PRIVACY POLICY

1. General
   1. We at UNKJD (“UNKJD“, “We“, “Us“ or “Our“), are committed to protecting the privacy of Our users. As part of this commitment, it is important for Us to be transparent about how We handle the information that We (or others on Our behalf) collect about Our users, when We collect information about them, and how We use such information.
      This privacy policy provides you with information regarding the information collected, processed, and used by UNKJD and others on our behalf on all websites associated with the UNKJD, including  http://unkjd.games  and  http://unkjd.com  and any application related to it (the “Policy“ and the “Website“).
      This Policy is part of and should be read in conjunction with our Terms of Use
      In this Policy, any reference to “Personal Data” is to any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or in combination with additional information that We have or that We have access to
2. When do We collect information about You?
   1. We may collect Personal Data about You in the following circumstances:
      1. When You access or use the Website and the services contained therein (the “Services”); and
      2. When You interact with Us in any manner, including by sending Us an email or through or service channels on third party platforms.
   2. You are under no legal obligation to furnish any information about You, and the furnishing thereof is at Your discretion and at Your own free will. However, if You do not furnish certain information about You, We shall not be able to provide You with some of the Services.
   3. We do not knowingly process information about minors. Any person who provides the Information to us (or to others on our behalf) in connection with the Services represents to us that they are 18 (eighteen) years of age (or such other lawful age – where higher than 18) or older. It is our policy to try and uncover attempts by minors to access the Services, and this may require having to access and verify your Personal Data. We will not accept and take actions to remove from our records any Information which we discover is or was submitted by a minor.
3. What types of information do We collect?
   1. We (or others on Our behalf) may collect the following types of Personal Data about You:
      1. Website usage information: this information includes online activity log, traffic information (including, without limitation, IP address, time of access, date of access, web and mobile page(s) visited, language used, operating system information, your device information, software crash reports and type of browser used, information regarding the device You used, including the hardware model, operating system and version, and other device identifiers. Some of this information may not identify You personally, and therefore does not constitute Personal Data;
      2. Technical Data: Telemetry Information if you use any of our open-source software, including bandwidth upload and download speeds, the amount of free and used storage space on your device and other device statistics. Usage Information, metadata about the files you upload for storage, recordings of instances in which you have used your private key to authenticate communications.
      3. Registration and Wallet information - upon creation of an account with UNKJD account will be associated with your wallet and for that purpose we will collect your wallet ID; amount and types of UNKJD NFT in your wallet; amount of MBS and SOL in your wallet; as well as any other information as the UNKJD may deem necessary to complete Your registration.
      4. KYC AML information - UNKJD may require You to provide additional information for the purpose of compliance with Know-Your-Customer and Anti-Money Laundering legal requirements and best practices. For this purpose, We will use Personal Data that You will provide to Us, and such information may also be combined with other information using crypto-wallet screening services for AML and CFT purposes, such as information available on publicly accessible ledgers and Blockchains, or information relating to Your possible association with known or suspected criminal individuals. Where Your Personal Data is combined with such other information, it is possible that such combination may generate additional Personal Data about You.
      5. Website activity information - whenever you use the Website, We monitor Your use of the Services and record Your activity. The information that We gather about You in this context includes any activity that You perform in the Website, such as searches that You will perform, content that You will view, the length of time You will be watching content on the Website, Your interaction with content in the Website will allow us to monitor the performance of the Website, etc. In addition, your performance in the games that you will play in the Website will be monitored. In this context, we will record the in-game items that you will purchase and/or gain, points that you will purchase and/or gain, in-game performance information, prizes won and/or estimated, rankings in game boards, etc. that you will purchase and/or gain.
      6. Transactions – when you transact with Our NFTs or UNKJD associated coins (MBS and SOL) on the Website and while using the services, We will collect, the details of the transaction, as well as any other information necessary for the performance thereof; Under no circumstances do we collect an unencrypted private key from you. We may also collect and maintain information relating to transactions you affect in your wallet on our Website.
      7. Communication information - when You contact Us, including via Our Website, social media networks or any other communications channels, You may provide Us with Your name, certain contact information (such as email address, social network identifier and telephone number) and the content of Your communication with Us.
      8. Social Sharing – If you use social sharing options and other integrated tools on the Website, UNKJD may gain access to the information you share with Us through these third party tools.
   2. The Personal Data that We gather as mentioned above, include “sensitive personal information”, such as wallet ID and Your account’s login information, in combination with Your credentials used for accessing Your account.
   3. You are responsible for ensuring the accuracy of the information that You provide Us (or others on Our behalf) with. Inaccurate information will affect Our ability to provide You with some of the Services, as well as Our ability to contact You as contemplated in this Policy.
4. The Purposes Of The Processing Of Personal Data And Their Legal Basis
   1. UNKJD will not process Personal Data about you unless there is a legal basis for such processing.
   2. The legal bases according to which We may process Personal Data about you are as follows:
      1. Your consent that UNKJD will process Personal Data about you for one or more specific purposes. By way of example, for the purpose of sending marketing materials to you.
         Where the legal basis for the processing of the Personal Data about you is consent, you may at any time withdraw your consent for the purposes for which you provided your consent by sending a notice free of charge.
         Where you withdraw your consent for the processing of Personal Data about you, We might not be able to provide you with some or all of the Services you requested or in the form intended to be provided to you, and you will have no claim in respect of that.
         
