# GemPION\_PRIVACY POLICY ![](https://lh6.googleusercontent.com/TXNAv_MbvafGLHo2j7clil6_zX0nsPeJ5Yk6uVZpNQ4j5NrwXr6DYMDCZrBpiFID2cYfREOGIyKiUNsTcBSOAFjt5cjUf_1d8IQxMln_XUjPce8K-XzcWEZik9U2-hy-2mUgW2cfNIjUjtav5-K83X0) 1\. Introduction This Privacy Policy describes personal data collection and processing executed by our company (company requisites) in particular this policy is to ensure that we collect, store and disclose your information in compliance with the requirements defined by South KOREA Data Protection Act. This Policy is to help you understand which data is being collected and how the data is used, all that to help you effectively manage your personal data. You acknowledge and agree with the data collection requirements essential to the provisions of our services, you also confirm that you are informed about required disclosures of your data for the development, regulatory, financial, and marketing purposes. If you feel comfortable, you may provide us with your consent to process your data for marketing purposes, you may also withdraw your consent at any time. Your relations with the company and usage of the products and services developed by the company are regulated exclusively by our Privacy Policy. Data processing on this website and the game is regulated by this Privacy Policy only. We may use services and products issued by 3rd parties. These linked services and products may use their own tools and procedures to collect, process, and store your data, and more importantly, is that every 3rd party service is regulated by its own Privacy Policy. In GemHUB we are absolutely committed to the safety and integrity of your personal data and privacy. This policy is effective as of the 9th of August 2023. Our data protection team may be approached by email - . Any major update of this Policy will be published on our website, please familiarize yourself with updated versions in a timely manner. 2\. Cookies warning 2.1 Cookies or pixel tags are small data files, they are placed and stored on your hard drive or in device memory. Cookies and pixels might be used by us, or by 3rd parties. Consenting with this policy you are not consenting with the cookies and pixels created by 3rd parties. You may change the settings of your browser to reject cookies and pixels, as well as you may reject cookies and pixels in the cookie banner on the website. You accept and agree that if you do choose to remove or reject cookies or pixels, some options and features might become unavailable.2.2 Service Providers. The website currently uses Google YouTube and Google Analytics cookies, which may be subject to change in the future, in which case this Privacy Policy shall be updated accordingly. 3\. The data we collect We narrow our data collection to an absolute minimum, the goal of this data collection process is to enhance your enjoyment and experience in our metaverse. We do not keep the data indefinitely and dispose of it as soon as we no longer require it. 3.1 Non-personally identifiable data such as web-browser type, language preferences, referring website, plugins used, time and date you are visiting our site, and time spent on the website. 3.2 Potentially personally identifiable data such as your IP connection, email address, your wallet addresses. 3.3 We also collect potentially personally identifiable data via our social media: Telegram and Discord channels or in case you engage in communication with us via our socials or emails, we may record your chats and email exchanges with us. 3.4 We are obligated to collect and disclose your sensitive data if you are purchasing high-value virtual collectibles, purchases over 10.000 USD make us comply with the AML regulations. 3.5 We do not provide voice support and do not collect records of this type of communication. 3.6 Public blockchains provide transparency into transactions and the company is not responsible for information broadcasted on a blockchain. Your blockchain public address can be collected, and we would like to highlight that transactions that take place using blockchain are confirmed and managed via the blockchain, and the public address is visible to everyone. 3.7 Your login credentials and your communication in the game is potentially personally-identifying information that we collect and store. 4\. What do we do with data 1\) communicate with you; 2\) personalize your experience; 3\) to improve the website and the game; 4\) we do not use the IP data to identify you and we only disclose your personal information if we absolutely must do so, for example if we are requested by the authorities. 4.1 We may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website. We may disclose information to the third-party service providers for the purpose of enabling them to provide their services, for example, IT service providers, data storage, hosting and server providers, advertisers, or analytics platforms, our existing or potential agents or business partners, sponsors or promoters of any competition, sweepstakes, or promotion we run. 4.2 International Transfers. The Company allows access to potentially personally identifying and personally-identifying information on need to know basis only to those of project administrators, employees, contractors, and affiliated organizations who are essential to the provision of our services and this data sharing is protected by the NDA (non-disclosure agreements) required to gain access to the sensitive information held by the company. 4.3 Some of those administrators, employees, contractors, and affiliated organizations might be located outside of your country, by using the website and our services you agree to with the data transfer over your borders. 4.4 In case you supplied to us your email and consent we might send you emails to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on in our product, you are allowed to not consent with such newsletter emails and able to opt-out of them any time by primary written notice. We primarily use our blog and webchat to communicate this type of information, so we expect to keep this type of email to a minimum. 4.5 You acknowledge that your requests or suggestions or feedback sent to us might be published by us. 4.6 The company is not going to rent or sell potentially personally-identifying and personally-identifying information to anyone. 4.7 Disclosures. We may disclose personal information to enforce this policy in courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or to establish, exercise, or defend our legal rights. 4.8 If the company is reorganized or restructured your data may be disclosed to a parent, subsidiary, or affiliate of our company. 4.9 Protected personal data will not be transferred outside and will be retained by us, if not in use, for 5 years maximum. 4.10 It is our responsibility to implement measures reasonably necessary to protect us and your information against unauthorized access, use, alteration, or destruction. 5\. Your data management rights 5.1 You have certain rights to the personal information we hold about you. You have a right to: a) ask if we process any personal data about you and/or request a copy of personal information we hold about you; b) ask that we update the personal information we hold about you, or independently correct such personal information that you think is incorrect or incomplete; c) ask that we delete personal information that we hold about you from live systems, or restrict the way in which we use such personal information (for information on deletion from archives, see the “Retention of personal information” section); d) ask that we restrict processing of your personal data object to our processing of your personal information; e)ask for the data portability; and/or withdraw your consent to our processing of your personal information (to the extent such processing is based on consent and consent is the only permissible basis for processing). 5.2 If you would like to request access to your account data or exercise your rights regarding the information we hold, please send us an email to . 6\. Minors Protecting the privacy of young children is especially important. For that reason, GemPION does not knowingly collect or maintain personally identifiable information from persons under 18 years-of-age. If GemPION learns that personally identifiable information of persons less than 18- years-of-age has been collected on or through the GemPION Service, then GemPION will take the appropriate steps to delete this information. If You are the parent or legal guardian of a child under 18 who has become a GemPION member, then please contact GemPION at to have that child's account terminated and information deleted. 7\. Third parties links Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites and cannot accept responsibility or liability for their respective privacy practices, you have to acknowledge third parties Privacy Policies to use them. 8\. Legal ground We rely on one or more of the following processing conditions:1. our legitimate interests in the effective delivery of information and services to you;2. explicit consent that you have given;3. legal obligations;4. fulfilling an agreement (contractual relationship) with you. 9\. Updates and changes At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy. 10\. Contact For any questions or concerns regarding your privacy, you may contact us using the following details: