Data Privacy Policy

Last Modified: December 06, 2023

This policy applies to visitors to our platform located at Flooz.Trade / Flooz.xyz (the, “Platform”), and any mobile applications we offer yuniou (the “Apps” and together with the Platform, our “Services”), when accessed from within the United States of America. If you are present in the European Union when you access or use our Platform, please refer to the European Union Privacy Addendum.

Introduction

Flooz Inc. (“Company”, “us” or “we”) respects your privacy and is committed to protecting it through our compliance with this privacy policy.

This privacy policy describes the types of information we may collect from you or that you may provide when you use our Services, when you create an account with us to use the Platform or the Apps, when you purchase our NFTs, or when you engage in other activities on our Services, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please review this privacy policy together with the Terms of Service, and any Cookie Policy, if available, to understand all of your rights and obligations, and how we operate and offer our Services. Any defined terms used in this policy which are not defined herein shall have the meanings given to them in the Terms of Service.

This privacy policy applies to information we collect:

• On the Services;

• In email, text, and other electronic messages between you and the Services;

• Through mobile and desktop applications, if any, that you download from the Services;

• When you interact with our advertising and applications on third-party websites and services, if such advertising or applications include links to this privacy policy; and

• Through any other means associated with or relating to the Services.

This privacy policy does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or

• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Services.

Please read this privacy policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using the Services, you agree to the terms of this privacy policy.

This privacy policy may change from time to time. We will notify you via email and/or post a notice on our Service prior to such changes becoming effective.  Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the privacy policy periodically for updates.

Information About Children

Our Services are not intended for children under eighteen (18) years of age. No one under age eighteen (18) may provide any personal information to us or on or through the Services.

We do not knowingly collect personal information from children under the age of sixteen (16). If you are under sixteen (16), do not use or provide any information on the Services or on or through any of its features or register on the Services (if such feature is available), make any purchases through the Services (if such feature is available), use any of the interactive or public comment features of the Services (if such feature is available) or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.

If we learn we have collected or received personal information from a child under sixteen (16) years of age without verification of parental consent, we will delete that information.

If you believe we might have any information from or about a child under the age of sixteen (16), please contact us at privacy@flooz.xyz.

Information We Collect About You and How We Collect It

We may collect several types of information from and about users of our Services (some of which is considered “personal information” pursuant to applicable law), including:

• Information by which you may be personally identified, such as name, mailing address, e-mail address, telephone number, or any other information that the Service collects, which applicable law may consider personally identifiable, personal information, personal data, and other such designations;

• Information about the device you use to access the Services;

• Your IP address, Identifier for Advertisers (“IDFA”), Android/Google Advertising ID, International Mobile Equipment Identity (“IMEI”), or another unique identifier;

• Your device characteristics and functionality (including information about your operating system, hardware, mobile network, browser, browser language, etc.);

• Referring and exit web pages and URLs;

• Your browsing history, including the areas within our Services that you visit and your activities there, including remembering you and your preferences;

• Your device location or other geolocation information, including the zip code, state or country from which you accessed the Services;

• Certain other device data, including the time of day you visit our Services; and

• Information about your internet connection and internet provider.

We may collect this information:

• Directly from you when you provide it to us, such as when filling in forms on the Services (including when you register for an account, when you purchase NFTs, when you trade any digital asset, when you subscribe to a service, when you request something from us, or when you fill out surveys).

• Automatically as you navigate through the Services, including through the use of cookies, web beacons, and other tracking technologies (including information about your network or computing device);

• From third parties, for example, our business partners;

• Records and copies of your correspondence (including email addresses), if you contact us through the Services;

• When you engage in transactions on our Services;

• When you run searches on our Services; and

• When you contact our customer service agents, if available.

Data Collection Technologies

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about you, your equipment, your technology providers, and your activities, including:

• Details of your visits to our Services, including traffic data, browsing patterns, location data, logs, and other communication data and the resources that you access and use on the Services; and

• Information about your device and about your internet connection and service provider, including:
  • Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
  • Your device functionality (including information about your operating system, hardware, mobile network, browser, browser language, etc.);
  • Referring and exit web pages and URLs;
  • Your browsing history, including the areas within our Services that you visit and your activities there, including remembering you and your preferences;
  • Your device location or other geolocation information, including the zip code, state or country from which you accessed the Services;
  • Your device characteristics;
  • Certain other device data, including the time of day you visit our Services; and
  • Information about your internet connection and internet provider.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically may be statistical data and may also include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. This information enables us to:

• Allow you to use and access the Services, including preventing fraudulent activity and improving security functionality;

• Assess the performance of the Services, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Services;

• Offer you enhanced functionality when accessing the Services, including identifying you when you sign into our Services, and keeping track of your specified preferences;

• Deliver content relevant to your interests on our Services and third-party sites based on how you interact with our advertisements and/or content;

• Estimate our audience size and usage patterns;

• Speed up your searches; and

• Analyze our services and products and perform market research.