      2. Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract. This refers to all the information required for us to provide you with the Services and grant you access to UNKJD and the various Services offered.
      3. Processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party. By way of example, for the purpose of improving Our Services, or for the exercise or defense of legal claim and conducting KYC and AML.
   3. At any time, you may approach Us by sending a notice to the email address support@unkjd.com in order to receive information concerning the review performed by Us. This is so you can conclude that We may process the Personal Data about you on account of such processing being necessary for the purposes of the legitimate interests pursued by the Company or by a third party.
5. How do We use Personal Data?

   We may use Personal Data about You for the following purposes:

   1. To operate the Website and provide the Services.
   2. To contact You for the purpose of operational requirements.
   3. To personalize content and/or offers to You.
   4. To respond to Your queries, requests and/or complaints.
   5. To send You materials regarding services, events and other information we think will be of interest to you, subject to Your consent.
   6. To analyze and improve the Services, as well as to develop and offer new ones.
   7. To analyze and track usage to determine the usefulness or popularity of certain content and to better understand the online activity of the Website users.
   8. Monitor and analyze trends, usage and activities in connection with the Website and the Services.
   9. To perform and maintain various activities supporting the offering and provision of the Services, including, but not limited to, the Website (such activities include back office functions, business development activities, strategic decision making, financing management, etc.).
   10. To protect Our and third parties’ interests, rights and assets, including detecting, investigating and preventing fraudulent transactions or unauthorized or illegal activities and initiation or exercise or defense of legal claims and preventing.
   11. To fulfil Our legal or regulatory requirements.
6. Sharing of Personal Data
   1. We will not disclose Personal Data about You to third parties except as detailed in this Policy.
   2. We may transfer Personal Data to entities that control Us, entities that are under Our control and/or to entities under common control or ownership with Us, as shall be from time to time (collectively the “Group”). Such entities may use the Personal Data to support the needs of the Group.
   3. We may share Personal Data about You with the following third parties or for the following purposes:
      1. Upon Your consent or instruction;
      2. Third parties providing Us services related to the offering of the Services, including the Website, including with identity-check providers and/or initiate submitting inquiries to data aggregators (such as watch-list checks providers).
      3. Crypto wallet screening services for the purpose of compliance with regulations regarding Anti Money Laundering and Combating the Financing of Terrorism. For this purpose, We use the services of Elliptic Enterprises Limited, who is considered as a separate controller of Your Personal Data, and its  privacy policy describes how it collects and processes Personal Data
      4. In the event that We sell, assign or transfer some or all of Our business or assets to a successor or acquirer, or if We are acquired by or merge with a third party, or if We file for bankruptcy or become insolvent, or any other situation where Personal Data may be sold, assigned or transferred to a successor or acquirer;
      5. To protect Our rights, property and interest or those of third parties;
      6. To fulfil Our legal or regulatory requirements or to comply with a court order.
   4. In the preceding twelve (12) months, We have not sold any Personal Data. are we obliged to keep this? There may be affiliation with third parties.
7. Transfer of Personal Data abroad

