Privacy Policy

Tribes Studio Gaming Limited (“Tribes Studio”) is a digital adventure and gaming company. They are dedicated Web3 technologists working with the community to create the gaming of the future.They are the beginning of the story, and with their assistance, it will continue on into the future. They want to tell stories across all platforms and media.

Tribes Studio, a company established in Dublin, Ireland, provides the websites https://tribes.studio/ and https://www.tribesters.xyz, and the subdomains of each of the foregoing (collectively, the "Website") and the Tribesters® IntellectualProperty (collectively the "IP" and, with the Websites, the "Services") of which is the sole owner.

This Policy sets forth how we collect, use, protect, store, and otherwise process your Personal Information (defined below).

This Policy does NOT apply to information we collect offline or you provide to or is collected by any third party (except as otherwise provided below). This Privacy Policy is intended for individuals using our services. As a European company we abide by the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation). For non-EU citizens and residents please feel free to read the legislation above, as well as consult your local data protection regulations. By using any of our websites that link to this Privacy Policy (collectively, “Sites”) or otherwise providing Personal Information to us, you agree to this PrivacyPolicy.

For our practices regarding children, please see below as well as our Terms of Use.
1. What types of PersonalInformation does the Company collect?

Generally


We may collect different types of information from you depending on how you use our Services, including Personal Information."Personal Information" means information that relates to an identified or identifiable natural person. The categories of PersonalInformation we may collect are listed below. Certain types of Personal Information may fall under more than one category.

Information you provide directly to Tribes Studio, including:

-  when you create a Member Account, your email address, user name and password;
-  if you purchase merchandise, your name, email address and postal address;
-  your purchase history and other information relating to transactions made through the Website; and
-  information contained in your correspondence with Tribes Studio, for example, when you send us an email;

Information collected during your use of the Website, Materials orServices, including:

-  character names and information from your interactions while using our Services;
-  any Posts or Images;
-  your credited name (if any);
-  'crash reports' in the event that a software crash occurs, which may include details of your Member Account, a portion of the memory state of the Services when the crash occurred and the Services settings you were using, but not other information from your computer or its memory; and
-  the IP address of your machine when connected to the internet, the operating system and the browser your computer uses and any search engine you are using, the date and time you are visiting, the URLs of the Website pages you visit and any telemetry details (such as speed of your connection and how well Tribesters game client is running) associated with your access and use of Tribesters and of our Website and Services

Information collected from third parties when you link your MemberAccount with an approved third-party account (currently Tally Solutions, Substack, Gamma Tech, Sky Mavis), where you have authorised this or where the information is publicly available; and

Information collected through our use of cookies or similar technologies. Please refer to Tribes Studios' Cookies Notice for further information, including information on how you can disable these technologies.

Tribes Studio does not process credit card transactions and does not have access to your credit card information.

- Identifiers: We may collect your first, middle and last name, email address, username, postal address, IP address, or display name if it is required for your registration. We do not share payment information or other related identifiers with our associates processing such transactions.
- Age: We may collect your date of birth or age.
- Commercial information: We may collect your sale history while using our Services where applicable.
- Internet or other similar network activity: We may collect your interaction with our Services history, running/loaded dynamic link library ("DLLs") on your computer or data gathered from a "small memory dump."
- Other categories: We may collect information from the content that you create and share publicly using our Services and Website,     and information you choose to reveal through our Services via chat or other public functions.

We may also collect information that does not generally identify you but may become associated with your account. We may use information that does not identify you for any permissible business purpose under applicable law.

We use Google Analytics to analyze the data collected via our Services. Through third party services like Facebook, Twitter, Google Analytics or Google Tag Manager, we collect page usage (e.g. buttons clicked, screens viewed, time spent, etc.),general demographics (language, country, city, age range, gender, interest categories), device usage and operating system. We use such data to deliver and personalize our communications with you and provide the most relevant advertising to you.

