DAPPER LABS’ BETA APPLICATION PRIVACY POLICY

DISNEY PINNACLE

The following privacy policy and notice applies to your involvement in a closed-beta (“Beta Trial”) of Dapper Labs, Inc.’s application (the “App”, or “Pinnacle”) for viewing, collecting, buying and trading showcase digital tokens containing licensed content from the Walt Disney Company, its affiliates and subsidiaries (“Disney”).  Your privacy is important to us, and Dapper Labs Inc (“we” “us” and “our”) is committed to taking care of your personal information..  We respect your privacy rights and are committed to protecting any necessary personal information that is collected during the Beta Trial.  This privacy policy describes what information we collect and how we use, disclose, transfer, and store it. If you do not want us to collect, store, use or share your information in the ways described in this Privacy Policy, you may not be able to access the App or participate in the Beta Trial.  This Privacy Policy is to be read in conjunction with the Dapper Service Privacy Policy related to use of your Dapper Labs e-wallet or other services that you have requested Dapper Labs perform outside of the Beta Trial.  This Privacy Policy does not pertain to any activities that you may engage directly with Disney outside of the Beta Trial or your use of the Services. 


Dapper Labs collects, stores, and uses your information as a data controller in connection with, and in order to provide and develop, the App and any services ancillary to the Beta Trial (collectively referred to as the “Services”) in accordance with this privacy policy (“Privacy Policy”).


NO Minor Personal Information (Not for children under the age of 18):


The Beta Trial is not intended for any persons under the age of eighteen (18) years old.  


All of our Services, including: 


– the Beta Trial; 


– the App, whether used via mobile or PC, console platforms or via website; 


are governed by this Privacy Policy.


By participating in the Beta Trial and using the Services, you hereby consent to this Privacy Policy.


This Privacy Policy is effective as of [August 21], 2023.


If you have any questions, comments or concerns regarding this Privacy Policy and/or Dapper Labs’ privacy practices, please refer to the “How to Contact Us” section below. 

1. HOW WE COLLECT INFORMATION

Dapper Labs collects information from you when you: 

a. Respond to emails regarding the Beta Trial;

b. Fill out a survey regarding your potential invitation to the Beta Trial;

c. Access the Services and/or create an account for the Services;

d. Make a purchase within the App; 

e. Sign up for an App-related newsletter;

f. Sign up for any promotional offers associated with the Services;

g. Contact Dapper Labs’ customer support/customer service;

h. Enter any contest, event or sweepstakes, or participate in any games or activities sponsored by Dapper Labs related to your involvement in the Beta Trial;

i. Connect with chat and/or otherwise interact with other users of the Services;

j. Submit feedback (either solicited or unsolicited) related to your use of the Services or involvement in the Beta Trial; or

k. Share or contribute to our social media channels and other community websites  


2. INFORMATION WE COLLECT

Dapper Labs collects only the necessary and relevant information limited to the purposes defined hereunder for purposes of offering the Services and any ancillary activities related to the Beta Trial.

a – Information you provide us

• Contact information (such as your email address)

• Your username and password

• Profile information 

• Information that you provide when seeking help from our customer service (such as chat logs, contact details such as your phone number and email address if necessary to resolve your request, and customer support tickets)

• Other information you provide us (such as information used to identify a lost account)

b – Information we automatically collect directly from you when you use our Services 

• Information about your use of the App, including your purchasing/collecting activity

• Information about your interactions with other users during the Beta Trial or during your use of the Services

• Information about your browsing activities, which we collect using cookies and similar tracking technologies included as part of the App and the Beta Services, if applicable (please note that cookies are only set in the web environment, we do not use them in the App itself—you can refer to our Cookies Policy to learn more about opting out of such technologies)

• IP address and device identifiers (such as your device ID)

• Information about your device (such as device name, operating system, and browser information (including browser type and the language you prefer))

• Account ID or identifier/handle

c – Information we obtain from our partners

• Information we may receive about you from Disney;

• Information we may receive about you from third party billing providers (when you make purchases during the Beta Trial while accessing the App or using the Services)