   We may transfer Personal Data about You outside the jurisdiction which You are a resident of and store it in other jurisdictions and countries; the data protection and other laws of these jurisdictions or countries may not be as protective to Personal Data as those in the jurisdiction which You are resident – in these instances, We will take steps to ensure that an appropriate level of protection is given to Your Personal Data. If you are an EEA resident, please note that these safeguards and protection will be available if any of the following are met:

   1. The transfer is to a third country or an international organization that the EU Commission has decided provides an adequate level of protection to the Personal Data that is transferred to it pursuant to Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR“);
   2. The transfer is according to a legally binding and enforceable instrument between public authorities or bodies pursuant to Article 46(2)(a) of the GDPR; or
   3. The transfer is in accordance with standard data protection clauses adopted by the EU Commission pursuant to Article 46(2)(c) of the GDPR. The clauses adopted by the EU Commission can be viewed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
      You may request that the Company provide you with details concerning the safeguards employed by it to protect the Personal Data about you that are transferred to a third country or an international organization, by sending an email to the following address: support@unkjd.com
8. Retention of Personal Data
   We will retain Personal Data about You only for as long as necessary for the fulfillment of the purposes for which such Personal Data is collected. We may retain Personal Data about You for longer periods, if We find it necessary to comply with legal requirements applicable to Us.
9. Marketing communications
   1. You may allow Us to provide You with communications from Us, as well as from third parties, either in connection with the Services or in connection with other products and services.
   2. You may opt-out from receiving communications from Us by sending a blank e-mail to Us to support@unkjd.com and/or by clicking on the unsubscribe link available in Our e-mails sent to You.
10. Cookies
    1. We (or others on Our behalf) use various technologies to collect information when You interact with the Website, including cookies and web beacons. Cookies, which are small text files that are placed on Your computer or equipment when You visit certain online pages, track your activities, record Your preferences, and make the Website more responsive to Your needs by delivering a better and more personalized experience to You. The cookies are stored on Your computer and/or other equipment and are used by Us to help track your clicks and pass information as You go through the Website and can allow Us to associate navigational information from browsing visits with Personal Data You provide via the Website. Web beacons are graphic images that are placed on the Website or in an email that is used to monitor Your behavior while visiting the Website or sending the email and are often used in combination with cookies.
    2. You can change the privacy settings in the browser that You use, delete the existing cookies, prevent the creation of cookies or click the setting that enables You to accept or deny the creation of a cookie every time that a cookie is detected. If You opt to not accept cookies and/or cancel Your acceptance of cookies, You will be limiting Your ability to enjoy all of the interactive features on the Website.

    Types of cookies:

    The cookies We may use have been classified according to their functionality, as follows:

    
    

