Privacy Policy

Last updated: February 6, 2023 

‍Introduction
‍Flockke Pte. Ltd., d/b/a Flockke (“Flockke,” “we,”“us” or “our”) provides a platform that enables users to maintaina digital custodial wallet that manages access to digital assets on the blockchainand integrates with decentralized applications provided by third parties. 
This Privacy Policy discloses our privacy practices forpersonal information we collect and use when you access our products, services,features, or content, without limitation, through our website at www.Flockke.xyz (the“Site”), our services to facilitate the purchase, storage, and transferof certain Digital Collectibles (“DIGITAL COLLECTIBLE(s)”), and softwareprovided on or in connection with those services (collectively, the “Service”),or when you apply or express interest in employment with Flockke.
By accessing, browsing and/or otherwise using the Siteand/or our Service, we collect the personal data of each user (the "User"or, indistinctly, the "Users") in accordance with this privacypolicy ("Privacy Policy") and any other policy that mayreplace it in the future.

‍1. Acceptance of this Privacy Policy
‍By accessing, browsing and/or otherwise using the Siteand/or our Service, you accept the terms of this Privacy Policy. If you do notagree with or you are not comfortable with any aspect of this Privacy Policy, you should discontinue access or use of our Site and Service.
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2. Data Controller
‍The data controller responsible for the collection andprocessing of your personal data is Flockke Pte. Ltd., with tax identificationnumber 202244474E, domiciled at 1 Tampines North Drive 1 #06-08 T-Space,Singapore, 528559

‍3. How We Collect Your Personal Information
‍Flockke collects and processes various information fromUsers. This information may, in many cases, constitute Users' personal data.This information will be considered "personal data" when it candirectly identify or allow us to identify a natural person.
The categories of personal information we collect depend onhow you interact with our Service and the requirements of applicable law. Thispersonal data may have been directly provided by the User, when interacting onthe Site or completing any of the available forms, or which may have beeninferred from the relationship we have with you. Specifically: 
‍A. Information you provide to us. To sell or purchasea Digital Collectible, establish an account with a wallet, and access ourService, we will request that you provide us with important information aboutyourself. If you choose not to share certain information with us, we may not beable to serve you effectively or offer you our Service. Any information youprovide to us that is not required is voluntary.
We may collect the following types of information from you:
1. User Data:
- Contact data, such as first and last name, email address, mailing address, and phone number.
- Personal identification information, such as date of birth, nationality, gender, signature, and photographs.
- Formal Identification Information, Government issued identity documents such as Passport, Driver's License, National Identity Card, State ID Card, Tax ID number, and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.
- Communications that we exchange with you, including when you contact us through the Service, social media, or otherwise regarding the Service.
- Transaction data relating to or needed to complete your transactions through the Service, such as the wallet addresses, your name, the transaction amount, Digital Collectible, and/or timestamp.
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2. Potential users and clients
- Marketing data such as your preference for receiving our marketing communications and details about your engagement with them.
- Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

3. Prospective employees
- Employment data, such as information submitted in resumes, cover letters, and/or applications.


‍B. Information we may collect automatically about you. 

‍(i) Service Data. To the extent permitted underthe applicable law, we, our service providers, and our business partners mayautomatically collect information about you, your computer, mobile device, andyour interaction over time with the Service, our communications and otheronline services. Information collected automatically includes:
- Wallet data, in order to provide the Service, we will create an account with a custodial wallet address and will collect data about your wallet such as the Digital Collectible related attributes on the blockchain and details about transactions that you executed.
- Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier,     radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your     activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

‍(ii) Cookies and similar technologies. We, as well asthird parties that provide content, or other functionality on the Service, mayuse cookies, local storage, and other technologies to automatically collectinformation through the Service.
- Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site.     Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
- Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
- Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked.

‍(iii) Analytics. We use website analytics software tohelp us understand user activity on the Service, including which pages are mostand least visited and how visitors move around the Service, as well as userinteractions with our emails. For example, we use Fathom Analytics for thispurpose. 

‍(iv) Social Sign In. Our Service allows you tosign in with Google or Discord third party social sign services. These featuresmay collect your IP address and which page you are visiting on our Service, andmay set a cookie to enable the feature to function properly. Your interactionswith these platforms are governed by the privacy policy of the companyproviding it.

If required by applicable law, in (i) to (iv) above we willobtain the necessary consents or treat this information always under anappropriate legal basis.

C. Information we receive from third parties: We receive personal data about you from third parties:
- Due to mergers or acquisitions, when we obtain your data from another company.
- Public sources, such as government agencies, public records, social media platforms, identification verification partners, credit bureaus, and other publicly available sources.
- Data providers, such as information services and data licensors that provide demographic and other information. 
- Public blockchain data, such as public addresses and public transaction data.

