Last Updated: July 29, 2022

Welcome to our Gambit Privacy Policy (“Privacy Policy”). This Privacy Policy is provided by Gambit Network Inc. (referred to as “we”, “us”, “our” and “Gambit”) and governs your use of this and our other websites, webpages, applications, games, products and services (collectively, our “Site”). Throughout this Privacy Policy, we will refer to you as “you” and “User”.

This Privacy Policy applies to all aspects of our Site. It does not apply to any third party sites (see below for more details). Through your use of our Site and engagement with our products and services, we may collect information from you. This Privacy Policy provides you with information on how we collect, use, share, transfer and store this information, which may include personal information. When we refer to “personal information” in this Privacy Policy we mean any information relating to, describing, capable of being associated with, or that could reasonably be linked, directly or indirectly, with an identified or identifiable natural person such as an individual’s name, home address, telephone number, email address, ‎and payment information.

Your use of the Site is also governed by our Terms of Service. All capitalized terms not otherwise defined herein have the meaning provided in our Terms of Service.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. By using our Site, or ‎otherwise by choosing to provide us with your personal information, you acknowledge and consent to ‎the transfer to and processing of your personal information in Canada and the United States in accordance with this Privacy Policy and as may be ‎further identified when the personal information is collected. We will use this consent as the legal basis for such data transfer, ‎unless otherwise stated in this Privacy Policy. ‎‎

If you do not consent to the processing of your personal information in accordance with this Privacy Policy, ‎please do not access or continue to use any aspect of our Site or otherwise provide ‎any personal information to us. ‎

1. Changes to our Privacy Policy

   We may revise this Privacy Policy, and when we do so, the “Last Updated” date at the top of this webpage will be updated. Your continued use of the Site after the new Privacy Policy is posted constitutes your acceptance of the revised Privacy Policy. In the event we make material changes to the Privacy Policy, we will notify you by placing a prominent notice on the Site. The amended Privacy Policy supersedes all previous versions of the Privacy Policy. For this reason, we encourage you to review this Privacy Policy any time you access or use the Site and to print out a copy of this Privacy Policy for your records.

2. Information That We Collect from You

   We may collect information from you, including personal information, in the following ways:

   • Browsing our Site. We collect certain location information from you, including your IP address, when you browse our Site.
   • Account Creation. You may be able to create an account on the Site. If you choose to do so, you will need to provide your name, mobile phone number and/or email address and create a password. You may be asked to provide other contact information, which we may store if you choose to save it to your account. We will use your account information to track records of transactions that you make and activity that you conduct on the Site.
   • Engaging in Transactions. If you choose to engage in transactions on the Site, we may collect information to enable you to complete such transactions and make or receive payments, which may include your mainnet wallet address, bank account, payment card information and billing address, contact information such as mailing address and mobile phone number, and other information as needed to verify your identity, which may include your passport copy or number, local government identification information or other unique identifiers. Such information will be shared with our third party cryptocurrency exchange partners, payment processors and payment services providers, compliance service providers, custodial service providers, wallet operators, authentication service providers, and others who need the information to process and verify transactions. In addition, information about your transactions, including a summary of your transactions, may be made available to other users interacting with the Site.
   • Customer Service. If you need assistance, you may provide information to our customer service support, which we will use to better your experience and to contact you if we need to follow up on a service request that you’ve made.
   • Promotions and Events. You may have the opportunity to participate in promotional events or engagements, and as part of such events may be asked to provide your name, email address, mobile phone number, and other relevant contact information. We will use this information to assess the progress of the promotion, improve on the promotion and to plan future promotions and engagements. We will use your mailing address or other contact information provided for the promotion to deliver your prize, if applicable, and, if you opt-in, for our own marketing purposes, unless you opt-out. We may also share your information provided to us to other Gambit users to assist them with understanding the nature of their fans, communities, and users engaged with promotions.
   • Your Submissions. You may be permitted to voluntarily submit comments, posts, photos, communications or other materials (each, a “Submission”). By doing so, you grant us certain rights to use such Submissions, including to display such Submissions on the Site. Please see the Terms of Service for more information. Please note that any information you include in a Submission may be made publicly available, therefore please do not include any personal information that you would not like other people to see. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN SUBMISSIONS THAT MAY BE MADE PUBLICLY AVAILABLE.
   • Becoming a User. When you interact as a user on our Site, you may provide us with information about yourself, including your name, your screen name, alias or preferred nickname, your contact information, including your email address and social media and social messaging handles, headshot, photos or bio to be used to create and maintain your profile, as well as other information that may be relevant to getting you set up. We will use this information to present your profile to users of the Site, and for other purposes to improve your experience and the experiences of users on the Site.
   • Logging in Through Third Party Sites. You may be able to log in to our Site through a third party site, including social media platforms and other sites. If you do so, the third party sites may pass certain information to us, including your name, your screen name, alias or preferred nickname, your contact information, including your email address and social media and social messaging handles, and other information relevant to your activity on such site. We will use this information to track records of transactions that you make and activity that you conduct on the Site.
   • Collection Through Third Parties. We may engage third parties to collect information from you relating to your engagement with our Site, products and services, including your IP address, country from where you access our Site, cookie information, hardware and software information and other analytics and technical information. These parties include data analytics vendors and related companies. We may use this information to analyze the effectiveness of our products and services and to understand your preferences and interactions with our Site, products and services. We may also combine this information with other data that we already have about you.

