DIVINE RIGHTS LTD
WHO WE ARE
Divine Rights Ltd is a company registered in England and Wales with company number 13839045 and having its registered office at Charlotte House, 500 Charlotte Road, Sheffield, South Yorkshire, S2 4ER, United Kingdom (“we”/ “us”). By accessing the website at https://www.tdrbingo.com (the “Website”), you acknowledge and consent to the information collection and use practices by us in our capacity as data controller as described below. Please read this Privacy Notice carefully and contact us if you have questions or concerns by email at firstname.lastname@example.org.
Personal data means data relating to natural persons who can be identified or who are identifiable, directly from the data in question or who can be indirectly identified from that data in combination with other data (“Personal Data”).
We may process data relating to the transaction such as your wallet address, date of purchase, payment method and in some cases, information about your purchases and other public blockchain data (“Transaction Data”). Please note that blockchain data is not truly anonymous, as we may be able to identify you from a blockchain transaction because, in some circumstances, Personal Data published on a blockchain (such as your wallet address and/or IP address) can be correlated with other Personal Data that we and others may have.
In addition, we may process Personal Data that you may include in correspondence with us, when you email us, contact us via social media, or otherwise submit to us via our Website for example identity details (name, username, similar identifier, social media handles) (“Identity Data”) or your contact details such as your address, email address and telephone numbers (“Contact Data”), and any other Personal Data that you provide in your correspondence.
We may also process your Personal Data relating to page views and visit data such as IP address, device type, operating system, and browser type through Google Analytics (“Technical Data”).
Most of the Personal Data we process is provided directly by you or made available when you access or use the Website. We set out below some examples of how you may provide Personal Data to us:
- Where you connect your wallet to our Website;
- Submitting information by sending enquiries by e-mail, social media or otherwise; and/or
We may use your Personal Data for the following purposes and reasons:
- Contract: We may process your Transaction Data when you connect your wallet to our Website to purchase one of our NFTs and/or when you purchase one of our NFTs by private sale on secondary marketplaces. We may process this Personal Data to enable us to carry out the contractual relationship between you and us.
- Legitimate Interests: We may process additional Personal Data, such as Identity Data and Contact Data, that you submit to us (for example, exercising your data protection rights, requests for customer support and technical assistance) and Technical Data that we automatically collect using cookies.
- Where we rely on our legitimate business interests to process these categories of Personal Data about you, we will balance our legitimate interests against your interests and rights (for example, responding to enquiries, improving the Website, and enabling network and information security).
- Consent: We rely on consent when you subscribe to receive updates from us. We may process your Contact Data and Identity Data. You have the right to withdraw consent at any time, simply contact us by email on email@example.com.
- Legal Obligation: We may process your Personal Data to comply with our legal obligations, including your Technical Data (particularly your IP address) to avoid transacting with sanctioned individuals or countries, or to make disclosures to government, regulatory or other public bodies where in our reasonable opinion the disclosure is appropriate and permitted by law.
We may also collect Personal Data to perform other functions that are not listed above, which will either be described to you when the Personal Data is collected or it may be collected if you have granted your consent for a particular purpose.
The third-party platforms currently used include those set out below, but may change from time to time:
- Wallet Extensions: For conducting cryptocurrency transactions we use third-party electronic wallet extensions such as (but not limited to) MetaMask; your interactions with MetaMask and/or any third-party electronic wallet extensions are governed by the applicable privacy notices. In the case of MetaMask, its privacy notice is available here.
- Google Analytics: A web analytics service that provides statistics and basic analytical tools to track and report website traffic for marketing and search engine optimisation purposes. We use Google Analytics to keep track of how the Website is performing. Please read Google Analytics’ privacy notice here to understand how they process your Personal Data, particularly your Technical Data.
- Google LLC (“Google”): We use G Suite, a collection of cloud computing, productivity and collaboration tools, software and products developed by Google which includes Gmail, Contacts, Calendar, Meet and Chat for communication; Currents for employee engagement; Drive for storage; and the Google Docs suite for content creation. In particular, we will store certain Transaction Data (wallet address), Contact Data (email) and Identity Data (social media handles) on Google Drive. Please read Google’s privacy notice here to understand how they process this Personal Data.
We are not responsible for their privacy practices and you are encouraged to read their privacy notices.
We will not share your Personal Data with third parties other than as necessary for the purposes outlined above and only with third party service providers that provide business, professional or technical support functions on our behalf or as required by law.
Your Personal Data may be transferred outside the UK. For example, this may be in relation to where we are sharing information with our third party service providers who operate outside the UK. Where third parties process your Personal Data outside the UK, you are advised to read their privacy notice as set out above.
STORAGE AND RETENTION
We are strongly committed to protecting your Personal Data and we take reasonable and appropriate steps to protect your Personal Data from unauthorised access, loss, misuse, alteration or corruption. We have put in place physical, electronic, and organisational procedures to safeguard and secure the Personal Data you provide to us, including industry-standard access controls such as secure passwords and multi factor authentication.
We take reasonable steps to ensure that the Personal Data we hold about you is as accurate and complete as is necessary to carry out the relevant purposes described in this Privacy Notice and we will retain your Personal Data for so long as is reasonably necessary for us to fulfil the relevant purposes described in this Privacy Notice, unless a longer retention period is required or permitted by law (for example for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements or in the event of a complaint or where there is a prospect of litigation). We will then securely dispose of your Personal Data that we hold by permanently deleting it and any back-up files. Personal Data shared with third party service providers is stored and deleted according to their privacy notices.
Please be aware that no electronic transmission or storage of Personal Data can be guaranteed to be 100% secure. We cannot and do not warrant the security of any Personal Data that you transmit, and all such transmissions are done at your own risk.
Under the Data Protection Act 2018, you have rights including:
- Right of Access: To ask for copies of your Personal Data.
- Right to Rectification: To ask to rectify inaccurate/incomplete Personal Data.
- Right to Erasure: To ask for your Personal Data to be erased in certain circumstances.
- Right to Restriction of Processing: To ask to restrict the processing of your Personal Data in certain circumstances.
- Right to Object to Processing: To object to the processing of your Personal Data in certain circumstances.
- Right to Data Portability: To ask that your Personal Data be transferred to another organisation, or to you, in certain circumstances.
For more information or to exercise your data protection rights regarding our processing, please contact us by email. We will try to respond to all legitimate requests within one month. If you are unhappy with any aspect of how we handle your Personal Data you can make a complaint to the Information Commissioner’s Office (ICO) here.
CHANGES TO THE PRIVACY NOTICE
This Privacy Notice may be updated from time to time. All amendments will take effect immediately upon posting of the updated Privacy Notice on this Website. If the changes are material, we will post a notice on the Website before the changes go into effect. We encourage you to periodically review this Privacy Notice to stay informed about how we are helping to protect your Personal Data.
This version of the Privacy Notice was last updated on 14th May 2022.