• Information we may receive about you from third-party analytics providers for analytics purposes (third-party analytics providers may be involved for tracking, analytics and/or technical purposes, within the Beta Trial, so we can provide you with better Services)



3. HOW WE USE INFORMATION COLLECTED

Under normal circumstances, we only collect personal information from you when:

• we obtain your consent to do so

• we have a legal obligation to collect and process your personal information 

• we need the personal information to fulfill a contract with you and provide you with the Services (including, among other things, providing customer support services, bug and service-error detection, and fraud prevention)

• the processing is in our legitimate interests (when we analyze your in-App activities, and protect and improve our products and services)

During the Beta Trial we will use the information you provide to Dapper Labs in order to perform the Services and to make the App better by improving it based on your feedback and a review of any submission you make through customer service or customer support channels.  Our primary use of your personal information during the Beta Trial will be as follows:

3.1 – To operate our business and to enhance your experience, including to:

• provide you with the App and Services during the Beta Trial

• provide in-App experiences that you may be interested in or have subscribed to based on your activities in-App and during the Beta Trial 

• track your use of the Services and in-App activities to help us learn more about user engagement, preferences and tendencies, so that we can personalize your experience, provide you with in-App offers and notifications that are tailored to you, and otherwise enhance your in-App experience

• enhance the Services, as Dapper Labs configures the App and its functionality during the Beta Trial 

• offer you the opportunity to take part in further testing or small group sessions to share your feedback and experiences

• protect against crime or fraud, or for other security reasons

• identify and/or fix bugs and Service errors

• use it for administration, analytics, research, and optimization

• compile statistics

• comply with all regulatory and legal requirements, and answer any requests from authorities or any law enforcement agency

• comply with security requirements (e.g. performing audits)

3.2 – To provide you with support, communicate with you, and respond to any requests or questions you have submitted through our customer support.

3.3 – To personalize our communication with you, including to:

• handle your subscription to, and opting-out of, our emails and newsletters

• contact you to promote our Services and any surveys or contests we may offer

• to send you, with your prior consent, promotions or marketing materials (we will provide you with the opportunity to opt out of receiving such materials in the future)

• offer in-App or email surveys

• personalize your in-App content and offers

3.4 – With your express consent, to securely share your account identifiers with selected partners, including Disney, for the sole purpose of improving the Services’ advertising campaigns on external sites. 

3.5 – For some of the purposes described above, Dapper Labs may use and perform analytics. Analytics information supports business analysis and operations, allows product development, improves products and Services, personalizes content, and makes recommendations. 


4. WHAT INFORMATION WE RETAIN AND FOR HOW LONG

Dapper Labs retains, uses and stores your information for as long as you are using our Services, and up to five (5) additional years thereafter, which may be necessary to fulfill all the purposes described in this Privacy Policy and comply with applicable laws.. 

We want to inform you that a longer retention period could be required to resolve disputes, or to answer regulatory or police requests. In such cases, the collected information will be used and stored until the request is closed. 


5. SHARING YOUR INFORMATION

5.1 – With Disney

In order to operate the Services, we may share your personal information with Disney or its subsidiaries, processors or third parties.

5.2 – With other third parties

With your consent we may share your personal information with Disney.  We may also share your personal information with vendors or agents working on our platform in order to provide the Services to you.  For example, companies we have hired to provide cloud hosting services, off-site backups, and customer support may need access to personal data to provide those functions. In such cases, these companies are required to abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. If you have questions or concerns about any of our vendors, feel free to contact us at the email listed at the end of this Privacy Policy.

While using our Services, whenever you decide to and where this option is available, you may use social sharing features to third-party social network sites. This may allow the sharing and collection of personal and non-personal information both to and from such third-party social networks. You should visit the policies of such third parties for more information about their information collection practices.

5.3 – With authorities

Dapper Labs reserves the right to report to law enforcement agencies activities that we, in good faith, believe to be illegal. We will investigate or take action to counter illegal activity, suspected abuse or unauthorized use of the Services during the Beta Trial, or to protect the property or safety of others. We may also disclose your information if required by any law or court order worldwide, if the information relates to actual or threatened harmful conduct. In that case, we will consider applicable local laws, the nature of the order, as well as the legitimacy and proportionality of your information.


