislation.

Daoing will process any personal information provided to us by individuals, whether it be provided through our website (www.daoing.app), the mobile App, in person, by any form, correspondence, telephone, email or by any other means, or otherwise held by us in relation to you in the manner set out in this policy.

By submitting your information to us and or by using our website you confirm your consent to the use of your personal information as set out by this Privacy Policy. If you do not agree with the terms of this Privacy Policy please do not use our website or mobile app to provide us with any personal information.

1. Types of Data We Collect. “Personal Data” means data that allows someone to identify you individually, including, for example, your name, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing. “Anonymous Data” means data, including aggregated and de-identified data, that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data as described below.

a. Information You Provide Us.

i. When you use our Service, update your account profile, or contact us, we may collect Personal Data from you, such as email address, user name, website, and other information you provide. We also collect your blockchain address, which may become associated with Personal Data when you use our Service.

ii. Our Service lets you store preferences like how your content is displayed, notification settings, and favourites. We may associate these choices with your ID, browser, or mobile device.

iii. If you provide us with feedback or contact us, we will collect your name and contact information, as well as any other content included in the message.

iv. We may also collect Personal Data at other points in our Service where you voluntarily provide it or where we state that Personal Data is being collected.

b. Information Collected via Technology. As you navigate through and interact with our Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

i. Information Collected by Our Servers. To provide our Service and make it more useful to you, we (or a third party service provider) collect information from you, including, but not limited to, your browser type, operating system, Internet Protocol (“IP”) address, mobile device ID, blockchain address, wallet type, and date/time stamps.

ii. Log Files. As is true of most websites and applications, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamps, and clickstream data. We use this information to analyse trends, administer the Service, track users’ movements around the Service, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Service, it will recognize you and the information can be used to personalize your experience.

iii. Cookies. Like many online services, we use cookies to collect information. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to analyse how users interact with our Service, make improvements to our product quality, and provide users with a more personalized experience.

iv. Pixel Tag. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags allow us to analyse how users find our Service, make the Service more useful to you, and tailor your experience with us to meet your particular interests and needs.

v. How We Respond to Do Not Track Signals. Our systems do not currently recognize “do not track” signals or other mechanisms that might enable Users to opt out of tracking on our site.

vi. Analytics Services. In addition to the tracking technologies we place like Cookies and Pixel Tags, other companies may set their own cookies or similar tools when you visit our Service. This includes third-party analytics services (“Analytics Services”) that we engage to help analyse how users use the Service. The information generated by the Cookies or other technologies about your use of our Service (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity, which we may receive on an individual or aggregate basis. We use the information we get from Analytics Services to improve our Service. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ terms of use and privacy policy. By using our Service, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above.

c. Information Collected from Third-Party Companies. We may receive Personal and/or Anonymous Data about you from companies that offer their products and/or services for use in conjunction with our Service or whose products and/or services may be linked from our Service. For example, third-party wallet providers provide us with your blockchain address and certain other information you choose to share with those wallets providers. We may add this to the data we have already collected from or about you through our Service.

d. Public Information Observed from Blockchains. We collect data from activity that is publicly visible and/or accessible on blockchains. This may include blockchain addresses and information regarding purchases, sales, or transfers of NFTs, which may then be associated with other data you have provided to us.

2. Use of Your Personal Data.

a. We process your Personal Data to run our business, provide the Service, personalize your experience on the Service, and improve the Service. Specifically, we use your Personal Data to:

i. facilitate the creation of and secure your account;

ii. identify you as a user in our system;

iii. provide you with our Service, including, but not limited to, helping you view, explore, and create NFTs using our tools and, at your own discretion, connect directly with others to purchase, sell, or transfer NFTs on public blockchains;

iv. improve the administration of our Service and quality of experience when you interact with our Service, including, but not limited to, by analysing how you and other users find and interact with the Service;

v. provide customer support and respond to your requests and inquiries;

vi. investigate and address conduct that may violate our Terms of Service;

vii. detect, prevent, and address fraud, violations of our terms or policies, and/or other harmful or unlawful activity;

viii. display your username next to the NFTs currently or previously accessible in your wallet, and next to NFTs on which you have interacted;

ix. send you a welcome email to verify ownership of the email address provided when your account was created;

x. send you administrative notifications, such as security, support, and maintenance advisories;

xi. send you notifications related to actions on the Service, including notifications of offers on your NFTs;

xii. send you newsletters, promotional materials, and other notices related to our Services or third parties' goods and services;

xiii. respond to your inquiries related to employment opportunities or other requests;

xiv. comply with applicable laws, cooperate with investigations by law enforcement or other authorities of suspected violations of law, and/or to pursue or defend against legal threats and/or claims; and

xv. act in any other way we may describe when you provide the Personal Data.

b. We may create Anonymous Data records from Personal Data. We use this Anonymous Data to analyse request and usage patterns so that we may improve our Services and enhance Service navigation. We reserve the right to use Anonymous Data for any purpose and to disclose Anonymous Data to third parties without restriction.

3. Disclosure of Your Personal Data. We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

a. Third Party Service Providers. We may share your Personal Data with third party service providers to: provide technical infrastructure services; conduct quality assurance testing; analyse how our Service is used; prevent, detect, and respond to unauthorized activities; provide technical and customer support; and/or to provide other support to us and to the Service.

b. Affiliates. We may share some or all of your Personal Data with any subsidiaries, joint ventures, or other companies under our common control (“Affiliates”), in which case we will require our Affiliates to honour this Privacy Policy.

c. Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition, or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

d. Legal Rights. Regardless of any choices you make regarding your Personal Data (as described below), Daoing may disclose Personal Data if it believes in good faith that such disclosure is necessary: (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas, warrants, or other legal process served on Daoing; (c) to protect or defend the rights or property of Daoing or users of the Service; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Service.

e. Other Disclosures. We may also disclose your Personal Data: to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide it; or with your consent.

