# BaksDAO Network Privacy Policy

BaksDAO Network, accessible from <https://baksdao.com/>, one of community\`s main priorities is the privacy of participants, which are visitors to <https://baksdao.com/> and its dApps (the “**Interface**”).

BaksDAO Network does it best to collect as minimum Personal Data as possible. Still, it’s quite a task not to collect it at all as there is a constant interaction within the BaksDAO Network community. That is why this Privacy Policy document contains types of data that is collected, used and recorded by BaksDAO Network.

BaksDAO Network Interface backed by BaksDAO Foundation located at: Stable Cooperation Associates CYF., Capital Tower, Greyfriars Road, Cardiff, Wales, CF10 3AG which is the controller for your Personal Data within the scope of this Privacy Policy. The BaksDAO Foundation decides “why” and “how” your Personal Data is processed in connection with the Interface. If you have additional questions or require more information about this Privacy Policy, do not hesitate to contact <info@baksdao.com>

This Privacy Policy applies only to the Interface activities and is valid for participants which are visitors to the Interface with regards to the Personal Data that they shared and/or collect within BaksDAO Network Interface. This Privacy Policy is not applicable to any Personal Data collected offline or via channels other than the Interface. Please read this Privacy Policy carefully to understand our policies and practices regarding your data and how it will be treated by the Interface.

IF YOU ARE UNWILLING TO AGREE TO THIS PRIVACY POLICY, OR YOU DO NOT HAVE THE RIGHT, POWER AND AUTHORITY TO ACT ON BEHALF OF AND BIND THE BUSINESS, ORGANIZATION, OR OTHER ENTITY YOU REPRESENT, DO NOT ACCESS OR OTHERWISE USE THE INTERFACE.

IF YOU ARE INTERESTED IN HOW WE USE COOKIES AND YOU CAN CHANGE YOUR COOKIES CHOICE, PLEASE SEE SECTION “COOKIES AND AUTOMATICALLY COLLECTED DATA”

## **1. Changes to this Agreement**

We reserve the exclusive right to make changes to this Privacy Policy from time to time, in our sole discretion. Your continued access to and use of the Interface constitutes your agreement to be bound by specific terms of this Privacy Policy posted at such time. You acknowledge and agree that you accept this Privacy Policy (and any amendments hereto) each time you access the Interface in any manner. Therefore, we encourage you to review this Privacy Policy regularly as you shall be bound by it.

If, within thirty (30) days of us posting changes or amendments to this Privacy Policy, you decide that you do not agree to the updated terms of the Privacy Policy, you may provide us with written notice of your withdrawal from this Privacy Policy to the email address at <info@baksdao.com>. Upon providing us with the written notice of the withdrawal of your acceptance to this Privacy Policy, you shall no longer be authorized to access or use the Interface, and you must immediately cease in doing so.

## **2. Eligibility**

*Age.* By accessing our using the Interface, you represent and warrant that you are at least eighteen (18) years of age. If you are under the age of eighteen (18), you may not, under any circumstances or for any reason, use the Interface.

## **3. Applicability**

This Privacy Policy applies to all of your interactions with us via the Interface, and your interactions with us in connection therewith.

## **4. Data processing in connection with the Interface**

**Types of Data Collected**

To the maximum extent possible, BaksDAO Network try to collect as minimum as possible Personal Data from you. Personal Data we collect:

* Email address, your name and any other your Personal Data you provide to us when communicating with us. Such Personal Data is used only for communication with you;
* The Personal Data that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Data;
* IP address, MAC address, log files, domain server, data related to usage, performance, website security, traffic patterns, location information, browser and device information only when you are using Interface;
* Wallet addresses, transaction and balance information data that is accessible when interacting with the Interface;
* Your name and address you provide to us when ordering our merch products.

Log Files. BaksDAO Network follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services' analytics. The data collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any data that is personally identifiable. The purpose of the data is for analyzing trends, administering the website, tracking users' movement on the website, and gathering demographic information.