6. INFORMATION SECURITY

We have implemented security measures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the personal information collected during the Beta Trial through the Services. 

We take, and will require any applicable third parties to take, reasonable precautions to protect your personal information against loss, misuse, unauthorized disclosure, alteration, and destruction. However, there is no guarantee that electronic transmissions are fully secure and while we will make efforts to ensure the safeguard and confidentiality of your personal information, there is always a risk of interception or breach by an unauthorized party. We will not be held responsible for unauthorized access to your information to the extent such events are out of the control of Dapper Labs.  When we use third parties to assist us in processing your personal information or credit card information, we take reasonable steps to ensure that they comply with this Privacy Policy and otherwise protect your personal information (including any credit card information).

If there is a breach of security involving your personal information, including credit card information, in-App or during our Beta Trial while using our Services, we will inform you promptly in accordance with your local regulations relating to the notification of information security breaches, and take commercially reasonable steps to remediate the effects of such breach.

If you believe your personal information is being improperly used by us or any third party, please immediately notify us via email at [email protected]


7. MINOR CHILDREN’S INFORMATION

As set forth at the outset of this Privacy Policy, the Beta Trial and the Services are not intended for anyone under the age of eighteen (18).  


8. YOUR DATA RIGHTS

You can exercise your rights at any time and, subject to verification of your identity, ask Dapper Labs to:

-Provide you with access to your personal information - this will allow you to know what information has been collected by Dapper Labs pursuant to this Privacy Policy;

-Correct/modify your information - this will allow you to submit changes or to correct mistakes or change your name if necessary;

- Not sell your information - this will instruct Dapper Labs not to share your information with any third-party advertisers or engage in any activities that may be deemed a ‘sale’ of your information;

-Erase/Delete your information - this will instruct Dapper Labs to delete the personal information that it has collected about you; note that your information may be required to allow Dapper Labs to perform its Services and therefore you may not be able to access some or all of the Beta Trial or Services if you request that your information be erased or deleted;

- Port your information - this allows you to instruct Dapper Labs to deliver your information to you in a format that is currently used by Dapper Labs (please allow reasonable time for Dapper Labs to complete this task);

-Appoint an agent - in some circumstances you may be able to appoint/designate an agent to request any of the aforementioned actions; note that Dapper Labs may request authorization and verification of any proposed agents prior to completing any requests by such agents.

We ask that you keep the information that you provide to us updated. You can correct any information you have provided by contacting us at the email listed at the end of this Privacy Policy. You represent and warrant that all information you provide us is true and correct, and relates to you and not to any other person.

If you have previously consented to any direct marketing communication from us or subscribed to our newsletters, you can unsubscribe by clicking on a link available in each communication and newsletter we send you.

If you want to decline, to allow, or to set your preferences regarding the use of cookies or other tracking technologies, please refer to our Cookies Policy in the Dapper Services Privacy Policy. Please note that this Cookies Policy applies to the Dapper Labs offered website only (not applicable to the App). 

Please note that in-App functionality, Services and features offered during the Beta Trial can be affected by your actions. Some of your information and its processing is mandatory for Dapper Labs to provide the Services. Enforcement of your data rights may force Dapper Labs to cease providing the Services or unenroll you from the Beta Trial. 


9. CALIFORNIA USER INFORMATION 

The California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA) permit California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has collected, shared with, and/or sold to third parties for a business or commercial purpose during the immediately preceding calendar year. Please note that we do not sell your personal information to provide the Services or the App or during the Beta Trial as described in this Privacy Policy. Our partners and providers who work with us may have access to your personal information in order to provide you with the Services within the limits and throughout the duration of the Beta Trial, but they can’t reuse your personal information for any other purposes and will not sell your data. 

To exercise your rights, please access this form or refer to the “How to contact us” section of this Privacy Policy.

If you submit a request on behalf of another person, you need to be 18 years old or over, and we may require a proof of authorization and verification of identity directly from this person.