When you visit or leave our Services by clicking a hyperlink or when you view a third-party site that includes our plugins or cookies (or similar technology), we may automatically receive the URL of the site from which you came or the one to which you are directed.

We may also receive location data passed to us from third-party services or GPS-enabled devices that you have set up, which we may use [to show you local information on our mobile applications and] for fraud prevention and security purposes. For location information, we may use this information to provide customized services, content, and other information that may be of interest to you. If you no longer wish for us, our affiliates, or our service providers to collect and use location information, you may disable the location features on your device. Consult your device manufacturer settings for instructions on how to do this. Please note that if you disable such features, your ability to access certain features, services, content, or products may be limited or disabled. The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Note that while you can set your browser to not allow cookies, we may not be able to honor that request, and may track your activity and collect information about you and your online activities even when the browser is set to “do not track”;

• Flash Cookies. Certain features of our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Services. Flash cookies are not managed by the same browser settings as are used for browser cookies and you may not be able to shut down our collection of and use of information through this technology;

• Web Beacons, Pixels and Tags. Pages of our Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity);

• Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Services, such as information about the links you click on;

• ETag, or entity tag. An ETag, or entity tag, is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. It is one of several mechanisms that HTTP provides for web cache validation. These allow websites to be more efficient and not serve content again, when data is already cached and ready to view;

• Fingerprinting. Fingerprinting refers to the collection and analysis of information from your device, such as your operating system, plug-ins, system fonts and other data, for purposes of identification;

• Recognition Technologies. Recognition technologies refers to various technology features used by websites, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user); and

• Log Files. These track actions occurring on our Services, and which help us collect your IP address, browser type, Internet service provider, the webpages from which you came or to which you go before and after visiting our Services, and the date and time of your visits.

Google Analytics

We may use Google Analytics, a service provided by Google, Inc. (“Google”) for various purposes, including potentially to analyze traffic on our Services, to grow our business, to improve and develop our services, to monitor and analyze use of our services, to aid our technical administration, to increase the functionality and user-friendliness of our services, and to verify that users have the authorization needed for us to process their request. Google may collect your IP address, and other information (although typically not your name), and utilizes the data collected to track and examine the use of our Services, and to prepare reports for us based on your activities online, among other uses. As part of Google Analytics, Google tracks many variables, including what website you visited prior to coming to our Services, how long you stay on a particular page, and your geographic location. Please be aware that Google uses the data it collects from our Services for its own purposes, and we do not control or direct such usage. Please visit Google’s privacy policy to understand how Google uses the information it collects: https://policies.google.com/privacy?hl=en-US. You may be able to opt out of the use of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/.

Cookie3.io

We may use Cookie3, a marketing intelligence and analytics platform, run by Cookie3 OÜ (Harju maakond, Tallinn, Nõmme linnaosa, Rännaku pst 12, 10917) to analyze the use of our services in order to improve technical product performance and user experience. Cookie3 unifies marketing analytics, giving Flooz actionable insights. You can find more information on how Cookie3 uses data on https://www.cookie3.co/privacy.

Firebase

We may use Firebase, an analytics service provided by Google.  Google claims that you may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en.  For more information on what type of information Firebase collects, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en.

GitHub

We may use third-party Service Providers to automate the development process of our Service. (“GitHub”) GitHub is provided by GitHub, Inc. GitHub is a development platform to host and review code, manage projects, and build software. For more information on what data GitHub collects for what purpose and how the protection of the data is ensured, please visit GitHub Privacy Policy page: https://help.github.com/en/articles/github-privacy-statement

Vercel

We may use Vercel, a service provided by Vercel Inc. (Vercel Inc., 340 S Lemon Ave #4133, Walnut, CA 91789, USA) for various purposes, including hosting our website and potentially to analyze traffic on our Services, to grow our business, to improve and develop our services, to monitor and analyze use of our services, to aid our technical administration, to increase the functionality and user-friendliness of our services, and to verify that users have the authorization needed for us to process their request. You can find more information on how Vercel collects data in their data privacy section: https://vercel.com/legal/privacy-policy

Hotjar

We may use Hotjar (Hotjar Ltd, Dragonara Business Centre,5th Floor, Dragonara Road, Paceville St Julian’s STJ 3141,Malta) to better understand the needs of our users and to optimize the offering and experience on this website. Using Hotjar’s technology, we get a better understanding of our users’ experience (e.g. how much time users spend on which pages, which links they click, what they like and dislike, etc.) and this helps us to tailor our offering to our users’ feedback and thus improve users’ experience on our site. Hotjar works with cookies and other technologies to collect data about our users’ behavior and about their devices, in particular IP address of the device (collected and stored only in anonymized form during their website use), screen size, device type (Unique Device Identifiers), information about the browser used, location (country only), language preferred to view our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually prohibited from selling the data collected on our behalf.

