Privacy policies
Butclick Technology OÜ (Private Limited Company), registered in the Commercial Register of the Republic of Estonia under Registration Code number 16451354 on 28-02-2022 ("BUTCLICK", "we", "us", "our" or "our") is committed to protecting users' privacy. This Privacy Policy to describe to you our practices with respect to Personal Data (as defined below) that we collect, use and share in connection with our branded website and Perception Face product and service lines, mobile application and other software provided on or in connection with our products and services. "NFT" in this Privacy Policy means a non-fungible token or similar digital item implemented on a blockchain, the kind that uses smart contracts to link and/or associate with certain content and/or data, used for the management, holding and trading of virtual goods.
1. Types of Data We Collect. "Personal Data" means data that allows someone to be individually identified, including, for example, name, email address, as well as any other non-public information about you that is associated or linked to any of your Personal Data. "Anonymous Data" means data, including aggregated and de-identified data, that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data as described below:
a. Information you provide to us:
I. When you use our Service, update your account profile, or communicate with us, we may collect Personal Data from you, such as your email address, first and last name, username, and other information you provide. We also collect your blockchain address, which may be associated with Personal Data when you use our Service;
II. Our Service allows you to store preferences, such as how your content is displayed, notification settings, and favorites. We may associate these choices with your ID, browser and/or mobile device;
III. If you provide us with feedback or communicate with us, we will collect your name and contact information, as well as any other content included in the message;
IV. We may also collect Personal Data at other points on our Service that you voluntarily provide and/or where we indicate that Personal Data is being collected.
b. Information Collected Through Technology. As you browse and interact with our Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and/or patterns, including:
I. Information Collected by Our Servers. To provide our Service and make it more useful to you, we (or a third party service provider) collect information about you, including but not limited to your browser type, operating system, Internet Protocol ("IP") address, mobile phone device ID, blockchain address, wallet type and/or date/time stamps;
II. Log Files. As with most websites and applications, we collect certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet Service Provider ("ISP"), referring/exit pages, operating system, date/time stamps, and clickstream data. We use this information to analyze trends, administer the Service, track users' movements around the Service and better tailor our Services to our users' needs. For example, some of the information may be collected so that when you visit the Service, it recognizes you and the information can be used to personalize your experience;
III. Cookies. Like many online services, we use cookies to collect information. We may use session Cookies (which expire once you close your web browser) and persistent Cookies (which remain on your computer until you delete them) to analyze how users interact with our Service, make improvements to the quality of our product, and provide users with a more personalized experience;
IV. Pixel tag. In addition, we use "Pixel Tags" (also known as clear Gifs, web beacons or web bugs). Pixel tags allow us to analyze how users find our Service, to make the Service more useful to you, and to tailor your experience with us to meet your particular interests and needs;
V. How We Respond to Do Not Track Signals. Our systems do not currently recognize "do not track" signals or other mechanisms that may allow Users to opt-out of tracking on our site;
VI. Analytics Services. In addition to tracking technologies we place, such as cookies and pixel tags, other companies may set their own cookies or similar tools when you visit our Service. This includes third-party analytics services ("Analytics Services") that we engage to help analyze how users use the Service. Information generated by Cookies or other technologies about your use of our Service ("Analytics Information") is transmitted to Analytics Services. The Analytics Services use the Analytics Information to compile reports on user activity, which we may receive on an individual and/or aggregated basis. We use the information we obtain from the Analytics Services to improve our Service. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on your behalf. Each Analytics Service's ability to use and share Analytics Information is restricted by the terms of use and privacy policy of such Analytics Services. By using our Service, you consent to the processing of data about you by the Analytics Services in the manner and for the purposes set forth above.
c. Information Collected from Third Party Companies. We may receive Personal and/or Anonymous Data about you from companies that offer their products and/or services for use in conjunction with our Service or whose products and/or services may be linked from our Service. For example, third party wallet providers provide us with your blockchain address and certain other information that you choose to share with those wallet providers. We may add this to the data we have already collected from or about you through our Service.
d. Public Information obtained from the blockchain. We collect data from activities that are publicly viewable and/or accessible on blockchains. This may include blockchain addresses and information about purchases, sales and/or transfers of NFTs, which may then be associated with other data provided to us.