We invite you to visit the following links of third party service providers used by our websites:

* [Google Play Services] (https://www.google.com/policies/privacy/)
* [Facebook] (https://www.facebook.com/about/privacy/update/printable)
* [Twitter] (https://twitter.com/en/privacy)
* [GameAnalytics] (https://gameanalytics.com/privacy)
* [GoogleAnalytics] (https://policies.google.com/privacy?hl=en-US)
* [Tik Tok] (https://www.tiktok.com/legal/page/eea/privacy-policy/en)
* [Youtube] (https://support.google.com/youtube/answer/10364219?hl=en)
* [Instagram] (https://help.instagram.com/155833707900388)
2. Data protection provisions about the application and use of Google Analytics (with anonymization function):
On our Websites, the controller has integrated the component of Google Analytics. GoogleAnalytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Ireland Limited, GordonHouse, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of the GoogleAnalytics component is to analyze the traffic on our Websites. Google uses the collected data and information, inter alia, to evaluate the use of ourWebsites and to provide online reports, which show the activities on our Websites, and to provide other services concerning the use of our Internet site for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained in our CookiePolicy. With the setting of the cookie, Google is enabled to analyze the use of our Websites. With each call-up to one of the individual pages of our Internet sites, which is operated by the controller and in to which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Websites, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America or where applicable according to the applicable Google Analytics terms which we encourage you to go over. These personal data are stored by Google in the United States of America or where currently applicable. Google may pass these personal data collected through the technical procedure to third parties.
Cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to a collection of data that are generated byGoogle Analytics, which is related to the use of this Websites, as well as the processing of this data by Google and the chance to preclude any such.For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to GoogleAnalytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must re install the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.
3. Use of Information:
Tribes Studio uses the information provided by you:

-  to provide the Website, Materials and Services to you;
-  to verify your identity and verify that your Member Account (where applicable) is not being used by others;
-  to fulfil any orders for merchandise ordered through the Website;
-  to market products and services to you, including contacting you via email that you may choose (or opt in) to receive. You can stop receiving Tribes Studio’ promotional emails by following the unsubscribe instructions included in those emails; and
-  to respond to communications from you.

Tribes Studio uses the information generated by your access or use of the Website, Materials or Services:

-  to monitor the performance of the Website, Materials and Services and ensure that the Website, Materials and Services perform in the best manner possible;
-  for security and system integrity purposes; and
-  to conduct research and statistical analysis (on an anonymised basis) (see more in the Statistics section of this privacy notice below);

TribesStudio may also use your personal information:

-  to protect and/or enforce Tribes Studio’ legal rights and interests, including defending any claim;
-  for any other purpose authorised by you, the Act or other applicable law;
-  to respond to lawful requests by public authorities, including to meet law enforcement requirements; and

where this is necessary for Tribes Studio’ legitimate interests (except where such interests would be overridden by your fundamental rights and freedoms which require the protection of personal data).
4. Disclosing Information:
Tribes Studio does not sell your personal data to third parties or provide such data to direct marketing companies or other such organisations without your prior consent.

Tribes Studio may disclose your personal information to:

-  any business that supports Tribes Studio' products or services, including any person that hosts or maintains any underlying IT system or data centre that Tribes Studio use to provide the Website, Materials or Services, or to process payments, or to fulfil merchandise orders;
-  its professional advisers e.g. accountants, lawyers, auditors; and
-  any other person authorised by you;

Your personal information may be viewable by other Service users or the public in general if you use certain features the Services (e.g. using real life personal data as identifiers for you) or make Posts in forums.

If you choose to log in with or link to your Member Account on a third party website or service, the third party site or service will have access to certain information from your Member Account. These third party sites and services have their own privacy policies, and you may be giving them permission to use your data in ways we would not. We suggest you review the privacy policy for any third party site or service before using or allowing access to your MemberAccount.

