BOOKMAKER.XYZ - PRIVACY POLICY

Introduction

This Privacy Policy, as updated from time to time, explains how BOOKMAKER.XYZ DAO “XYZ DAO”, processes personal data in the context of its digital activities. For example, websites, registration systems, digital marketing, online professional services and business resources, as well as engagement and information services that are each managed by XYZ DAO alone or in cooperation with other members of XYZ DAO. We refer to these activities as the “Services” in this Privacy Policy.

It also details how XYZ DAO processes personal data that it receives from other organisations, or via cookies and similar technologies that are integrated into another organisation’s digital properties for the benefit of XYZ DAO.

Who are we?

When we refer to “we”, “our” or “us” in this Privacy Policy, we mean XYZ DAO.

Applicability and Acceptance of Policy

This Policy defines Personal Data and explains how Personal Data is collected, used, processed, and disclosed.

This Policy shall come into effect at the moment you first access and register on the Website. By accessing, browsing, or using the Website you irrevocably and unconditionally accept and adhere to the provisions of this Policy without any exemptions, limitations, and/or exclusions.

In the event you disagree with any provision of this Policy or would not like to provide your consent for the processing of your Personal Data, you shall cease using the Website.

Legal Grounds for Personal Data Processing

We process your Personal Data based on the following legal grounds:

• Contractual Necessity: When we have a contract with you, we will process your Personal Data to fulfill that contract, particularly to provide access to the XYZ DAO Website under our Terms of Use;


• Consent: Your consent, as provided in this Policy;


• Legal Obligations: When we are required to comply with legal obligations, such as responding to court orders or regulatory requests;


• Legitimate Interests: When processing, is necessary for our legitimate interests, provided that such interests do not override your fundamental rights and freedoms;


• Compliance with Applicable Legislation: As permitted by relevant laws.

Consent to Personal Data Processing

EU Persons’ Consent to Personal Data Processing

• If you are an EU resident, we will process your Personal Data based on your consent as required by the General Data Protection Regulation (GDPR). We will only proceed if we have received from you a freely given, specific, informed, and unambiguous indication of your wishes, indicating your agreement for us to process your Personal Data (“Consent”).


• You can provide your Consent by ticking a box when visiting the XYZ DAO Website or by submitting your Personal Data through designated forms. By ticking the box, you irrevocably and unconditionally consent to our processing of your Personal Data as specified in your Consent.


• Your Consent encompasses all processing activities related to the same purpose(s). If there are multiple purposes for processing, your Consent is considered granted for all of them. You have the right to withdraw your Consent at any time by emailing us. Withdrawal of Consent does not affect the lawfulness of any processing based on Consent prior to its withdrawal.


• Except as required or enabled by law, we will not use or disclose your Personal Data for any purpose for which you have refused Consent or later withdrawn your Consent. If you withdraw Consent, you agree that we may continue to use your previously provided Personal Data to the extent necessary to fulfill contractual obligations or as permitted by law.

Non-EU Persons’ Consent to Personal Data Processing

If you are not an EU resident, by providing us with your Personal Data via the XYZ DAO Website or otherwise, you irrevocably and unconditionally consent and agree to our processing of your Personal Data in accordance with this Policy. This includes:

• Collecting, storing, using, disclosing, sharing, and transferring (including cross border) your Personal Data provided to us, as well as any Personal Data collected from your use of the XYZ DAO Website (e.g., data collected automatically and/or from other sources); and/or


• Use cookies and web beacons (including tags) to collect your Personal Data and associate it with your computer and web browser.

Collection of Personal Data

General Provisions

The type of Personal Data we collect depends on your interaction with us. While you can often choose whether to provide your Personal Data, opting out may limit your access to the full functionality of the XYZ DAO Website. When using the XYZ DAO Website, you may provide us with the following types of Personal Data:

• Voluntarily Disclosed Personal Data: Information you provide on an individual basis;


• Automatically Collected Personal Data: Information collected automatically during your use of the XYZ DAO Website;


• Third-Party Collected Personal Data: Information we gather from other sources other than the XYZ DAO Website.

Please note that the XYZ DAO Website may contain links to other third-party applications that may also collect Personal Data about you through cookies or other technologies. This Policy does not apply to your interactions with those third-party applications. We recommend reviewing their privacy policies, as we have no control over their date practices.

Personal Data You provide to Us

In order to fulfill our obligations under the Terms of Use, we are entitled to ask you to provide us with your Personal Data, including (but not limited):

• Wallet information.

Personal Data hereof is collected only when voluntarily offered, and solely for the purposes that are clearly identified on the Website or in this Policy.

XYZ DAO may collect the Personal Data from you in a variety of ways and circumstances, including, but not limited to subscription to a newsletter, filling out a form, and providing us with feedback. XYZ DAO shall be entitled to combine Personal Data collected in the course of your interaction with different sections of the Website with any other relevant available information.