2. Use of your personal data:
a. We process your Personal Data to administer our business, provide our Services, personalize your experience on the Service, and improve the Service. Specifically, we use your Personal Data to:
I. Facilitate the creation and/or security of your account;
II. Identify you as a user in our system;
III. provide you with our Service, which includes, but is not limited to, helping you view, browse NFTs using our tools and, at your own discretion, connect directly with us and others to buy, sell or transfer NFTs on public blockchains;
IV. Improve the administration of our Service and the quality of the experience when you interact with our Service, including, but not limited to, analyzing how you and/or other users find and interact with the Service;
V. Provide customer service and/or respond to customer requests and/or inquiries;
VI. Investigate and/or address conduct that may violate our Terms and Conditions of Use;
VII. Detect, prevent and/or address fraud, violations of our terms or policies and/or other harmful and/or illegal activities;
VIII. Display your username next to the NFTs that belong to you and next to the NFTs you have interacted on;
IX. Send you a welcome email to verify ownership of the email address provided when your account was created;
X. Send you administrative notices, such as security, support and/or maintenance notices;
XI. Send you notifications regarding actions on the Service, including notifications of offers relating to your NFTs;
XII. Send you newsletters, promotional materials and/or other notices regarding our Services or third party goods and/or services;
XIII. Respond to your inquiries regarding employment opportunities and/or other requests;
XIV. Comply with applicable laws, cooperate with investigations by law enforcement or other authorities of suspected violations of law, and/or pursue or defend against threats and/or legal claims; and
XV. Act in any other way that we may describe when Personal Data is provided to us.
b. We may create anonymous data records from Personal Data. We use this Anonymous Data to analyze request and/or usage patterns so that we can improve our Services and/or improve navigation of the Service. We reserve the right to use Anonymous Data for any purpose and to disclose Anonymous Data to third parties without restriction.
3. Disclosure of your Personal Data. We disclose your Personal Data as described below:
a. Third Party Service Providers. We may share your Personal Data with third party service providers to: provide technical infrastructure services; perform quality assurance testing; analyze how our Service is used; prevent, detect and/or respond to unauthorized activity; provide customer and technical support; and/or otherwise support us and the Service.
b. Affiliates. We may share some and/or all of your Personal Data with subsidiaries, joint ventures or other companies under our Internal Joint Affiliate Control, in which case we will require our Affiliates to abide by all of our policies, including the one contained herein.
c. Corporate Restructuring. We may share some or all of your Personal Data in connection with or during the negotiation of any transaction or merger, financing, acquisition or dissolution proceeding involving the sale, transfer, divestiture or disclosure of all or a portion of our business or assets. In the event of insolvency, bankruptcy or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business or assets, that company will own the Personal Data collected by us and will assume the rights and obligations with respect to your Personal Data as described in this Privacy Policy.
d. Legal Rights. Regardless of the choices you make with respect to your Personal Data (as described below), Butclick Technology OÜ may disclose Personal Data if it believes in good faith that such disclosure is necessary: (a) in connection with any legal investigation; (b) to comply with applicable laws and/or to respond to subpoenas, court orders or other legal process; (c) to protect or defend the rights or property of Butclick Technology OÜ and/or Perception Face or users of the Service; and/or (d) to investigate and/or help prevent any violation and/or potential violation of law, this Privacy Policy and/or our Terms and Conditions of Use.
e. Other Disclosures. We may also disclose your Personal Data: to fulfill the purpose for which it is provided by each user; for any other purpose disclosed by us when such data is provided to us and/or with the user's consent.
4. Third Party Websites. Our Service may contain links to third-party websites. When you click on a link to any other website or location, you will leave our Service and go to another site, and another entity may collect your Personal Data. We have no control over user activity on other sites, do not review and cannot be responsible for those third party websites and/or their content. Please note that the terms of this Privacy Policy do not apply to those third party websites or their content, or to any collection of your Personal Data after you click on links to those third party websites. We encourage all of our users and/or visitors to our sites to read the privacy policies of each website they visit. All links to third party websites and/or locations are for your convenience and do not signify our endorsement of such third parties and/or their products, content or websites.
5. Third Party Wallets. To use our Service, you must use a third party wallet that allows you to transact on public blockchains. Your interactions with any third party wallet provider are governed by that third party's applicable terms of service and privacy policy.