Tribes Studio may disclose research and statistical analysis (on an anonymised basis)derived from your personal information to third parties Tribes Studio also may disclose information it holds about you without your prior permission if Tribes Studio reasonably believes that such disclosure is necessary:
- to meet legal requirements;
- to comply with legal process or help to maintain the law;
- to protect Tribes Studio' rights or property or that of Tribes Studio' related companies; or
- to enforce these Terms of Use or any other agreement that Tribes Studio may have with you.

for Tribes Studio's other legitimate interests (except where such interests would be overridden by your fundamental rights and freedoms which require the protection of personal data).
5. Statistics:
Tribes Studio may use and publish non-personal aggregate statistics and group data about those people who access or make use of any of the Website, Materials orServices and their usage of any of the Website, Materials or Services.
6. Protecting your personal information:
Unfortunately, no data transmission over the Internet can be guaranteed as totally secure.Tribes Studio will take reasonable steps to keep your personal information safe from loss, unauthorised activity or other misuse. Tribes Studio implements appropriate technical and organisational measures to ensure a level of security appropriate to the risks inherent in processing personal information. You can play an important role in keeping your personal data secure by maintaining the confidentiality of any password and accounts used in relation to the Website, Materials and Services, including using a unique password that you do not use on any third-party websites or related services. Please do not disclose yourMember Account password to third parties. Please notify Tribes Studios immediately if there is any unauthorised use of your account or any other breach of security.
7. Transfers of personal information:
A business that supports our services and products may be located outside the EuropeanEconomic Area ("EEA"), the United Kingdom or United States. This may mean your personal information is held and processed outside the EEA, the United Kingdom or US. Please see the EU/UK GDPR Terms below for further information about personal data transfers from the EEA and the United Kingdom.
8. Accessing and correcting your personal information:
You are entitled to access any information which Tribes Studio may hold about you and Tribes Studio is obliged to provide this information to you as long as it has such information and such information can be readily retrieved.You are also entitled to request Tribes Studio correct any inaccuracies in any information which Tribes Studio holds about you.
9. Children's privacy:
Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
10. Contact us:
If you have any questions about this privacy notice, Tribes Studios' privacy practices, or if you would like to request access to, or correction of,your personal information, you can contact Tribes Studio here: hello@tribes.studio. If you would like your personal data deleted, please email hello@tribes.studio and use the subject: “Delete:User”
PRIVACY NOTICE: EU/UK GDPR TERMS
EU/UK additional terms: If you are based in the European Union ("EU") or the United Kingdom ("UK") and use any of the Website, Materials and Services, these additional terms("EU/UK GDPR Terms") supplement and form part of Tribes Studios' Privacy Notice. The General Data Protection Regulation("GDPR") and the equivalent laws of the UK (together with the GDPR,"EU/UK Data Protection Laws") regulate the collection, processing and transfer of EU and UK individuals' personal data (as defined in the applicableEU/UK Data Protection Laws). The personal information described in our privacy notice is personal data under applicable EU/UK Data Protection Laws. TribesStudio is committed to complying with applicable EU/UK Data Protection Laws when dealing with personal data of our website visitors and service users based in the EU or UK. For the purposes of applicable EU/UK Data Protection Laws,Tribes Studio is the data controller (as defined in applicable EU/UK Data protection Laws) when processing personal data collected by it when you use any of the Website, Materials and Services. Tribes Studio is happy to assist with any questions regarding its collection and use of data. Any requests for further information should be sent to hello@tribes.studio.

Processing personal data: The personal data Tribes Studio may process, consists of the personal information described in its Privacy Policy. This personal data may be processed for the purposes outlined. The legal basis for Tribes Studio' processing of personal data depends on the type of personal data and the specific context in which it collects it. However, Tribes Studio normally processes personal data only (a) where it has your consent to do so, (b) where it needs to process personal data to perform a contract with you (e.g. to provide the Website, Materials or Services to you), or (c) where the processing is necessary for the purposes of Tribes Studio' legitimate interests (except where such interests would be overridden by your fundamental rights and freedoms which require the protection of personal data).

Despite the above, Tribes Studio may process any of your personal data where such processing is necessary for compliance with applicable laws.