AWS

We may host our website with AWS. The provider is Amazon Web Services, Inc. 410 Terry Avenue North Seattle WA 98109 (hereinafter: AWS). When you visit our website, your personal data is processed on the servers of AWS. In the process, personal data may also be transmitted to the parent company of AWS in the USA. More information can be found here: https://aws.amazon.com/privacy/

Webflow
We may use Webflow (Webflow, Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103) to build out websites. You can find more information on how Webflow handles data in their Data privacy policy:
https://webflow.com/legal/privacy

Sentry

We use Sentry (Functional Software, Inc. dba Sentry, with the registered seat: 132 Hawthorne Street, San Francisco, CA 94107; e-mail address: security@sentry.io; web: https://sentry.io/welcome/) to help us analyze in the event of a malfunction when and why the application might have misbehaved. You can learn more on how Sentry uses data here: https://sentry.io/privacy/

Facebook Pixel

We use Facebook Pixel (Meta Pixel) provided by Facebook, Inc., Facebook Headquarters 1 Hacker Way Menlo Park, CA 94025 to connect data from the Facebook advertising network with actions performed on Flooz. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network. You can access the privacy policy here:  https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

Statsig

We may use Statsig, provided by Statsig, Inc. 14725 SE 36th St #200, Bellevue, WA 98006, USA, to run A/B testing on new product features being released on the platform. Statsig might collect personald data - you can learn more on how Statsig uses data here: https://www.statsig.com/privacy

Moonpay

We offer Moonpay as one on-ramp provider. Users can connect to the Service to on-/ and off-ramp FIAT to crypto directly. In order for us to provide the service, we share data such as the wallet address and transaction details with Moonpay. More information on how Moonpay handles data can be found here: https://www.moonpay.com/legal/privacy_policy

Ramp Network

We offer Ramp Network as one on-ramp provider. Users can connect to the Service to on-/ and off-ramp FIAT to crypto directly. In order for us to provide the service, we share data such as the wallet address and transaction details with Ramp Network. More information on how Ramp Network handles data can be found here: https://ramp.network/terms-and-conditions/#privacy-policy

Transak

We offer Transak as one on-ramp provider. Users can connect to the Service to on-/ and off-ramp FIAT to crypto directly. In order for us to provide the service, we share data such as the wallet address and transaction details with Transak. More information on how Transak handles data can be found here: https://transak.com/privacy-policy

Mercuryo

We offer Mercuryo as one on-ramp provider. Users can connect to the Service to on-/ and off-ramp FIAT to crypto directly. In order for us to provide the service, we share data such as the wallet address and transaction details with Mercuryo. More information on how Mercuryo handles data can be found here:https://mercuryo.io/legal/privacy/

Customer.io

We use Customer.io, provided by Peaberry Software Inc. to automate our e-mail outreach and send out e-mail notifications. Customer.io may store personal information such as your e-mail address and name. You can learn more on how Paragraph handles data on: https://customer.io/legal/privacy-policy/

Web3 related services

We are using Web3 related services to ensure product performance and functionality. These services may collect personal identifiable information. You can find an overview of these services below:

• Wallet Link: wss://www.walletlink.org/rpc

• Wallet Connect: wss://.bridge.walletconnect.org | https://registry.walletconnect.com

Dynamic.XYZ

We are using Dynamic.XYZ, provided by Dynamic Labs, Inc. (Palo Alto, California, USA), to facilitate the setting up of wallets in our system. Dynamic.XYZ may store personal information such as your e-mail address and name and share these information with Flooz us. Further, Dynamic.XYZ integrates services such as Chainalysis, provided by Chainalysis Inc., (114 5th Avenue, 18th Floor, New York, NY 10011) that provides analytical services to identify and block sanctioned wallets or users that have interacted with sanctioned wallets. You can learn more on how Dynamic.XYZ and Chanailysis handle data on: https://www.dynamic.xyz/privacy-policy | https://www.chainalysis.com/privacy-policy/

Behavioural Advertising

We may use your personal information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We use a few third party tools for this purpose: Google Ads (AdWords) remarketing service is provided by Google.  Google claims that you can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. They also claim that Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.  For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en. Facebook remarketing service is provided by Facebook Inc.  You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950. Facebook claims that you can opt-out from Facebook’s interest-based ads by following their instructions available at: https://www.facebook.com/help/568137493302217. Facebook claims to adhere to the self-regulatory principles for online behavioral advertising established by the Digital Advertising Alliance. Facebook also claims that you can opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.  For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation. Pinterest remarketing service is provided by Pinterest Inc.  Pinterest claims that you can opt-out from Pinterest’s interest-based ads by enabling the “Do Not Track” functionality of your web browser or by following Pinterest instructions: http://help.pinterest.com/en/articles/personalization-and-data.  You can learn more about the privacy practices and policies of Pinterest by visiting their Privacy Policy page: https://about.pinterest.com/en/privacy-policy.