   We only collect personal information that we need. We encourage you to not provide us with any ‎personal information beyond what is necessary and as requested by us.‎

3. Cookies and Tracking Technologies

   We may collect certain personal information using cookies and other technologies such as web beacons, device IDs, advertising IDs, geolocation, HTML5 local storage, Flash cookies, and IP addresses. We use these technologies to provide you with an improved user experience on our Site, including to save your preferences for future visits to our Site. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization, performance/analytics, and advertising.

   Some of our third party vendors may collect your personal information. You may manage your preferences with third party vendors in accordance with their privacy policies and other terms of use.

   We do not currently honor “Do Not Track” signals.

   If you disable cookies, adjust privacy settings on your device, restrict local storage, or otherwise limit these technologies, you may not be able to use some of our Site features.

4. How We Use Information

   In addition to the purposes described in Sections 2 and 3 above, we use your information for the following purposes:

   • To keep in touch with you about your transactions on the Site and to let you know about changes to our policies, when applicable;
   • To learn about your preferences and activities in order to improve our Site and our products and services;
   • To maintain our legal and business obligations relating to internal controls, document retention and record keeping;
   • To gather and analyze aggregate data about Site traffic and engagement, which may include anonymizing your information in a manner that it is no longer identifiable;
   • To improve our content, promotions and advertising; and
   • To accomplish other business purposes as described in this Privacy Policy.

5. How We Share Information

   We may share or disclose your personal information to the following categories of third parties and for the following reasons:

   • To provide to service providers and vendors who perform services for us and on your behalf in relation to your transactions and interactions on the Site. These third parties may use your information to provide you with services, but they will not use your information for their own marketing purposes without your consent;
   • To third party advertising networks and other advertising companies, to help us serve advertisements;
   • To law enforcement and other parties in order to comply with a law, regulation, legal process, or investigation, including to protect the rights of our users; and
   • To effectuate a sale of assets, merger, acquisition, reorganization, bankruptcy, or other transaction. In the event of such a transaction, you grant us the right to assign the personal information collected via the Site.

   In addition, any information that is not personal information or that is aggregated and/or de-identified in a manner that may no longer be associated with you may be shared by us in our discretion with third parties.

   Your personal information that we collect may be processed outside of Canada but only in relation to ‎the purposes described in this Privacy Policy. As a result, your personal information may be accessible to law enforcement and ‎regulatory authorities in accordance with other jurisdictions’ applicable laws.‎

6. Third Party Advertising

   We sometimes use third party ad networks and other advertising companies to serve advertisements on and off our Site. In the European Union (“EU”), the EDAA provides additional information at http://www.youronlinechoices.eu/. Please note that opting-out does not mean you will no longer receive online advertising.

7. Information from Children

   We do not knowingly collect information online from children under 13. If you become aware that a child has provided us with their information, please contact us by sending an email to [email protected]. If we become aware that a child under 13 has provided us with their information, we will take steps to remove the data without delay.