You do not have to provide Tribes Studio with some information that is automatically collected when you use any of theWebsite, Materials and Services, e.g. cookies. However, you must provide us with (a) your email address and username or (b) a username and approved third party (currently TallySolutions, Substack, Gamma Tech, Sky Mavis) account ID when using the Materials and Services or you want to subscribe to our Services.

Your rights: Your rights in relation toyour personal data under the applicable EU/UK Data Protection Laws include (subject to any legal exceptions):

Right of access - if you ask TribesStudio, it will confirm whether it is processing your personal data and provide you with a copy of that personal data.

Right to rectification - if the personal data Tribes Studio holds about you is inaccurate or incomplete, you have the right to have it rectified or completed. Tribes Studio will take every reasonable step to ensure personal data which is inaccurate is rectified. If Tribes Studio has shared your personal data with any third parties, it will tell them about the rectification where possible.

Right to erasure – Tribes Studio will delete your personal data when it is no longer needed for the purposes for which you provided it. You may request that Tribes Studio delete your personal data and it will do so if deletion does not contravene any applicable laws. If Tribes Studio has shared your personal data with any third parties, it will take reasonable steps to inform those third parties to delete such personal data.

Right to withdraw consent - if the basis of Tribes Studio’ processing of your personal data is consent, you can with draw that consent at any time.

Right to restrict processing - you may request that Tribes Studio restrict or block the processing of your personal data in certain circumstances. If Tribes Studio has shared your personal data with third parties, it will tell them about this request where possible.

Right to object to processing - you may request that Tribes Studio stops processing your personal data at any time and it will do so to the extent required by the GDPR and the equivalent laws of theUK.

Right to data portability - you may obtain your personal data from Tribes Studio that you have consented to give it or that is necessary to perform a contract with you. Tribes Studio will provide this personal data in a commonly used, machine-readable and inter operable format to enable data portability to another data controller. Where technically feasible, and at your request, it will transmit your personal data directly to another data controller.

The right to complain to a supervisory authority - you can report any concerns you have about Tribes Studio’ privacy practices to the relevant data protection supervisory authority e.g. in theUnited Kingdom, this is the Information Commissioner’s Office.

Where personal data is processed for the purposes of direct marketing, you have the right to object to such processing, including profiling related to direct marketing. If you would like to exercise any of your above rights, please contact us at hello@tribes.studio. If you are not satisfied by the way your query is dealt with by Tribes Studio, you may refer your query to your local data protection supervisory authority.

Children: Tribes Studio does not intend to collect personal data from children in the EU or any other country aged under 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected PersonalData from children without verification of parental consent, we take steps to remove that information from our servers.

International transfer of data: The personal data Tribes Studio collects in relation to the Website, Materials and/or Services may be transferred to, and stored in, a country operating outside the European Economic Area ("EEA"). Under applicable EU/UKData Protection Laws, the transfer of personal data to a country outside the EEA or the UK may take place where the European Commission or the UK government has decided that the country ensures an adequate level of protection. In the absence of an adequacy decision, Tribes Studio may transfer personal data provided appropriate safeguards are in place.

Some of the personal data Tribes Studio collects is processed by us and/or third-party data processors in other countries. For personal data processed in countries that have not been determined as ensuring an adequate level of protection for personal data under the applicable EU/UK Data Protection Laws, Tribes Studio has entered intoStandard Contractual Clauses as published by the European Commission with its third-party processors. The Standard Contractual Clauses provide specific guarantees around transfers of personal data and Tribes Studio rely on theStandard Contractual Clauses in transferring personal data to these third-party processors.

Data retention policy: Personal data that Tribes Studio collects and processes will not be kept longer than necessary for the purposes for which it is collected, or for the duration required for compliance with applicable law, whichever is longer.

Contacting us: You can contact Tribes Studio as set out in our privacy notice. The name and contact details of Tribes Studio' European and UK representative for the purposes of Article 27 of theGDPR and equivalent laws of the UK are as follows:

DPO: Glenn McGuire
Contact email: hello@tribes.studio
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