‍Third-party services, such as Google and Discord’ssocial media services, that you use to log into, or otherwise link to, yourService account. This data may include your username, profile picture and otherinformation associated with your account on that third-party service that ismade available to us based on your account settings on that service. Thesefeatures may collect your IP address and which page you are visiting on ourService, and may set a cookie to enable the feature to function properly. Yourinteractions with these platforms are governed by the privacy policy of thecompany providing it.

‍What We Use Your Personal Information For.
‍Our primary purpose in collecting personal information is toprovide, develop and, ultimately, improve the provision of the Service, and toprovide you with a secure and customized experience. We may use your personalinformation for the following purposes - or as otherwise described at the timeof collection:

‍A. Delivering our service. When you create your Flockkeaccount and use our Service, you accept our Terms of Service and thus enterinto a contract. In order for us to fulfill our obligations under thatagreement, we need to access and process your personal information. We will notbe able to service you do not include your details in your account registrationor if, when you make a purchase or proceed to payment, you do not provide yourpersonal details.

Within the framework of this purpose of treatment, we mayuse your personal information to: 
- fulfill our contract with you and provide the Service.
- enforce our terms in our user agreement (Terms of Service) and other agreements.
- provide Service communications.
- provide customer service in responding to questions, comments, and other requests.
- enhance your experience, improve Service, and develop new services.
- ensure quality control.

‍Third parties such as identity verification services mayalso access and/or collect your personal information when providing identityverification and/or fraud prevention services on our behalf.

‍B. Research and development. We may use yourpersonal information to better understand the way you use and interact with ourService,, including to analyze and improve the Service and our business and todevelop new services.

‍C. Direct marketing. Based on your communicationpreferences, we may send you direct marketing communications. You may opt-outof our marketing communications in every such communication we send you or asdescribed in the Opt-outof marketing section below. Our marketing will be conducted inaccordance with your advertising marketing preferences and as permitted byapplicable law.

‍D. To manage our recruiting and process employment applications. We may use personal information, such as information submitted to us in a jobapplication, to facilitate our recruitment activities and process employmentapplications, such as by evaluating a job candidate for an employment activity,and monitoring recruitment statistics.

‍E. Compliance and protection. We may use yourpersonal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities
- comply with anti-money laundering regulations and help detect, prevent, and mitigate fraud and abuse of our Service;
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); 

audit our internal processes for compliance with legal andcontractual requirements or our internal policies; and
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- enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

‍F. With your consent. We will not use yourpersonal information for purposes other than those purposes we have disclosedto you, without your permission. In some cases, we may specificallyask for your consent to collect, use or share your personal information, suchas when required by law.

‍G. To create anonymous, aggregated or de-identifieddata.  We may create anonymous, aggregated or de-identified datafrom your personal information and other individuals whose personal informationwe collect.  We make personal information into anonymous, aggregated orde-identified data by removing information that makes the data identifiable toyou.  

We may use anonymized or aggregate customer data for anybusiness purpose, including to better understand customer needs and behaviors,improve our Service, conduct business intelligence and marketing, and detectsecurity threats. We may perform our own analytics on anonymized data or enableanalytics provided by third parties.

Types of data we may anonymize include, transaction data,click-stream data, performance metrics, and fraud indicators.

4. Legal bases for processing your information
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‍For individuals who, at the time when we collect yourpersonal data, are located in the European Economic Area, the United Kingdom orSwitzerland (jointly, “EEA Residents''), our legal bases for processingyour personal information pursuant to the EU General Data Protection Regulation(“GDPR”) will depend on the personal information at issue, the specificbackground where the personal information is collected and the purpose forwhich such information is used. 

We usually only process your data where we are legally requiredto, where processing is necessary to perform our services and/or any agreementswe entered with you, where processing is in our legitimate interests to operateour business and not overridden by your data protection interests or rights, orwhere we have obtained your consent to do so. 

Below is a list of how we use your personal information withthe corresponding legal bases for processing:

‍Purpose of Processing
Legal Basis for Processing
‍(i) to enforce our terms in our user agreement and otheragreements; (ii) to provide the Service; (iii) to provide Servicecommunications (iv) to provide customer service; and (v) to ensure qualitycontrol

Based on our agreement with you or to take steps at yourrequest prior to entering into an agreement.
(i) for research and development purposes; (ii) to enhanceyour experience; and (iii) to engage in direct marketing activities

Based on our legitimate interests. When we process yourpersonal data for our legitimate interests, we ensure that we balance any potentialimpact on you and your rights under applicable laws.
(i) to maintain legal and regulatory compliance, includingbut not limited to anti-money laundering regulations; (ii) to detect andprevent fraud, funds loss, spam or other malware or security risks, as well asany other illegal activitu (iii) to ensure network and information security;(iv) to audit our internal systems; and (v) protect our, your or others’rights, privacy, safety or property.