In some instances, we may inform you that we were not able to complete your request.  Examples of such situations include where we cannot verify that you have the authority to make a request on behalf of another person, or when an exception applies, such as when the disclosure of personal information would adversely affect the rights and freedoms of another consumer or when the personal information that we maintain about you is not subject to the CCPA/CPRA’s access or deletion rights.

The exercise of any of the rights mentioned above will not have any discriminatory consequences for you. 

10. ADDITIONAL INFORMATION FOR EU RESIDENT (DATA SUBJECT)

If you are a European Union resident Data Subject, we will transfer personal data from the European Economic Area and Switzerland to other countries such as the United States, some of which have not been determined by the European Commission to have an adequate level of data protection. When we engage in such transfers, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections travel with your data. To learn more about the European Commission’s decisions on the adequacy of the protection of personal data in the countries where Dapper Labs processes personal data, please visit: ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm.


11. THIRD PARTY SERVICES

The Services may link to external sites that are beyond our control. This Privacy Policy only covers the way we treat personal information and non-personal information we collect during the Beta Trial while offering the Services. By accessing any external sites, you agree to the privacy policies of those sites. Please understand that external sites may have different policies with respect to the collection, use and disclosure of your personal information. Dapper Labs has no control over, and are not responsible for, the privacy practices of such third parties.


12. CHANGES TO THIS POLICY

We reserve the right to change this Privacy Policy at any time. In the event that we make material changes to this Privacy Policy, they will be re-posted in the "Privacy" section of our website and may require that you agree to any new Privacy Policy terms in the App as a condition to your continued access to the Beta Trial.  If you would like further information about any recent changes made, please send your request to [email protected] and include “Information about Changes” in the subject line. 


13. LEGAL

This Privacy Policy is governed by the laws of your country of residence. Any dispute arising from the use of the Services shall be submitted to the competent courts of your country of residence. 


14. CONTACT US

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please contact us:

1. by sending an email to [email protected]

2. by writing to the 565 Great Northern Way #600, Vancouver, BC V5T 0H8, Canada

DAPPER LABS’ BETA APPLICATION PRIVACY POLICY – DISNEY PINNACLE™

The following privacy policy and notice applies to your involvement in a closed-beta (“Beta Trial”) of Dapper Labs, Inc.’s application (the “App”, or “Pinnacle”) for viewing, collecting, buying and trading showcase digital tokens containing licensed content from the Walt Disney Company, its affiliates and subsidiaries (“Disney”).  Your privacy is important to us, and Dapper Labs Inc (“we” “us” and “our”) is committed to taking care of your personal information..  We respect your privacy rights and are committed to protecting any necessary personal information that is collected during the Beta Trial.  This privacy policy describes what information we collect and how we use, disclose, transfer, and store it. If you do not want us to collect, store, use or share your information in the ways described in this Privacy Policy, you may not be able to access the App or participate in the Beta Trial.  This Privacy Policy is to be read in conjunction with the Dapper Service Privacy Policy related to use of your Dapper Labs e-wallet or other services that you have requested Dapper Labs perform outside of the Beta Trial.  This Privacy Policy does not pertain to any activities that you may engage directly with Disney outside of the Beta Trial or your use of the Services. 

Dapper Labs collects, stores, and uses your information as a data controller in connection with, and in order to provide and develop, the App and any services ancillary to the Beta Trial (collectively referred to as the “Services”) in accordance with this privacy policy (“Privacy Policy”).

NO Minor Personal Information (Not for children under the age of 18):

The Beta Trial is not intended for any persons under the age of eighteen (18) years old.  

All of our Services, including: 

– the Beta Trial; 

– the App, whether used via mobile or PC, console platforms or via website; 

are governed by this Privacy Policy.

By participating in the Beta Trial and using the Services, you hereby consent to this Privacy Policy.

This Privacy Policy is effective as of [August 21], 2023.

If you have any questions, comments or concerns regarding this Privacy Policy and/or Dapper Labs’ privacy practices, please refer to the “How to Contact Us” section below. 