6. Your Choices Regarding Information. You have several choices regarding the use of information on our Services:
a. Email Communications. We may periodically send you newsletters and/or emails that directly promote the use of our Service or third party goods and services. When you receive newsletters or promotional communications from us, you may indicate your preference to stop receiving these communications by following the unsubscribe instructions provided in the email you receive and/or through the Notifications preferences on your Settings page. Despite these preferences, we may still send you occasional informational communications related to the transactional service.
b. If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, you can tell your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Please refer to your browser's technical information. However, if you do not accept Cookies, you may not be able to use all parts of the Service and/or part and/or all features of our Services.
7. Data Access and Control. You may view, access, edit and/or delete your Personal Data for certain aspects of the Service through your Settings page. You may also be able to exercise certain additional rights:
a. If you are a user in the European Economic Area or the United Kingdom, you have certain rights under the respective European and UK General Data Protection Regulations ("GDPR"). These include the right to (i) request access to and obtain a copy of your personal data; (ii) request its rectification or erasure; (iii) object to or restrict the processing of your personal data; and (iv) request portability of your personal data. In addition, if we have collected and processed your personal data with your consent, you have the right to withdraw your consent at any time;
b. If you are a California resident, you have certain rights under the California Consumer Privacy Act ("CCPA"). These include the right to (i) request access to, details and a copy of the personal information we have collected about you and/or shared with third parties; (ii) request deletion of the personal information we have collected about you; and (iii) the right to opt out of the sale of your personal information. As those terms are defined in the CCPA, we do not "sell" your "personal information";
c. If you wish to exercise your rights under the GDPR, CCPA or other applicable privacy or data protection laws, please contact us using the "Submit a request" link here or at the address provided in Section 13 below, specify your request and reference the applicable law. We may ask you to verify your identity or request further information about your request. We will consider and act on any prior request in accordance with applicable law. We will not discriminate against you for exercising any of these rights;
d. Without limiting the foregoing, we cannot edit or delete any information stored on a blockchain, as we do not have custody or control of any blockchain. Information stored on the blockchain may include purchases, sales and transfers related to your blockchain address and the NFTs held at that address.
8. Data Retention. We may retain your Personal Data for as long as you continue to use the Service, please note that with us or as long as necessary to fulfill the purposes described in this Privacy Policy, we may continue to retain your Personal Data even after you deactivate your account and/or stop using the Service, if such retention is reasonably necessary to comply with our legal obligations, resolve disputes, prevent fraud and/or abuse, enforce our Terms or other agreements, and/or protect our legitimate interests. When your Personal Data is no longer needed for these purposes, we will delete it.
9. Data Protection. We care about the security of your information and use physical, administrative and technological security measures to preserve the integrity and/or security of information collected through our Service. However, no security system is impenetrable and we cannot guarantee the security of our systems. In the event that any information in our custody and control is compromised as a result of a security breach, we will take steps to investigate and remedy the situation and, in accordance with applicable laws and regulations, we will notify those persons whose information may have been compromised. As such, each user is responsible for the security of their digital wallet and we urge them to take steps to ensure that their digital wallets remain secure. If you discover any problems with your wallet, we urge you to contact your digital wallet providers immediately.
10. Minors. We do not knowingly collect Personal Data from visitors under the age of 13. Our Terms of Service require that all users be at least 18 years of age. Children under the age of 18 shall and may use the Butclick Technology OÜ and/or Perception Face account of a parent or guardian, but only with the involvement of the account holder. If a child under the age of 13 submits Personal Data to us and we learn that the Personal Data is the information of a child under the age of 13, we will attempt to delete the information as soon as possible. If you believe that we might have Personal Information about a child under 13, please contact us using the "Submit a Request" link here or at the address in Section 13 below.
11. Users Outside the United States. If you are a user of the Service outside of the U.S., by visiting the Service and providing data to us, you acknowledge and agree that your Personal Data may be processed for the purposes identified in this Privacy Policy. In that case, you further agree that your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where the laws regarding the processing of Personal Data may be less stringent than the laws of the country applicable to you. By providing your Personal Data, you consent to such transfer.
12. Changes to this Privacy Policy. This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy on our website. The date of the last revision of the Privacy Policy is identified at the beginning of this Privacy Policy. You are responsible for periodically visiting our Service and this Privacy Policy to check for changes. You may even refrain from continuing to use our services if you do not agree with any future changes to our Privacy Policy, so you also have the right to notify us of your disagreement and receive a timely and effective response.
13. Frequently Asked Questions. If you have any questions, concerns and/or complaints about our Privacy Policy and/or our data collection and/or processing practices and/or if you wish to report any security breaches to us, please contact us using the "Submit a Request" link here.