Payments

We may provide paid products and/or services within the Services. In that case, we use third-party services for payment processing (e.g. payment processors). We will not store your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their own privacy policy. These payment processors assure us that they adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements are intented to secure payment information.

Do Not Track

Do Not Track (“DNT”) is a concept promoted by certain regulatory authorities and industry groups for development and implementation of a mechanism that would allow internet users to control the tracking of their online activities across websites. Currently, various browsers (including Internet Explorer, Firefox, and Safari) offer a DNT option that allows a user to set a preference in the browser to not have his/her activities on the internet tracked. You can usually access your browser’s DNT option in your browser’s preferences. When a user’s browser is set to DNT, some cookies and other tracking technologies may become inactive, depending on how the website visited responds to DNT browser settings. If that occurs, the website visited will not recognize you upon return to that website, save your passwords or user names, and some other features of a website may become unavailable or not function properly.

Given the lack of a standard in the industry or any clear regulatory guidance on this issue, we may not comply with DNT signals from your browser at this time.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Services may be served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We may use information that we collect about you or that you provide to us, including any personal information:

• To present our Services and its contents to you and to maintain the Services (we may match your e-mail with your wallet address to provide better insights for you);

• To provide you with information, products, or services that you request from us;

• To fulfill any other purpose for which you provide it;

• To provide you with notices about your account and/or the Services;

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection, if needed;

• To provide customer support;

• To notify you about changes to our Services or any products or services we offer or provide though it;

• To allow you to participate in interactive features on our Services, if any;

• To develop and create our products and services;

• For behavioral tracking, profiling and advertising;

• For any other purpose as needed for our business;

• In any other way we may describe when you provide the information;

• For any other purpose with your consent;

• To contact you about our own and third-parties’ goods and services that we think may be of interest to you;

• To monitor usage of our Services;

• In any other way we may describe when you provide the information; and

• To enable us to display advertisements to our advertisers’ target audiences.

Because your data belongs to you, you may choose to have us change the way we use your data in some circumstances. Please contact us if you would like more information about how to do this.

Retention of Data

We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to perform our obligations and make the Services available to you, to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain collected usage data for internal analysis purposes. Usage data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

Updating Personal Information

We prefer to keep your personal information accurate and up to date. If you would like to change your contact information, please contact us at privacy@flooz.xyz. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates;

• To contractors, service providers, and other third parties we use to support our business and assist us in providing services and offering our products;

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets or stock, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Services users is among the assets transferred;

• To third parties to market their products or services to you;

• To fulfill the purpose for which you provide it;

• For any other purpose disclosed by us when you provide the information; and

• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including responding to any government or regulatory request;

• To enforce or apply the Terms of Service, including this privacy policy, and any other agreements between us, including for billing and collection purposes; and

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Keep in mind that some of your information (e.g., our digital wallet ID, and other identifiers) may be available to other members of the Services, and that some of that information will be stored in a blockchain, visible to all other NFT buyers. You specifically consent to the use of that information and disclosure in such a manner.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone and to change your password from time to time. We also highly recommend that you use a password that is dissimilar to and cannot be easily found by unauthorized third parties who may have obtained your login credentials to other sites. Keep in mind that if you use the same password for all websites, if someone obtains your credentials for one site, they may be able to then use those credentials to log into any other site you use.

Unfortunately, the transmission of information via the internet is not completely secure. Although we try to protect your personal information, we cannot guarantee the security of your personal information transmitted through or collected through the use of our Services. Any transmission of personal information is at your own risk.

We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

California Residents

California Civil Code Section § 1798.83, known as the “Shine The Light” law, permits users of our Site who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding year, and the names and addresses of those third parties. You may request this information from us no more than once a year, but such request will be handled by us free of charge to you. To make such a request, please send an email to privacy@flooz.xyz.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account, if applicable. We may also post a notice on the Services home page. The date this privacy policy was last revised is identified at the top of this page. You are responsible for periodically visiting our Services and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: E-mail: privacy@flooz.xyz.