15. HOW WE COLLECT INFORMATION

Dapper Labs collects information from you when you: 

l. Respond to emails regarding the Beta Trial;

m. Fill out a survey regarding your potential invitation to the Beta Trial;

n. Access the Services and/or create an account for the Services;

o. Make a purchase within the App; 

p. Sign up for an App-related newsletter;

q. Sign up for any promotional offers associated with the Services;

r. Contact Dapper Labs’ customer support/customer service;

s. Enter any contest, event or sweepstakes, or participate in any games or activities sponsored by Dapper Labs related to your involvement in the Beta Trial;

t. Connect with chat and/or otherwise interact with other users of the Services;

u. Submit feedback (either solicited or unsolicited) related to your use of the Services or involvement in the Beta Trial; or

v. Share or contribute to our social media channels and other community websites 


16. INFORMATION WE COLLECT

Dapper Labs collects only the necessary and relevant information limited to the purposes defined hereunder for purposes of offering the Services and any ancillary activities related to the Beta Trial.

a – Information you provide us

• Contact information (such as your email address)

• Your username and password

• Profile information 

• Information that you provide when seeking help from our customer service (such as chat logs, contact details such as your phone number and email address if necessary to resolve your request, and customer support tickets)

• Other information you provide us (such as information used to identify a lost account)

b – Information we automatically collect directly from you when you use our Services 

• Information about your use of the App, including your purchasing/collecting activity

• Information about your interactions with other users during the Beta Trial or during your use of the Services

• Information about your browsing activities, which we collect using cookies and similar tracking technologies included as part of the App and the Beta Services, if applicable (please note that cookies are only set in the web environment, we do not use them in the App itself—you can refer to our Cookies Policy to learn more about opting out of such technologies)

• IP address and device identifiers (such as your device ID)

• Information about your device (such as device name, operating system, and browser information (including browser type and the language you prefer))

• Account ID or identifier/handle

c – Information we obtain from our partners

• Information we may receive about you from Disney;

• Information we may receive about you from third party billing providers (when you make purchases during the Beta Trial while accessing the App or using the Services)

• Information we may receive about you from third-party analytics providers for analytics purposes (third-party analytics providers may be involved for tracking, analytics and/or technical purposes, within the Beta Trial, so we can provide you with better Services)

17. HOW WE USE INFORMATION COLLECTED

Under normal circumstances, we only collect personal information from you when:

• we obtain your consent to do so

• we have a legal obligation to collect and process your personal information 

• we need the personal information to fulfill a contract with you and provide you with the Services (including, among other things, providing customer support services, bug and service-error detection, and fraud prevention)

• the processing is in our legitimate interests (when we analyze your in-App activities, and protect and improve our products and services)

During the Beta Trial we will use the information you provide to Dapper Labs in order to perform the Services and to make the App better by improving it based on your feedback and a review of any submission you make through customer service or customer support channels.  Our primary use of your personal information during the Beta Trial will be as follows:

3.1 – To operate our business and to enhance your experience, including to:

• provide you with the App and Services during the Beta Trial

• provide in-App experiences that you may be interested in or have subscribed to based on your activities in-App and during the Beta Trial 

• track your use of the Services and in-App activities to help us learn more about user engagement, preferences and tendencies, so that we can personalize your experience, provide you with in-App offers and notifications that are tailored to you, and otherwise enhance your in-App experience

• enhance the Services, as Dapper Labs configures the App and its functionality during the Beta Trial 

• offer you the opportunity to take part in further testing or small group sessions to share your feedback and experiences

• protect against crime or fraud, or for other security reasons

• identify and/or fix bugs and Service errors

• use it for administration, analytics, research, and optimization

• compile statistics

• comply with all regulatory and legal requirements, and answer any requests from authorities or any law enforcement agency

• comply with security requirements (e.g. performing audits)

3.2 – To provide you with support, communicate with you, and respond to any requests or questions you have submitted through our customer support.

