Privacy Policy

This Privacy Policy (Privacy Policy) tells you how FV Platform (BVI) Ltd and our related companies (FV Platform, we, us, our) collect and use your personal information (meaning any information that identifies you) when you use our Services, which includes our:

• websites, including www.therootnetwork, staking.therootnetwork.com and any other websites related to our Services and/or subdomains (Website);

Our commitment to protect your information

We are committed to dealing with your personal information safely and securely and will comply with our obligations under the British Virgin Islands' Data Protection Act, 2021 (DPA) and the New Zealand Privacy Act 2020 (Privacy Act). If you live in the European Union (EU) or the United Kingdom (UK) we will also comply with our obligations under the European Union General Data Protection Regulation 2016/679 (GDPR) and the UK General Data Protection Act 2018 (UK GDPR).

If you use any of our Services, you also need to read our terms and conditions, which apply together with this Privacy Policy. If you have any questions about this Privacy Policy or want to access or change the personal information we hold about you, get in touch with us at privacy@therootnetwork.com.

Your acceptance of this Privacy Policy

Make sure you read this Privacy Policy carefully. By using any of our Services or otherwise providing us with your personal information, you are accepting this Privacy Policy, and agree that we can collect, use, disclose and hold your personal information in the ways described in this Privacy Policy.

Changes to this Privacy Policy

We may need to change this Privacy Policy from time to time. If we do, we’ll post the new version on our Websites and/or Apps and, if we make substantial changes, we’ll also contact you (via email or other means) to let you know about the changes. By using any of our Services after the revised policy has come into effect, you will be taken to have accepted the changes. If you’re not happy with any of the changes, you should contact us and immediately stop using our Services.

Why do we collect personal information?

We need to collect, use, and disclose personal information to operate our business and provide you with our Services, including to:

• operate and make available the Website and associated Digital Collectibles and our Apps;
• provide you with marketing and promotional material, where you have agreed to receiving this;
• run our business and meet our legal obligations; and
• develop and improve our Services.

The legal justification for why we collect and process your personal information is that:

• you have given us your consent to collect and use your personal information. You can withdraw your consent at any time by contacting us at privacy@therootnetwork.com or unsubscribing from any of our communications. If you choose to withdraw your consent, we may not be able to continue providing you with all our Services. You can’t withdraw consent for any processing of your information which has already occurred;
• the processing of your personal information is required to enable us to perform a contract that we have entered into with you, such as where we provide you with Services under our terms and conditions; or
• we need to process your personal information to carry out our legitimate business interests, such as servicing our customers and managing staff, to conduct market research and analysis to improve the Services, and to perform marketing and development activities.

What personal information do we collect?

We will only collect personal information where it is necessary to provide you with our Services and/or operate our business.  The type of personal information we need to collect depends on the reason it is collected for and the Services you are using. This may include:

• your name and contact details, including email address, contact phone number, address, and age, the country you live in;
• any username or alias you create;
• your blockchain address, which may link with your personal information;
• your Ethereum/ROOT (and/or other public blockchain) address and wallet, and public blockchain data;
• your preferences and/or opinions and other information provided through customer surveys;
• Website and App user data collected when you visit and use our Websites and Apps (this may include your IP address, cookies, device information, unique device identifiers, operating system and version and mobile network information;
• details of the products and Services we have provided to you and/or that you have asked about;
• where you participate in ROOT, your trading data;
• where you connect or use a digital wallet for use with a third-party’s products and services, the assets held in that wallet;
• how you’re connected to others whose personal information we hold;
• information about how you’re using the Services through cookies, device and network information, browsing information and history, geo-location data, your IP address, computer’s operating system and your internet service provider;
• any other personal information you provide us by submitting forms or by using the Services, associated social media platforms and/or accounts that you allow us to collect from;
• publicly available information from social media accounts, posts and profiles, where relevant to your interactions with us, or to our business or relationship with you;
• information that we need to fulfil any regulatory compliance obligations we may have, including but not limited to those found in the Anti-Money Laundering and Countering Financing of Terrorism Act 2009; and
• any other information that we may need from time to time for the purposes set out in this Privacy Policy.

All personal information is collected and held by FV Platform (BVI) Ltd, Jayla Place, 2nd Floor, Road Town, Tortola, British Virgin Islands VG1110.

How do we collect your personal information?

We usually collect personal information directly from you (or from third parties where you have authorised us to) such as when:

• you use one of our digital platforms like our Websites and/or Apps;
• you access any of our social media platforms, rooms or servers that we administer;
• you subscribe to one of our newsletters or publications;
• you buy some of our products or services, either from us or a third party;
• you come to or participate in one of our events, marketing campaigns, competitions, promotions or similar events;
• you give us your details when providing feedback or get in touch with us through social media, email, telephone or any other way; or
• we are required to do so by law.

If you give us personal information about someone else (like for a joint application), you must have their permission, and you must tell them about the terms of this Privacy Policy.

When using our Website and/or Apps, your computer or mobile device may send us information (such as your IP address, referral URL, geo-location and data about the webpages you visit) which we may collect, but generally this data can’t be used to identify you.

You may decide that you don’t want to provide us with certain personal information. If this is the case, you might not be able to fully access the Services, participate in third-party’s events and competitions, or it might impact the quality of the Services. If you are unsure what information is important to have full access to the Services, please contact us.

How do we use and disclose your personal information?