8. Legal Bases for Processing Your Personal Information

   Consent

   We will process your personal information only with your knowledge and consent, except where ‎exempted, required or permitted by applicable law. The form of consent may vary depending on the ‎circumstances and the type of information being requested. Your consent may be express with clear ‎options to say “yes” or “no”, such as by being asked to check a box to indicate your consent, or ‎implied, such as when you provide us with your address through a form or email seeking information ‎and we use those means to respond to your request. Taking into account the sensitivity of your personal information, purposes ‎of collection, and your reasonable expectations, we will obtain the form of consent that is appropriate ‎to the personal information being processed. By using our Site or otherwise ‎by choosing to provide us with your personal information, you acknowledge and consent to the ‎processing of your personal information in accordance with this Privacy Policy and as may be further identified ‎when the personal information is collected. When we process your personal information for a new ‎purpose, we will document that new purpose and ask for your consent again.‎ If you do not want to provide personal information to us that we request from you, you can choose not to provide it. Depending on what the personal information is that you choose not to provide, we may not be able to provide certain services or products.

   You may refuse to provide consent or may notify us at any time that you wish to withdraw or change ‎your consent to the processing of your personal information without penalty, subject to legal or ‎contractual restrictions and reasonable notice by (i) changing your privacy preferences through the ‎Site, (ii) deleting your account with us and stopping use of our Site, or (iii) opting out of the use of your personal information by emailing us at [email protected]. However, if you withdraw or change your consent, we may not be ‎able to provide you with access to or full use of our Site.‎

   Other Legal Bases ‎

   Aside from consent, we may also process your personal information under other legal bases, as ‎permitted by the applicable law. ‎

9. Marketing Messages

   We are committed to compliance with Canada’s Anti-Spam Legislation (“CASL”). Any electronic ‎communication we send to outside parties is protected by a range of business procedures, processes ‎and policies to ensure that such communication is done in compliance with CASL. In our electronic ‎communications with outside parties, we comply with the rules established by CASL and enforced by ‎various Canadian authorities including the Canadian Radio-television and Telecommunications ‎Commission. CASL regulates, and our policies generally apply to, each commercial electronic message ‎‎(a “CEM”) that we send. A CEM is an electronic message sent to an electronic address that, among its ‎purposes, encourages participation in a commercial activity.‎

   In addition to adopting and updating this Policy, we undertake various transparency initiatives to ‎ensure we comply with CASL, which include:‎

   • Consent— we do not send you CEMs without your consent. This consent typically must be ‎‎“express” (expressly acknowledged by you), but in certain circumstances can be “implied” or ‎specifically exempt from consent requirements. We modified or adopted our sign-up, ‎registration and consent forms in order to ensure that your consent is meaningful (i.e. ‎informed and freely given) as per CASL. When we collect your electronic contact information, ‎you will know the exact purposes behind the collection.‎
   • Content— we adopted processes to ensure that our CEMs contain the following requirements ‎prescribed under CASL, which will usually be in the footer of the CEM. We will:‎
     • Identify ourselves as the party sending the CEM, and whether we are sending the ‎message on our own behalf or on behalf of someone else;‎
     • Provide you with our contact information; and
     • Set out a clear, working unsubscribe mechanism or preference centre that is easy to use, ‎automatic, and at no cost to you (other than your own cost of connecting to the ‎Internet).‎
   • Clarity— we ensured that each aspect of a CEM, including its header, content, or any links or URLs ‎in the CEM) conveys the appropriate information, whether viewed individually or taken as a ‎whole, so that you always know what you are clicking on.‎

   If you receive a CEM from us but believe that you should not have or no longer wish to receive CEMs, ‎we will aim to respect your preferences in a timely manner once you update them through our ‎unsubscribe mechanism. CASL requires us to process unsubscribe requests within 10 business days. If ‎you have any questions or concerns about our unsubscribe options, you may contact us at [email protected].‎

10. Requests for Access to and Correction of Personal Information

    Applicable privacy law grants, to varying degrees, individuals the right to access and/or request the ‎correction of errors or omissions in their personal information that is in our custody or under our ‎control. You may request access to and review of your personal information in our possession. ‎However, access may be declined where permitted or required by applicable law.‎

    You may request that we correct your personal information in our possession. We reserve ‎the right not to change any personal information if we do not agree that it is inaccurate or outdated, ‎but will append any alternative text the individual concerned believes appropriate.‎

    If access or a correction cannot be provided, we will notify the individual making the request within 30 days, in writing, ‎of the reasons for the refusal. ‎

11. Data Retention

    Subject to Section 10, we will retain your personal information for as long as you maintain an account or as otherwise necessary to provide you access to and use of the Site. We will also retain your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. When we no longer need to process your personal information for the purposes set out in this Privacy Policy, we will delete your personal information from our systems.