3.3 – To personalize our communication with you, including to:

• handle your subscription to, and opting-out of, our emails and newsletters

• contact you to promote our Services and any surveys or contests we may offer

• to send you, with your prior consent, promotions or marketing materials (we will provide you with the opportunity to opt out of receiving such materials in the future)

• offer in-App or email surveys

• personalize your in-App content and offers

3.4 – With your express consent, to securely share your account identifiers with selected partners, including Disney, for the sole purpose of improving the Services’ advertising campaigns on external sites. 

3.5 – For some of the purposes described above, Dapper Labs may use and perform analytics. Analytics information supports business analysis and operations, allows product development, improves products and Services, personalizes content, and makes recommendations. 


18. WHAT INFORMATION WE RETAIN AND FOR HOW LONG

Dapper Labs retains, uses and stores your information for as long as you are using our Services, and up to five (5) additional years thereafter, which may be necessary to fulfill all the purposes described in this Privacy Policy and comply with applicable laws.. 

We want to inform you that a longer retention period could be required to resolve disputes, or to answer regulatory or police requests. In such cases, the collected information will be used and stored until the request is closed. 


19. SHARING YOUR INFORMATION

5.1 – With Disney

In order to operate the Services, we may share your personal information with Disney or its subsidiaries, processors or third parties.

5.2 – With other third parties

With your consent, we may share your personal information with Disney.  We may also share your personal information with vendors or agents working on our platform in order to provide the Services to you.  For example, companies we have hired to provide cloud hosting services, off-site backups, and customer support may need access to personal data to provide those functions. In such cases, these companies are required to abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. If you have questions or concerns about any of our vendors, feel free to contact us at the email listed at the end of this Privacy Policy.

While using our Services, whenever you decide to and where this option is available, you may use social sharing features to third-party social network sites. This may allow the sharing and collection of personal and non-personal information both to and from such third-party social networks. You should visit the policies of such third parties for more information about their information collection practices.

5.3 – With authorities

Dapper Labs reserves the right to report to law enforcement agencies activities that we, in good faith, believe to be illegal. We will investigate or take action to counter illegal activity, suspected abuse or unauthorized use of the Services during the Beta Trial, or to protect the property or safety of others. We may also disclose your information if required by any law or court order worldwide, if the information relates to actual or threatened harmful conduct. In that case, we will consider applicable local laws, the nature of the order, as well as the legitimacy and proportionality of your information.


20. INFORMATION SECURITY

We have implemented security measures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the personal information collected during the Beta Trial through the Services. 

We take, and will require any applicable third parties to take, reasonable precautions to protect your personal information against loss, misuse, unauthorized disclosure, alteration, and destruction. However, there is no guarantee that electronic transmissions are fully secure and while we will make efforts to ensure the safeguard and confidentiality of your personal information, there is always a risk of interception or breach by an unauthorized party. We will not be held responsible for unauthorized access to your information to the extent such events are out of the control of Dapper Labs.  When we use third parties to assist us in processing your personal information or credit card information, we take reasonable steps to ensure that they comply with this Privacy Policy and otherwise protect your personal information (including any credit card information).

If there is a breach of security involving your personal information, including credit card information, in-App or during our Beta Trial while using our Services, we will inform you promptly in accordance with your local regulations relating to the notification of information security breaches, and take commercially reasonable steps to remediate the effects of such breach.

If you believe your personal information is being improperly used by us or any third party, please immediately notify us via email at [email protected].


21. MINOR CHILDREN’S INFORMATION

As set forth at the outset of this Privacy Policy, the Beta Trial and the Services are not intended for anyone under the age of eighteen (18).  


22. YOUR DATA RIGHTS

You can exercise your rights at any time and, subject to verification of your identity, ask Dapper Labs to:

-Provide you with access to your personal information - this will allow you to know what information has been collected by Dapper Labs pursuant to this Privacy Policy;

-Correct/modify your information - this will allow you to submit changes or to correct mistakes or change your name if necessary;

- Not sell your information - this will instruct Dapper Labs not to share your information with any third-party advertisers or engage in any activities that may be deemed a ‘sale’ of your information;

-Erase/Delete your information - this will instruct Dapper Labs to delete the personal information that it has collected about you; note that your information may be required to allow Dapper Labs to perform its Services and therefore you may not be able to access some or all of the Beta Trial or Services if you request that your information be erased or deleted;

- Port your information - this allows you to instruct Dapper Labs to deliver your information to you in a format that is currently used by Dapper Labs (please allow reasonable time for Dapper Labs to complete this task);

-Appoint an agent - in some circumstances you may be able to appoint/designate an agent to request any of the aforementioned actions; note that Dapper Labs may request authorization and verification of any proposed agents prior to completing any requests by such agents.