    Type of Cookie	Purpose	Additional Information
    Strictly Necessary Cookies	These cookies are strictly necessary to enable you to navigate the Platform and use features you have requested. They are used to provide you with Our content, products, and services that you have requested. Such cookies are essential to help your device download or stream information so that you can navigate around the Platform, use its features, and return to pages you have previously visited.	These cookies collect Personal Data about you, such as user name and last login date, and identify you as being logged in to the Platform. These cookies are deleted when you close your web browser (session cookies).
    Functionality Cookies	These cookies are used to recognize you when you return to the Platform and allow Us to remember your choices and preferences.	These cookies survive the closing of your web browser, and last until their applicable expiry time.
    Performance Cookies	These cookies are used to provide aggregated statistics in respect of the performance of the Platform and to test and improve such performance, in order to provide better user experience. In addition, they allow Us to carry out analytical functions on the Platform.	These cookies collect anonymized data that is not related to an identified or identifiable natural person. These cookies are valid for varying periods; some are deleted once you close your browser, while others have an indefinite validity period.
    Third Party Marketing/Targeting Cookies	These cookies are used to deliver ads and marketing communications, and to display the Platform in a manner that is more relevant to you. They are also used to measure the effectiveness of an advertising campaign. These cookies record your visit to the Platform and the pages you have visited.	Some of these cookies are provided and used by third parties. These cookies are valid for varying periods; some are deleted once you close your browser, while others have an indefinite validity period.

    Blocking and removal of cookies
    You can change your browser settings to block and delete some or all cookies. Please see below links to instructions on how to do this in respect of some of the most popular web browsers:

    1. Firefox
    2. Internet Explorer
    3. Microsoft Edge
    4. Google Chrome
    5. Safari

Please note, however, that if you do so, some or all of the Services’ features and functionalities might not perform as intended.
We use mobile analytics software to allow us to better understand the functionality of Our Website on your device. This software may record non personal information such as how often you use the Website, the events that occur within the Website, aggregated usage, performance data, etc.
Our Services may contain third party tracking tools from our service providers. Such third parties may use cookies, APIs, and SDKs in the Services to enable them to collect and analyze user information on our behalf. The third parties may have access to information such as your device identifier, MAC address, geo-location information, and IP address for the purpose of providing their services under their respective privacy policies. This Policy does not cover the use of tracking tools from third parties. We do not have access or control over these third parties.
The use of third party advertising services, allow us to offer our Services for profitable price. You may use third party tools, not supported by Us to opt-out of tailored advertising. This will not prevent the presentation of advertisements in the Platform.
If you are interested in more information about tailored advertising and your choices to prevent third parties from delivering tailored web and mobile web advertising you may visit the following websites:


1. Network Advertising Initiative Consumer Opt-Out Page or the Digital Advertising Alliance Opt-Out Page for U.S.-based advertising;https://optout.aboutads.info/?c=2&lang=EN
2. the NAI  Consumer Opt-Out Page - https://optout.networkadvertising.org/?c=1
3. Your Online Choices website for EU-based advertising  https://www.youronlinechoices.com/

ONLINE TRACKING NOTICE - AT THIS TIME, THIS SERVICE DOES NOT SUPPORT DO-NOT-TRACK SIGNALS.

11. Security

    We have implemented suitable security policies, rules and technical measures to protect and safeguard the Personal Data under Our control from unauthorized access, improper use or disclosure, unauthorized modification, or unlawful destruction. However, any storage of Personal Data and especially, the transfer thereof via the internet cannot be fully secured, and therefore We cannot promise absolute protection of Your Personal Data.

12. Disclaimer

    We cannot guarantee, nor do We represent, that there will be error-free performance regarding the privacy of Your Personal Data, and We will not be liable for any indirect, incidental, consequential, or punitive damages relating to the use or release of Personal Data about You including, but not limited to, disclosure of Personal Data due to errors in transmission, unauthorized third-party access, or other causes beyond Our reasonable control.

13. Links to Other Websites
    1. The Website may contain links to websites and/or applications of third parties. Other websites and applications may also reference or link to Our Website. We do not control such websites and applications, nor the collection and/or processing of Personal Data about You by such websites and applications, and thus We are not responsible for the privacy practices. This Policy does not apply to any actions taken via such websites and/or applications.
    2. Whenever You access such third parties’ websites and/or applications, We recommend that You carefully review their privacy policies prior to using such websites and/or applications and prior to disclosing any Personal Data about You.
    3. The Website may offer social sharing features, links to social media and other integrated tools. Your use of such features enables the sharing of information with the social network operator, your contacts and/or the public, depending on the settings you use with the entity that provides the social sharing feature or social media. Please visit the privacy policies of the entities that provide these features to obtain more information about the purpose and scope of data collection and the processing of such data by such entities.