Personal Data We Collect Automatically

When you access and interact with the XYZ DAO Website, we may automatically collect certain types of Personal Data, including but not limited to:

• Device Information: Details about the computer or mobile device you use to access the XYZ DAO Website, such as hardware model, operating system and version, web browser type, and other device identifiers;


• Server Log Information: This includes, but is not limited to, your login details, date and time of visits, pages viewed, button clicks, input form changes (excluding entered values), errors encountered, IP address, time spent on the XYZ DAO Website, and the previous and next XYZ DAO Website visit;


• Tracking Technologies: We and our service providers use various technologies, including cookies and web beacons, to collect information during your interactions with the XYZ DAO Website. “Cookies” are small data files stored on your device that help us gather information about device identifiers, IP addresses, web browsers used, pages viewed, time spent on pages, and links clicked. “Web beacons” are graphic images placed on a webpage or in an email that monitor user behavior. They often work in conjunction with cookies. For more details on our cookie policy, please refer to our Cookies Notice.

Use of Personal Data

We use Personal Data for the following purposes:

• to make it easier for you to use the Service;


• to manage your user account and your authentication;


• providing you with goods, services, information or content that you have requested;


• transferring your data to selected third parties service providers.

Disclosure of Personal Data

XYZ DAO treats Personal Data as confidential and may not pass on or use such data without valid legal grounds.

We will only disclose your Personal Data in the following circumstances:

• with your Consent or at your instruction;


• with companies under common control or ownership with us or our offices internationally;


• for everyday business purposes, such as processing transactions, maintaining accounts, responding to court orders and legal investigations;


• in connection with a merger or sale of our company assets, or if we do a financing or are involved in an acquisition, or any other situation where Personal Data may be disclosed or transferred as one of our business assets;


• if we believe your actions are inconsistent with the Terms of use of the Website or applicable legislation, or to protect the rights, property, and safety of any assets of XYZ DAO or third parties;

XYZ DAO may without limitations share aggregated or de-identified information, which cannot reasonably be used to identify you.

Transmission of Personal Data

The transmission of Personal Data or any other information (including communications by e-mail) over the Internet or other publicly accessible networks is not one hundred percent secure. XYZ DAO is not liable for the security of any Personal Data or any other information you are transmitting over the Internet, or third-party content.

Information about you may be transferred to and processed in countries other than the country in which you are a resident. We have taken appropriate safeguards to require that your information will remain protected in accordance with this Privacy Policy.

Protection of Personal Data. Security Measures

We implement appropriate security, administrative, and technical measures to protect any Personal Data you provide. These measures safeguard your Personal Data against unauthorized access and unlawful processing or disclosure, as well as accidental loss, modification, or destruction, through state-of-the-art technical and organizational measures.

Personal Data is protected through advanced and organizational measures, which are continuously updated in response to technological advancements and organizational changes. Regular audits and controls are conducted to ensure compliance. However, no computer security system is entirely foolproof, and the Internet is not a secure method for transmitting information. Therefore, we do not assume responsibility for Personal Data submitted or received via the Internet, nor for any unauthorized access or use of that information. You agree not to hold us liable for any loss or damage resulting from the misappropriation, interception, modification, deletion, destruction, or use of information provided through the XYZ DAO Website.

Retention of Information

We may retain your Personal Data in accordance with applicable laws and as necessary to fulfill our obligations. This retention is based on the need to comply with legal requirements and resolve potential disputes.

We may retain your Personal Data until you withdraw your Consent or the Terms of Use are terminated. We aim not to store your Personal Data longer than necessary to provide access to the XYZ DAO Website or respond to inquiries.

XYZ DAO will continue to process your personal data in accordance with this Privacy Policy.

Rights

Under applicable data protection laws, you have the following rights:

• the right to be informed about the collection and use of your Personal Data;


• the right to access and receive a copy of the Personal Data held by us;


• the right to rectify any inaccurate or incomplete Personal Data;


• the right to request deletion of your Personal Data (the “right to be forgotten”);


• the right to restrict (i.e. prevent) the processing of your Personal Data;


• the right to data portability (to obtain a copy of your Personal Data to re-use);


• the right to object to specific uses of your Personal Data;


• rights concerning automated decision-making and profiling;


• the right to revoke the Consent for future processing of your Personal Data; and


• the right to complain to the relevant data protection authority.

Alterations to the Policy

We reserve the right to update this Policy at our discretion. We recommend checking this Policy frequently to stay informed about changes and how we protect Personal Data.

By using the XYZ DAO Website, you acknowledge and agree that it is your responsibility to periodically review this Policy and be aware of the changes. Your continued use of the XYZ DAO Website following any modifications to this Policy will be deemed as your acceptance of those changes.

The Policy may occasionally be translated into other languages. In the event of any discrepancies between the English version of this Policy and its translations, the English version shall prevail.

Data Protection Officer

We appointed a Data Protection Officer (DPO) who is an expert in data privacy and operates independently to ensure compliance with the GDPR. The DPO’s responsibilities include:

• monitoring internal compliance with data protection policies and procedures;


• informing and advising us on data protection obligations;


• providing guidance on Data Protection Impact Assessments;


• acting as a point of contact for data subjects and supervisory authorities.

Children’s Privacy

The minimum age to use XYZ DAO Website is 18 years. We do not knowingly collect Personal Data from individuals under this age. We strongly encourage parents to educate their children about online safety, including not sharing personal information without parental guidance.

Complaint and Contact

If you have any concerns or complaints regarding the use of your Personal Data, or if you have questions related to this Policy, please contact us by email which can be found in the contact information.

We are committed to addressing your concerns and will make reasonable efforts to resolve any issues. If we are unable to assist you satisfactorily, you have the right to lodge a complaint with the relevant data protection supervisory authority.