We ask that you keep the information that you provide to us updated. You can correct any information you have provided by contacting us at the email listed at the end of this Privacy Policy. You represent and warrant that all information you provide us is true and correct, and relates to you and not to any other person.

If you have previously consented to any direct marketing communication from us or subscribed to our newsletters, you can unsubscribe by clicking on a link available in each communication and newsletter we send you.

If you want to decline, to allow, or to set your preferences regarding the use of cookies or other tracking technologies, please refer to our Cookies Policy in the Dapper Services Privacy Policy. Please note that this Cookies Policy applies to the Dapper Labs offered website only (not applicable to the App). 

Please note that in-App functionality, Services and features offered during the Beta Trial can be affected by your actions. Some of your information and its processing is mandatory for Dapper Labs to provide the Services. Enforcement of your data rights may force Dapper Labs to cease providing the Services or unenroll you from the Beta Trial. 


23. CALIFORNIA USER INFORMATION 

The California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA) permit California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has collected, shared with, and/or sold to third parties for a business or commercial purpose during the immediately preceding calendar year. Please note that we do not sell your personal information to provide the Services or the App or during the Beta Trial as described in this Privacy Policy. Our partners and providers who work with us may have access to your personal information in order to provide you with the Services within the limits and throughout the duration of the Beta Trial, but they can’t reuse your personal information for any other purposes and will not sell your data. 

To exercise your rights, please access this form or refer to the “How to contact us” section of this Privacy Policy.

If you submit a request on behalf of another person, you need to be 18 years old or over, and we may require a proof of authorization and verification of identity directly from this person.

In some instances, we may inform you that we were not able to complete your request.  Examples of such situations include where we cannot verify that you have the authority to make a request on behalf of another person, or when an exception applies, such as when the disclosure of personal information would adversely affect the rights and freedoms of another consumer or when the personal information that we maintain about you is not subject to the CCPA/CPRA’s access or deletion rights.

The exercise of any of the rights mentioned above will not have any discriminatory consequences for you. 


24. ADDITIONAL INFORMATION FOR EU RESIDENT (DATA SUBJECT)

If you are a European Union resident Data Subject, we will transfer personal data from the European Economic Area and Switzerland to other countries such as the United States, some of which have not been determined by the European Commission to have an adequate level of data protection. When we engage in such transfers, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections travel with your data. To learn more about the European Commission’s decisions on the adequacy of the protection of personal data in the countries where Dapper Labs processes personal data, please visit: ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm.


25. THIRD PARTY SERVICES

The Services may link to external sites that are beyond our control. This Privacy Policy only covers the way we treat personal information and non-personal information we collect during the Beta Trial while offering the Services. By accessing any external sites, you agree to the privacy policies of those sites. Please understand that external sites may have different policies with respect to the collection, use and disclosure of your personal information. Dapper Labs has no control over, and are not responsible for, the privacy practices of such third parties.


26. CHANGES TO THIS POLICY

We reserve the right to change this Privacy Policy at any time. In the event that we make material changes to this Privacy Policy, they will be re-posted in the "Privacy" section of our website and may require that you agree to any new Privacy Policy terms in the App as a condition to your continued access to the Beta Trial.  If you would like further information about any recent changes made, please send your request to [email protected][DAPPER LABS INFO EMAIL] and include “Information about Changes” in the subject line. 


27. LEGAL

This Privacy Policy is governed by the laws of your country of residence. Any dispute arising from the use of the Services shall be submitted to the competent courts of your country of residence. 


28. CONTACT US

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please contact us:

1. by sending an email to [email protected]

2. by writing to the 565 Great Northern Way #600, Vancouver, BC V5T 0H8, Canada

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