4. Third-Party Websites. Our Service may contain links to third-party websites. When you click on a link to any other website or location, you will leave our Service and go to another site, and another entity may collect Personal Data from you. We have no control over, do not review, and cannot be responsible for these third-party websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these third-party websites or their content, or to any collection of your Personal Data after you click on links to such third-party websites. We encourage you to read the privacy policies of every website you visit. Any links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.

5. Third-Party Wallets. To use our Service, you may use a third-party wallet which allows you to engage in transactions on public blockchains. Your interactions with any third-party wallet provider are governed by the applicable terms of service and privacy policy of that third party.

6. International data transfers

All personal data processed by Daoing is kept within the EU, specifically all data is stored and processed within Ireland. As we transfer data cross-border from one EU member State to another we have nominated the Irish Data Protection Commission as the lead supervisory authority in accordance with the Data Protection Commission’s ‘One Stop Shop’ (OSS) on the basis that our main establishment for data protection purposes is within the Republic of Ireland. As such, our Local Supervisory Authority for OSS is the Irish Data Protection Commission.

For further information concerning the ‘One Stop Shop’ procedure, please see the Data Protection Commission’s website (www.dataprotection.ie)

Daoing does not transfer personal data outside of the EEA or EU unless it is specifically requested by a data subject, or on foot of performance of a contract outside of the EEA or EU, on a case-by-case basis.

If we do transfer personal data to outside of the EEA, Daoing will make sure that it is protected in the same way as if it was being used in the EEA. We’ll use one of the following safeguards:

Transfer to a non-EEA country whose privacy legislation ensures an adequate level of protection of personal data to the EEA one (in terms of GDPR requirements),

Put in place a contract with the foreign third-party that means they must protect personal data to the same standards as the EEA (to the same standards as GDPR),

Transfer personal data to organisations that are part of specific agreements on cross-border data transfers with the European Union (e.g. corporate rules, privacy shield, etc.), or,

Complying with any guidance and or practice directives issued by the Irish Data Protection Commission.

7. Information Storage

We will take reasonable steps to ensure that your information is kept secure and protected, including but not limited to electronic data being protected using appropriate software, relevant networks safety and security checks, and, any computers or devices that can access data are encrypted. We do store some personal data in physical forms and they are kept in an appropriately secure environment that includes:

· Secure HTTP connection (HTTPS) which encrypts data between clients and servers.

· User password encryption and saving password as encrypted string to avoid password reading from database.

· Some of our pages (e.g. reset password page) has CAPTCHAs which prevents robots to try email existence on our site.

· Default headers like X-Frame-Options, X-XSS-Protection etc. which protects users uploading remote content like iFrames, remote JavaScripts etc.

· Database Backups (within the EU)

· User input sanitization

8. Data Retention Policy

We have a general data retention policy that relates to the retention of relevant data for seven years. We identify this based on business/commercial needs, legal requirements and any consumer or client queries and or issues to which the Statute of Limitations may apply.

There are some legal exceptions to the seven year retention policy but each is on a case-by-case basis, e.g. investigation of accidents in the work place under Health & Safety legislation.

Personal data that is no longer required will be destroyed and or deleted in secure manner.

9. Requesting your data

Any person has the right to find out whether an organisation has any personal data about them, what they use the personal data for and ask for copies of personal information held by that organisation.

If you wish to make a data access request in order to get a copy of any personal data we may process, please write a letter stating that you wish to make a data access request and email it to [e-mail].

In order to process your request we may request that you send us a copy of your identification (passport, drivers licence, etc.). The reason we may ask for personal identification is to ensure that you are the correct person making the request for your personal data.

Unfortunately, verbal data access requests cannot be entertained as we need to establish a data controller’s identity and retain a paper/auditing trail of any data access request to establish ongoing compliance with GDPR and the Data Protection Act 2018.

In response to any data access request, you have the right to refer the matter to the Data Protection Commission if you are unhappy with the outcome, however, we ask that you would notify us first of any issue so that we may help resolve it as quickly as possible.

The Data Protection Commission can also provide you with full information as to your rights as a data subject at dataprotection.ie.

10. Rectifying mistakes

You have the right to rectify any incorrect or inaccurate personal data at no cost to you.

If you believe that we are incorrectly processing any of your personal data, please inform us by email to [e-mail].

11. Queries or complaints

If you have any queries or complaints regarding our Privacy Policy or any data protection matter, please let us know by email to [e-mail].

Daoing has undertaken to submit to the jurisdiction of the Republic of Ireland and Data Protection Act 2018 and the Data Protection Commission.

Individuals have the right to refer any matter to the Data Protection Commission by contacting them at www.dataprotection.ie or by writing to:

Data Protection Commission

Canal House

Station Road

Portdarlington

Co. Laois

If you are, for whatever reason, considering contacting the Data Protection Commission about us we would ask that you inform us of your difficulty first so that we can try to resolve it to your satisfaction.

12. Changes to our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on our website.

Any changes will become effective upon posting the revised Privacy Policy on our website. If we make any material or substantial changes to this Privacy Policy we will use reasonable endeavours to inform you by email, notice on our website or any other agreed communications channels.