14. If you reside in the EEA, please read below with respect your rights in respect of the Personal Data about you:

    1. You are entitled to the following rights in respect of the Personal Data about you. To exercise such rights, you may send a request to exercise your rights to the following email address:support@unkjd.com
    2. Right of access
       1. You have the right to receive from the Company confirmation as to whether or not Personal Data about you is being processed, and, if that is the case, access to the Personal Data and the following information: (1) the purposes of the processing; (2) the categories of Personal Data concerned; (3) the recipients or categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries outside the European Economic Area (EEA) or international organizations; (4) if possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; (5) the existence of the right to request from the Company rectification or erasure of Personal Data or restriction of processing of Personal Data about you or to object to such processing; (6) the right to lodge a complaint with a supervisory authority; (7) if the Personal Data is not collected from you, any available information as to its source; (8) the existence of profiling; and (9) if Personal Data is transferred to a third country outside the EEA or to an international organization, the appropriate safeguards relating to the transfer.
       2. The Company shall provide a copy of the Personal Data undergoing processing and may charge a reasonable fee for any further copies requested by you. If you make the request by electronic means, and unless otherwise requested by you, the information shall be provided in a commonly used electronic form.
       3. The right to obtain a copy of the Personal Data shall not adversely affect the rights and freedoms of others. Therefore, if the request harms the rights and freedoms of others, the Company may not fulfill your request or do so in a limited manner.
    3. Right to rectification

       You have the right to obtain from the Company the rectification of inaccurate Personal Data about you. Taking into account the purposes of the processing, you have the right for incomplete Personal Data about you to be completed, including by means of providing a supplementary statement.

    4. Right to erasure
       1. You have the right to obtain from the Company the erasure of Personal Data about you if one of the following grounds applies: (a) the Personal Data is no longer necessary in relation to the purpose for which it was collected or otherwise processed; (b) you withdraw your consent on which the processing is based and there is no other legal ground for the processing; (c) you object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by Us or by a third party, and there are no overriding legitimate grounds for the processing; (d) you object to the processing of Personal Data about you for direct marketing purposes; (e) the Personal Data has been unlawfully processed; or (f) the Personal Data about you has to be erased for compliance with a legal obligation in European Union or Member State law to which the Company is subject.
       2. This right is not applicable to the extent that the processing is necessary (a) for compliance with a legal obligation that requires processing by European Union or Member State law to which the Company is subject; or (b) for the establishment, exercise, or defense of legal claims.
    5. Right of restriction of processing
       1. You have the right to obtain from the Company the restriction of processing of Personal Data about you if one of the following applies: (a) the accuracy of the Personal Data is contested by you, for a period enabling the Company to verify the accuracy of the Personal Data about you; (b) the processing is unlawful and you oppose the erasure of the Personal Data about you and request the restriction of its use instead; (c) the Company no longer needs the Personal Data about you for the purposes of processing, but the Personal Data is required by you for the establishment, exercise, or defense of legal claims; (d) if the processing of Personal Data about you is necessary for the purpose of the legitimate interests pursued by the Company or by a third party, unless We demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims; or (e) if the Personal Data about you is processed for direct marketing purposes, including profiling, to the extent it is related to such direct marketing.
       2. If the processing of Personal Data about you has been restricted following your request, such Personal Data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.
    6. Right to data portability
       1. You have the right to receive the Personal Data about you, which you have provided to the Company, in a structured, commonly used, and machine-readable format, as well as the right to transmit such Personal Data to another controller, if (a) the processing is based on your consent or on a contract to which you are a party, and (b) the processing is carried out by automated means.
       2. In exercising your right to data portability, you have the right for the Personal Data about you to be transmitted directly from the Company to another controller, where technically feasible. The exercise of your right to data portability is without prejudice to your and the Company’s rights under your right to erasure. In addition, the right to data portability shall not adversely affect the rights and freedoms of others.
    7. Right to object
       1. You have the right to object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by the Company or by a third party, including profiling based on such legitimate interests. In such case, We shall no longer process the Personal Data about you, unless We demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.
       2. You have the right to object at any time to the processing of Personal Data about you for direct marketing purposes, including profiling, to the extent it is related to such direct marketing.
    8. Right to withdraw consent