Public Blockchain Addresses and Blockchain Data. We use public Blockchain addresses to identify a user’s journey through our product. We group and analyze these user journeys collectively in order to improve our product user experience. We do not use this data for any purpose at an individual user level. The legal basis for this processing is that it is our legitimate interests, such as monitoring and improving the Interface and the proper protection of the Interface against risks. Note that we are not responsible for your use of any of the blockchain and your data processed in these decentralized and permissionless networks.

BaksDAO Network may also engage third-parties advertising platforms that are only effective when their technical features (so-called “pixels”) are enabled through Interface. The mentioned third-parties advertising platforms may collect anonymized Personal Data of Interface\`s visitors only with the purpose to optimize their advertising possibilities through their platforms. In all those cases BaksDAO Network do not engage with the mentioned Personal Data of Interface\`s visitors. We may also receive data about you from other sources, including through third-party services and organizations. For example, if you access third-party services, through the Interface, we may collect data from these third-party services.

In no event we are going to ask you to share your private keys or wallet seed. Never trust anyone or any website that asks you to enter your private keys or wallet seed.

**How and Why we use your Personal Data**

We may use your Personal Data listed above only for:

* Our internal and operational purposes, when: ensuring security, identifying irregular website behavior, preventing fraudulent activity and improving security at all possible levels;
* Assessing and improving the performance of the services we provide through our Interface;
* Analyzing our website visitors’ actions to improve our Interface (section “Cookies and Automatically Collected Data”);

Analyzing the Interface behavior, including via: Google Analytics (please refer to [Google\`s Analytics\` Policy](http://www.google.com/policies/privacy/partners/) for more information);

* Delivering our merch products to users that ordered them;
* Send you marketing, advertising, informational emails;
* Find and prevent fraud.

To clear any doubts, we may use Personal Data described above or any other Personal Data only at your request and consent for particularly-tailored purposes you may require from us.

**Disclosure of Data**

We may disclose any Personal Data about you:

* to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders;
* in connection with a merger, division, restructuring, or other association change; or
* to our subsidiaries or affiliates (if any) only if necessary for operational purposes.

If we must disclose any of your Personal Data in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your Personal Data will maintain the privacy or security of your Personal Data.

**Data Retention Period**

BaksDAO Network maintain Personal Data exclusively within the time needed to follow prescribed herein legal purposes. When we no longer need Personal Data, we securely delete or destroy it. Aggregated data, which cannot identify a device/browser (or individual) and are used for purposes of reporting and analysis, are maintained for as long as commercially necessary. In any case, we are going to erase data on the user\`s name and address after 30 calendar days pass from the date of order of BaksDAO Network merch products.

Sometimes legal requirements oblige us to retain certain data, for specific purposes, for an extended period of time. Reasons we might retain some data for longer periods of time include:

* Security, fraud & abuse prevention;
* Financial record-keeping;
* Complying with legal or regulatory requirements;
* Ensuring the continuity of your interaction with the Interface.

**Your Inquiries**

You may contact us by email to the following email address: <info@baksdao.com>; We use the data that you provide in an email to us, which you may give voluntarily, only in order to answer your contact question or to reply to your email in the best possible manner.

## **5. Cookies and Automatically Collected Data**

As you navigate through and interact with our Interface, we may ask your consent to use cookies, which are small files placed on the hard drive of your computer or mobile device, and web beacons, which are small electronic files located on pages of the Interface, to collect certain information about your equipment, browsing actions, and patterns.

The data automatically collected from cookies and web beacons may include information from your web browser (such as browser type and browser language) and details of your visits to the Interface, including traffic data, location data and logs, page views, length of visit and website navigation paths as well as information about your device and internet connection, including your IP address and how you interact with the Interface. We collect this data in order to help us improve the Interface and interaction with it.

The information we collect automatically may also include statistical and performance information arising from your use of the Interface. This type of data will only be used by us in an aggregated and anonymized manner.

You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers' respective websites:

* For Google Chrome browser please refer to these [instructions](https://support.google.com/accounts/answer/32050?co=GENIE.Platform%3DDesktop\&hl=en);
* For Firefox browser please look up [here](https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox);
* For Safari browser please [visit](https://support.apple.com/ru-ru/guide/safari/sfri11471/mac);
* For Internet Explorer browser please [refer to](https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d).