Based on our legal obligations or the public interest.
(i) to enhance your experience; (ii) to engage in thirdparty marketing activities; (iii) to manage our recruiting and processemployment applications; and (iv) for any purpose to which you consent.

Based on your consent.

5. How We Share Your Personal Information

‍The holdings and transactions associated with a walletaddress are publicly available on the blockchain. Therefore, information aboutyour holdings and transactions will be accessible to third parties due to thenature of the blockchain. We may share your personal information with thefollowing categories of third parties and as otherwise described in this Privacy Policy or at the time of collection:
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‍Affiliates.  Our corporate parent,subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
Project Creators. We may share your Contact data with the projectcreator(s) of any Digital Collectibles you purchase through the Service,strictly to the extent necessary to provide the Service and execute the intendedtransaction initiated by you.
‍Service providers. We may share your personalinformation with our third-party service providers that provide services on ourbehalf or help us operate the Service or our business. This includes serviceproviders that provide us with technology support, hosting, payment processing(including financial institutions with which we partner to process payments youhave authorized), transaction monitoring, customer service, auditing,analytics, maintenance, security or other related business purposes. We may usethird-party Application Program Interfaces (“APIs”) and Software DevelopmentKits (“SDKs”) as part of the functionality of our Service.
Additionally, we may share your personal information withthird party identity verification services in order to prevent fraud. Thisallows CB to confirm your identity by comparing the information you provide usto public records and other third-party databases. These service providers maycreate derivative data based on your personal information that can be used inconnection with the provision of identity verification and fraud preventionservices.
‍Authorities and others. We may release yourinformation to law enforcement, government authorities, and private parties, aswe believe in good faith to be necessary or appropriate for the compliance andprotection purposes described above.
‍Business Transferees. We may release yourinformation to a third party if we are involved in a merger, acquisition, orsale of all or a portion of our stock or assets. If this occurs, you will benotified of any change to this Privacy Policy, as well as any choices you mayhave regarding your personal information.
‍Linked third-party services. If you log into theService with, or otherwise link your Service account to, a social media orother third-party service, we may share your personal information with thatthird-party service. The third party’s use of the shared information will begoverned by its privacy policy and the settings associated with your accountwith the third-party service.
‍Professional advisors.  Professional advisors,such as lawyers, auditors, bankers and insurers, where necessary in the courseof the professional services that they render to us.
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6. International Data Transfers

‍We are headquartered in the United States and may useservice providers that operate in other countries. To facilitate our globaloperations, we may transfer, store, and process your personal informationwithin our affiliates, third-party partners, and service providers basedthroughout the world (specifically, outside of the European Economic Area(“EEA”), UK and Switzerland, in what is defined as “third country transfers”under GDPR). 
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In cases where we intend to transfer personal data to thirdcountries or international organizations outside of the EEA, we put in placesuitable technical, organizational and contractual safeguards, to ensure thatsuch transfer is carried out in compliance with applicable data protectionrules, except where the country to which the personal information istransferred has already been determined by the European Commission to providean adequate level of protection.

We also rely on decisions from the European Commission wherethey recognize that certain countries and territories outside of the EuropeanEconomic Area ensure an adequate level of protection for personal information(“adequacy decisions”). 

7. Your Privacy Choices

‍‍Access or update your information. If you haveregistered for an account with us through the Service, you may review and update certain account information by contacting us.

 Opt-out of marketing communications.  You willreceive transaction-related emails regarding the Service you have requested. Wemay also send you certain non-promotional communications regarding us and ourService and you will not be able to opt out of those communications (e.g.,communications regarding the Service or updates to our Terms of Service or thisPrivacy Policy). 
You may opt-out of marketing-related emails by following theopt-out or unsubscribe instructions at the bottom of the email, orby contacting us. Please note that if you choose to opt-out ofmarketing-related emails, you may continue to receive service-related and othernon-marketing emails pursuant to your use of the Service.

‍Cookies and similar technologies. You may stopor restrict the placement of cookies and web beacons on your device or removethem by adjusting your preferences as your browser or device permits.