       You may withdraw your consent provided to Us for the purpose of processing Personal Data about you at any time, without affecting the lawfulness of processing based on your consent before its withdrawal.

    9. Right to lodge a complaint with a supervisory authority

       You have the right to lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights and freedoms of natural persons in relation to the processing of Personal Data within the European Union.

    10. Your rights in respect of Personal Data about you as outlined in this section may be restricted by European Union or Member State law to which the Company is subject.

    11. We shall provide you with the information requested according to your rights outlined in this section without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We shall inform you of any such extension within one month of receipt of your request, together with the reasons for the delay.

    12. The information requested according to your rights outlined in this section shall be provided free of charge, unless stated otherwise. Where requests are manifestly unfounded or excessive, in particular because of their repetitive character, We may either (a) charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested; or (b) refuse to act on the request.

    13. The Company may require you to provide additional information necessary to confirm your identity in order to fulfill your request according to your rights outlined in this section, if We have reasonable doubts concerning the identity of the natural person making the request.

15. If You reside in the U.S.A, please read below with respect to the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), the Virginia Consumer Data Protection Act (VCDPA), and the Colorado Privacy Act (CPA)) rights You might have:

    Right	Scope
    Right to know	You have the right to receive the following information: What types of Personal Data collected; What are the types of sources of the Personal Data collected; To what end We collect, sell or share the Personal Data (if at all); Types of third parties to whom We disclose Personal Data, if any; and The specific pieces of Personal Data We have collected about you.
    Right to Correct	Taking into account the nature of the Personal Data and the purposes of the processing thereof, You have the right to request that We correct inaccurate Personal Data about You.
    Right of Erasure	You may ask Us to delete Your Personal Data and direct Our service providers to do so. Please note that We may not delete Your Personal Data if it is reasonably necessary to complete Our legal obligation to You to provide the Services or otherwise protect Our legal rights, comply with an existing legal obligation; or use Your Personal Data, internally, in a lawful manner that is compatible with the context in which You provided the information.
    Right to Limit Use and Disclosure of Sensitive Personal Data	You have the right to request that We limit Our use or disclosure of your “sensitive personal information” that we collected from You. We may deny Your limitation request if the use and/or disclosure of the information is necessary for Us to perform Our Services or provide the goods or Services as reasonably expected by an average consumer.
    Right to Non-Discrimination for the exercise of your privacy rights	You have the right to not be discriminated against by Us because You exercised any of your rights under the CCPA.
    Right to Non-selling or Sharing	You may ask Us to not sell or share Your Personal Data.
    Right to designate an authorized agent to submit CCPA requests on your behalf	You may designate an authorized agent to make a request under the CCPA on your behalf. To do so, you need to provide the authorized agent written permission to do so and the agent will need to submit to Us proof that such agent has been authorized by you. We will also require that you verify your own identity, as explained below.

    
    

    In order to exercise Your rights, please contact Us by sending Us a message to the following address: support@unkjd.com

16. Changes to the Policy

    We may change this Policy in Our sole discretion at any time. Any revisions to this Policy will be posted as an updated version accessible via the Website home page. We recommend that You revisit this Policy regularly so as to be kept apprised of any such changes.

17. Contact Us

    For any queries relating to this Policy and data protection, please contact Us at support@unkjd.com