## **6. Your rights under GDPR**

Under certain circumstances, you may have a number of privacy rights concerning the use, storage, and processing of your Personal Data (e.g., the right to delete your data). Here is a list of privacy rights:

* **right to be informed** - we are publishing this Privacy Policy to keep you informed as to what we do with your Personal Data. You can ask us for data regarding any data of yours that we keep at any time. This information concerns, among other things, the data categories we process, for what purposes we process them, the origin of the data if we did not acquire them directly from you and, if applicable, the recipients to whom we have sent your data.
* **right of access** – You may ask us whether we process your Personal Data and you have the right to request a copy of the data we hold about you.
* **right of rectification** – You have the right to correct inaccurate or incomplete data about you. ● **right to be forgotten** – You can ask for the data that we hold about you to be erased from our system and we will comply with this request unless we will have a legitimate reason not to do so.
* **right to restriction of processing** – where certain conditions apply, you can ask us to ‘block’ the processing of your data.
* **right to data portability** – You have the right to have the data we hold about you transferred to another organization and to receive Personal Data in a structured, commonly used format. Please apply at <info@baksdao.com>to find out whether we currently support the provision of the portable file containing Personal Data we process about you.
* **right to object** - You can object to the processing of your data at any time for reasons that arise from your special situation provided the data processing is based on your consent or our legitimate interest or that of a third party. In this case, we will no longer process your data. The latter does not apply if we are able to prove there are compelling, defensible reasons for the processing that outweigh your interests or we require your data to assert, exercise or defend against legal claims.
* **right to withdraw consent** - withdraw the consent you gave us with regard to the processing of your Personal Data for certain purposes.
* **right to complain** - we take your rights very seriously. However, if you are of the opinion that we have not dealt with your complaints adequately, you have the right to submit a complaint to the data privacy protection authorities responsible.

Please email at <info@baksdao.com> with any questions about exercising any of the above rights. If You wish to learn more about the GDPR and Your rights, the [Information Commissioner’s Office](https://ico.org.uk/your-data-matters/) website is a reliable source.

## **7. Privacy of children**

Our Interface is not directed to collect any data from people under the age of 18. We do not knowingly allow anyone under 18 to submit any data to our Interface. If you believe your child may have provided us with their data, you can contact us using the information in this Policy and we will delete the data from our Interface.

## **8. Transfer of Personal Data**

Transfers to third countries, shall be made subject to appropriate safeguards, namely standard contractual clauses adopted by a supervisory authority and approved by the Commission. Copy of the foregoing appropriate safeguards may be obtained by you upon a prior written request sent. We may instruct you on further steps to be taken with a purpose of obtaining such a copy, including your obligation to assume confidentiality commitments in connection with being disclosed the BaksDAO Foundation proprietary and personal information of third parties as well as terms of their relationships with the BaksDAO Network.

Keep in mind that the use of Interface based on public blockchains intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of Personal Data, in particular when blockchain data is combined with other data. Because blockchains are decentralized or third-party networks which are not controlled or operated by us, we are not able to erase, modify, or alter Personal Data from such networks.

## **9. Data Integrity & Security of Processing**

We take data security very seriously. We work hard to protect the Personal Data you provide us from loss, misuse, or unauthorized access. We utilize a variety of safeguards such as encryption, digital and physical access controls, non-disclosure agreements, and other technical and organizational measures to protect the Personal Data submitted to us, both during transmission and once it is at rest.

Please note that no electronic transmission, storage, or processing of Personal Data can be entirely secure. We cannot guarantee that the security measures we have in place to safeguard Personal Data will never be defeated or fail, or that those measures will always be sufficient or effective. Therefore, although we are committed to protecting your privacy, we do not promise, and you should not expect that your Personal Data will always remain private or secure.

## **10. Supervisory authority oversight**

If you are a data subject whose data we process, you may also have the right to lodge a complaint with a data protection regulator in one or more of the European Union member states. [Here](https://edpb.europa.eu/about-edpb/board/members_en) you can find a list of data protection authorities in Europe.

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