‍Do Not Track. Some Internet browsers may beconfigured to send “Do Not Track” signals to the online services that youvisit. We currently do not respond to “Do Not Track” or similar signals. Tofind out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

‍Linked third-party platforms. If you choose toconnect to the Service through your social media account or other third-partyplatform, you may be able to use your settings in your account with thatplatform to limit the information we receive from it. If you revoke our abilityto access information from a third-party platform, that choice will not applyto information that we have already received from that third party.

8. Data Retention

‍We retain your personal information for as long as necessaryto fulfill the purposes for which we collected it to provide the Service,including for the purposes of satisfying any legal, accounting, or reportingobligations or to resolve disputes, or as otherwise communicated to you.

9. Information Security

‍We take steps to secure your information in accordance withthis Privacy Policy. We have technical and administrative safeguards to protectthe security and confidentiality of your personal information. Unfortunately,no system is 100% secure when transmitting and storing data, and we cannotensure or warrant the security of any information you provide to us. 
By using the Service or providing personal information tous, you agree that we may communicate with you electronically regarding security,privacy, and administrative issues relating to your use of the Service. If we learn of a breach, we may attempt to notify you electronically by posting anotice on the Site or by sending you an email.

10. Third Party Websites or Applications

‍The Service may contain links to other websites/applicationsand other websites/applications may reference or link to our Service. Inaddition, our content may be integrated into websites or other online servicesthat are not associated with us. We encourage our users to read the privacypolicies of each website and application with which they interact. These third-party service are not controlled by us. We do not endorse, screen, or approve,and are not responsible for, the privacy practices or content of such otherwebsites or applications. Providing personal information to third-partywebsites or applications is at your own risk.  

11. Children’s Personal Information

‍The Service is not intended for use by anyone under the ageof 18 and we do not knowingly request to collect personal information from anyperson under the age of 18. If a user submitting personal information issuspected of being younger than 18 years of age, we will require the user toclose his or her account and will not allow the user to continue using ourService. We will also comply with applicable legal requirements and take stepsto delete the information as soon as possible. Please notify us if you know ofany individuals under the age of 18 using our Service so we can take action toprevent access to our Service.  

12. Changes to our Privacy Policy

‍We may, in our sole discretion, change this Privacy Policyfrom time to time by posting a revised version at www.flockke.com/privacy-policy. If we make any material change to this Privacy Policy, we will notify you byposting a notice on www.Flockke.com/privacy prior to the change becomingeffective and may also elect to send you an email notifying you of the policymodifications. Any modifications to this Privacy Policy will be effective uponour posting the modified version (or as otherwise indicated at the time ofposting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.  

13. Your privacy rights

‍Depending on applicable law where you reside, you may beable to assert certain rights related to your personal information, asdisclosed below. If any of these rights are not provided under law for thejurisdiction we you reside, we reserve our right to provide you with those rights.
1. Access: you have the right to obtain the confirmation that your personal information is being processed as well as the right to obtain a copy of such information. 
2. Rectification: you may request the rectification of any personal information held by us which that you deem inaccurate. You can also change your personal information directly in your account at any time.
‍ 3. Deletion: you can, in some cases, have your personal information deleted. However, please note that even after closing your account we may keep certain account information in our database pursuant to applicable law and to     assist law enforcement.
‍ 4. Objection: you can object, for reasons relating to your particular situation, to theprocessing of your personal information. Additionally, in some jurisdiction, you may be have the right not to be subject to a decision based solely on automated processing of your personal information.
5. Restriction of processing: You have the right, in certain cases, to temporarily     restrict the processing of your personal information by us. However, please note we may continue to process your personal information if it isnecessary pursuant to applicable law.
6. Portability: in some cases, you can ask to receive your personal information which you have provided to us in a structured, commonly used and machine-readable format, or, when this is possible, that we communicate your personal information on your behalf directly to another data controller.
7. Withdraw consent: to the extent we are processing your information based onyour consent, you have the right to withdraw your consent at any time.This withdrawal does not affect the lawfulness of the processing based on the consent given before the withdrawal.

Note these rights may be limited where we can demonstrate wehave a legal requirement to process your personal data.

‍How to lodge a complaint. We hope that we cansatisfy any queries you may have about the way in which we process yourpersonal information, so we encourage you to submit your claim to our DataProtection Officer at legal@flockke.xyz

However, if this does not satisfy you, you also have theright to complain to the data protection authority in the location in which youlive, work or believe a data protection breach has occurred.

14. Contact Us

‍If you have any questions about our privacy practices orthis Privacy Policy or would like to file a complaint, please contact us at:
‍Company Name: Flockke Pte. Ltd
‍Mailing Address:
‍Flockke Pte. Ltd.,
1 Tampines North Drive 1 #06-08 T-Space
Singapore, 528559
‍Email:legal@flockke.xyz