Privacy Policy

Version 1.0

Last revised on: March 2023

1. Our User Privacy Policy

1.1. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

1.2. Your use of this Website and W3Smart Wallet's Services at all times are subject to our Terms and Conditions, which incorporate this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms and Conditions.

1.3. If you do not agree to the terms of this Privacy Policy, please stop using the Platform.

2. What information we collect

2.1. Information we collect from you

We collect information about you when you provide it to us and when you visit our Sites, sign up for and use our Services, request information or otherwise interact with us or our Services.

The information we collect from you may include (but is not limited to): Username and avatar, your IP address, email address, telephone number, feedback and log-in information.

2.2. Third-Party Websites

Our website may contain links to third-party websites or services that are not operated by us. We are not responsible for the privacy practices or content of these third-party websites or services. We encourage you to review the privacy policies of these third-party websites or services before providing any personal information.

2.3. Cookies and Other Tracking Technologies

We may use cookies and other tracking technologies to collect information about your use of our crypto wallet web app and improve your user experience. Cookies are small text files that are stored on your device when you access our website. They help us remember your preferences and provide a more personalized experience.

You can choose to disable cookies in your browser settings, but this may limit your ability to use certain features of our crypto wallet web app.

2.4. Children’s Privacy

We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register. If we become aware that we have collected personal information from a child under the relevant age without parental consent, we take steps to delete that information. Kindly write to us at blockchain.cs@smartosc.com for any further queries in this regard.

3. How We Use Personal Information

3.1. Lawful basis for processing your information

We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances:

  • Where you have asked us to do so, or consented to us doing so;
  • Where we need to do so in order to perform a contract we have entered into with you;
  • Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests;
  • Where we need to comply with a legal or regulatory obligation.

3.2. Our provision of Services

We use, collect and process your personal information in connection with our provision of Services:

  • We use your username for identification purposes within the game or marketplace.
  • We use your email address to authenticate you, communicate with you to provide technical and customer support and to send updates regarding your participation in any waitlists, Contests and Surveys.
  • We use your network address associated with your Wallet to allow you to make transactions on the platform, including buying and receiving digital assets such as gaming tokens.
  • We use your feedback and correspondence to respond to your requests, feedback, or inquiries, and to continuously improve our products and services.
  • We use your payment information to process payments for the digital assets you buy and sell on the platform.

3.3. Marketing

SmartOSC Corporation will occasionally send you marketing material/offers related to our services by email and tele-conversation that have been identified as being beneficial to our customers and in our interests. Such information will be relevant to you as a customer and is non-intrusive and you will always have the option to opt-out/unsubscribe at any time. Personally identifiable information collected/stored under this legitimate interests’ basis is protected by the same security measures listed in the ‘Safeguarding Measures’ section below.

4. Safeguarding Measures

SmartOSC Corporation takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorized access, alteration, disclosure or destruction and have several layers of security measures in place, including:

  • Encryption of data during transit (HTTPS)
  • Restricted access to only authorized personnel through authentication and password mechanisms
  • Implementation of anti-malware software
  • Network protection through firewalls

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the “Contact Us” section.

If we learn of a security systems breach, we will inform you of the occurrence of the breach in accordance with applicable law.

5. Legitimate Interests

As noted in the “How We Use Personal Information” section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.

We use the legitimate interests’ legal basis for processing direct marketing mailers / phone calls and have identified that our interests are to provide you with high quality, best in industry, performance support systems to ease and improve user onboarding, support and training.

6. Who do we share your information with?

For business improvement (evaluation) purposes, we may also share your data with professional advisers, consultants and contracted suppliers working on SmartOSC’s behalf who are subject to obligations of confidentiality.

As required by law, we may disclose information to government bodies and law enforcement agencies for their enforcement purposes. We will never share information other than for the purpose for which it was provided to us.

SmartOSC will not sell your personal information.

7. Your rights

As an individual whose personal data is processed by SmartOSC, its affiliates, partners and subcontractors, you have:

7.1. The right to be informed

Transparency is a key requirement of data protection law. You have the right to be informed about the collection and use of your personal data. This privacy notice is designed to provide you with the information needed to allow you to see how and why your personal data is used when visiting this website.

7.2. The right to access the data we hold on you

You also have the right to ask for the personal data that we have about you to increase your awareness of and allow you to verify the lawfulness of the processing. To protect your privacy we may ask you to verify your identity.

7.3. The right to have your data rectified if it is inaccurate

If you believe that personal data we hold on you is inaccurate or misleading then you have the right to request that it is rectified.

7.4. The right to erasure

In some circumstances, you can ask for your personal information to be deleted, for example:

  • Your personal information is no longer needed for the reason it was collected in the first place.
  • You have removed your consent for us to use your information (where there is no other legal reason us to use it).
  • There is no legal reason for the use of your information.

7.5. The right of data portability

Where you have provided your personal data directly to us that is processed by automated means and is done so purely on the basis of your consent, then you will have the right to obtain and reuse your personal data in an electronic format for your own purposes across different services.

7.6. The right to object to direct marketing

You have an unconditional right to object to direct marketing at any time. As noted within this privacy notice www.wallet.smartosc.com will not send you direct marketing without your consent and you can withdraw your consent at any time by sending an email to blockchain.cs@smartosc.com.

7.7. The right to object to processing of your personal data

Processing is the term under data protection law that describes all uses of your personal data. This will include the collection, sharing, storage, retention and destruction of your data.

You may object to processing of your personal data where we rely on legitimate interest for processing that personal data. We will comply with your request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.

7.8. Exercising your rights

When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.

It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).

If you would like to exercise your right of access in relation to information held on you by SmartOSC, email: blockchain.cs@smartosc.com.

8. Contact us

If you have any specific data protection queries or concerns, you can address it to SmartOSC’s Legal Officer at blockchain.cs@smartosc.com.

9. Changes to this privacy policy

We reserve the right to revise or amend this Privacy Policy at any time to reflect changes to our business or changes in the law. Future changes to this Website’s Privacy Policy will be published on this page and, where appropriate, sent to you by email notification. Please check back frequently to read any updates or changes to this Privacy Policy.