We only use and share your personal information for the following purposes:

• to provide you with access to and use of our Services, including helping you view, explore, create or modify digital collectables, join in The Rootnetwork and/or our Apps, using our tools and, at your own discretion, connecting with us or others to buy, sell or transfer digital collectables on public blockchain networks;
• any use in accordance with permissions granted through your account with any third-party (if you have one);
• to get in touch with you, such as to ask for feedback or give customer support;
• to provide a more personalised experience on our Services;
• to develop and run our events and competitions;
• to contact you about assets or other airdrops that you may qualify for in the future from other parts of our eco system from our affiliates and related companies;
• for research and to help improve our Services;
• for any regulatory compliance matters or administrative functions related to our business, to comply with any legal obligations, or for other purposes permitted under the DPA or the Privacy Act;
• for market analysis and data analytics related to the Services;
• where you have asked us to, to send you electronic marketing messages; and
• for any other purpose, where you’ve expressly consented to such use or disclosure.

You should take care when picking a username as these are publicly accessible through the Services. If you choose a username that includes any information that could be used to identify you (such as your name), you agree to the publication of that username through the Services your username relates to.

Where you have agreed to receive marketing material from us, you can opt out at any time by notifying us at privacy@therootnetwork.com or by clicking the unsubscribe button in any of our marketing communications.

We will not knowingly collect information about children under the age of 18. If you are a parent or guardian and think your child or minor has provided us with personal information without your consent, please get in touch with us at privacy@therootnetwork.com  and we will delete the information from our system.

Who do we share your information with?

In carrying out the purposes set out above, we may share your personal information with:

• any subsidiaries, joint ventures or other companies under our control (Affiliates), where their use will comply with this Privacy Policy;
• any third party brands or businesses that we have partnered with to provide any of our Services;
• any service providers or professional advisors that we use to provide a service to us in relation to the Services or our business generally, such as IT, marketing, legal or customer support;
• anyone else you have agreed that we can share the information with;
• potential purchasers, investors and funders if we sell or negotiate to sell all or part of our business or assets or restructure our business;
• Government departments, regulators and any other third party where the disclosure is permitted under the Privacy Act and/or any other applicable law.

We do not sell or purchase any personal information.

Transfer of information overseas

Generally, we hold your information in BVI or New Zealand. However, sometimes personal information may be transferred and/or stored outside of BVI or New Zealand by our third party service providers or staff working remotely. If we share personal information with third parties outside of New Zealand who will use the information for their own purposes, we will ensure that the information is protected by comparable safeguards to those in the Privacy Act.

If you live in the EU or UK and your personal information is shared outside of the European Economic Area, the United Kingdom or New Zealand, it will be shared:

• to an Affiliate that is subject to binding corporate rules;
• to a country or organisation that has 'adequacy' for the purpose of Article 45 of the GDPR or under the UK GDPR; or
• transferred subject to the European Commission's model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses) and relevant UK standards.

What about my payment card details?

We don’t collect or hold any payment card details. If we offer an online payment service on our websites and/or Apps, we use a trusted payment service to process any payment card transactions. Your payment card details will be collected and held securely by that third party payment service processor (in accordance with their own terms).

Your rights to access and correct your personal information

You are responsible for making sure the information you give to us is accurate, correct and up to date.

You can request access, deletion, or correction of your personal information at any time (subject to certain exceptions under applicable privacy law). To do so, get in touch with our team at privacy@therootnetwork.com.

We will only refuse access to, deletion or correction of your personal information where we have a good reason to do so under applicable privacy law. While you can request that we delete your information at any time, this may mean you can’t access some or all of the Services. To protect your privacy and security, we may also need to verify your identity before we can give you access to or correct your personal information.

We can’t edit or delete any information that is stored on a blockchain, as we don’t have custody or control over any blockchains. The information stored on a blockchain may include purchases, sales, and transfers related to your blockchain address and digital collectibles) held at that address.

We only keep your information for as long as we need it to carry out the purposes set out in this Privacy Policy or if we are otherwise required by law to retain it for a certain length of time.

Additional rights for EU/UK residents

If you live in the EU or UK when we collect your personal information, you may have additional rights in relation to your personal information. These include:

• the right to request the deletion of your information;
• the right to ask us to restrict the processing for your information in certain circumstances;
• the right to object to the use of your information for specific processing activities;
• the right to withdraw consent to processing; and
• the right to ask that we transfer the information you gave us to another organisation or give it back to you (known as data portability) so your information can be retained and used for other purposes.

If you want to exercise any of these rights, or would like more information about these rights, contact us at privacy@therootnetwork.com.

Links to other websites

Our websites sometimes have links or references to third party websites or content that are outside of our control. You should always exercise caution when accessing any third-party websites or content, as they aren’t covered by this Privacy Policy. Make sure you read and agree to their privacy policy before sharing any personal information with a third-party website, because we aren’t responsible or liable for the content or privacy practices of any third-party websites.

How to contact us

If you have any questions about this Privacy Policy or how we handle your personal information please get in touch with our data protection officer at FV Platform (BVI) Ltd, Jayla Place, 2nd Floor, Road Town, Tortola, British Virgin Islands VG1110 or by emailing us at privacy@therootnetwork.com.

If you aren’t happy with our response or feel we haven’t satisfactorily resolved your concern, you can make a complaint to (as applicable):

• If you are based in the BVI, the Government of The Virgin Islands at: customerservice@gov.vg;
• if you are based in New Zealand, the New Zealand Office of the Privacy Commissioner at: PO Box 10-094, The Terrace, Wellington 6143, phone 0800 803 909, https://privacy.org.nz/; or
• if you are based in the EU/UK, your local supervisory authority.

Last Updated: 18 March 2024

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