PRIVACY AND COOKIE POLICY 

In force as of: June 28, 2022 (the “Effective Date”) 

Introduction: 

Clancy International Inc., its affiliates and subsidiaries (“Clancy”, “we”, “us”, “our”) provides, through its website https://beta.euroreels.clancyworld.com/ (the “Platform”), users of the Platform (“Users”, “User”, “you” or “your”) with the opportunity to purchase, sell, collect, display and play with blockchain distributed ledger technology (“DLT”) digital collectible video play cards (“Collectible Video Cards”)). 

Clancy understands that protecting the privacy and confidentiality of information is important to its Users, and is committed to protecting and respecting such information. 

This privacy and cookie policy (“Policy”) explains our policies about data collection and user personal information of our Users when they use the Platform, including the type of data we collect and use through the Platform and how we use certain technologies, such as cookies.  This Policy will help you understand what information we collect about you when you use our Platform and what choices you can make about the way your information is received and used by us.   

This Policy, applies to our Platform and any other online service where this Policy is posted (collectively the “Services”).  The Privacy should be reviewed every time you access the Services, and can be updated from time to time, updated terms will be posted here. By using the Platform or Services, you acknowledge that you have read, and agree to this Policy.   

Our Policy ensures compliance with processing principles established by: (i) Regulation (EU 679/2016) the General Data Protection Regulation (“GDPR”); (ii) California Consumer Privacy Act (“CCPA”); (iii) EU ePrivacy Directive; (iv) the Personal Information Protection and Electronic Documents Act (“PIPEDA”). 

This Policy is divided into 2 parts:  Part 1 deals with the collection, use and protection of User Data and Part 2 deals with our cookie policy. 

PART 1:  USER INFORMATION: 

Clancy collects data, including personal information and other information from and about you, in order to provide the Services and operate the Platform effectively, and to enhance your experience on the Platform.  Personal information is data that identifies an individual either directly or indirectly.  You have choices about the data we collect.   

This Part 1 explains what type of User data is collected, how it is used by Clancy and its Customers. 

1. User Information Collected:
2. The data we collect depends on the context of your interactions with the Platform, the Services you use and the choices you make (including your privacy settings).  When you are asked to provide personal data, you may decline.  But if you choose not to provide data that is necessary to provide the Services on the Platform available to you, you may not be able to sign up for or use the Services or the Platform.

  The data we can collect can include the following: 

• Login and Payment Information, including email address, electronic wallet address, password and personal contact information.  You may be able to access some of the Services using Social Sign-On information.;
• Personal contact information, including your first and last name, e-mail address, mailing address, telephone or mobile number;
• Demographic Information, including your age, gender, nationality, 
• Technical and Device Information, including information about your device, such as the type and model, manufacturer, operating system, IP address, mobile browser, and referring URLs or network connection used;
• Log Information, including the date and time, time zone, and session start/stop time and cookie information;
• Information about Orders, including information collected when you purchase or sell a Video Card or other product or Service;
• Geographic Information, including inferred geo-location of your device, including the country, region, city, postal code, latitude and longitude;
• Social Sign-On Information, including login information, profile information and friends lists from a social network that you choose to share when accessing the Services and the Platform via the Social sign-on option; and
• Information about Interests and User Generated Content, including information you post or upload, including comments, , interests, preferences, videos, photos or social media.

1. How we collect Information

We collect data from you in the following ways: 

• Directly: we collect information provided voluntarily by you during your interactions with the Platform and your use of Services, including when you: 
• Create an account or register for the Services;
• Participate in online activities, applications, contests (or other promotions);
• Post-user generated content;
• Place an order to buy or sell a Video Card, or otherwise interact with Collectible Video Cards;
• Subscribe to updates, newsletters or other marketing communications; and
• Contact us directly for customer service, support, or with a question or comment.
• Indirectly/Automatically: we also collect information indirectly, including:
• Through the use of cookies and similar technologies (see below in Cookies Section);
• Through third parties, including if you choose to access the Platform or register through third party applications, such as a social network, then Clancy will receive information from such application; and
• Through mobile devices we may collect location information provided by mobile devices interacting with the Platform or associated with your IP address or Wi-Fi-network (you can generally limit or prohibit the collection of this information using the built-in settings on your mobile devices – check the device for instructions).

1. How we Use the Information Collected

Clancy collects data from and about you in order to operate the Platform and provide the Services, properly implement contractual arrangements between us, serve your needs, manage our content and advertising, operate efficiently and improve our Services and Platform. 

We collect information, and such information can alone or combined with other information collected, be used to: 

• Provide the Platform and the Services to you, including performing essential business operations;
• Provide technical support, diagnose problems and to provide customer care;
• Personalize and optimize your experiences with the Platform and the Services;
• Understand our Platform users and improve our products and services;
• Enable you to buy, sell and interact with Collectible Video Cards;
• We may use your information to send to administer contests, promotions, surveys and other site features;
• To communicate with you, including to respond to inquiries and requests, inform you about your account, security updates and other information about the Platform ;
• To prevent, detect, mitigate and investigate fraud, security breaches and activities that are or may be banned or illegal;
• Send you, or other individuals you identify, marketing communications on behalf of Clancy and select non-affiliated third party companies, and to improve our advertising campaigns, in an effort to prevent targeting you with advertisements that are not relevant to you;
• to organize local events;
• To comply with laws and protect our legal rights and the legal rights of others; and
• As we believe is necessary or appropriate under applicable law, to respond to requests from government authorities and comply with the legal process.

1. Disclosure of User Data To Third Parties

As noted above, Clancy uses third parties as processors of data.  Additionally, we share User data with your consent, or as necessary to make the Platform available to you.   

We also share your data: 

• With third party vendors working on our behalf, including for example cloud hosting services, off-site backups and customer support as well as payment processors;
• As part of a corporate transaction such as a corporate sale, merger, reorganization, dissolution or similar event;
• Additionally, we will share, access, transfer, disclose, and/or preserve personal data when we have a good faith belief that doing so is necessary to:
• Comply with applicable laws or respond to legal processes, judicial orders or subpoenas
• Respond to requests for public or governmental authorities, including for national; security or law enforcement purposes (including money laundering);
• Protect the interest of our users, customers or third parties;
• Operate and maintain security or integrity of the Platform including to prevent or stop an attack on our systems or networks;
• Protect our rights, the platform, our interests and properties, as well as the rights, interest and property of third parties;
• Prevent or investigate possible wrongdoing in connection with the Services or use of the Platform; and
• Enforce our Terms of Use

We may use and share aggregated non-personal information with third parties for marketing, advertising and analytics purposes.  We do not sell or trade your personal information to third parties. 

1. How do we Protect your Personal Information?

We will use a variety of technical and organizational measures to safeguard your personal information and to minimize the likelihood of data breaches, whether pre-emptive or not. Data breaches and protection of data itself comes under the wider umbrella of the data lifecycle. 

Secure auditory practices are carried out to ensure standardized operations and encryption practices. New techniques are continually implemented in order to keep our data security ahead of the curve. 

Compliance of some of our Services with the Payment Card Industry Data Security Standard (PCI DSS) is in itself an evidence that we are doing our very best to keep our customers’ valuable information safe & secure and out of the hands of people who may fraudulently use that data. PCI DSS ensures technical and operational strengths to raise the bar on our security. 

Our systems are on Amazon Web Services (AWS) behind significant levels of firewalls and we run ongoing penetration testing.  User profile data is stored in the AWS Cognito platform where it is encrypted both at rest and in transit in accordance with industry standards. Data resilience and security is ensured via the Cognita AWS cloud platform. 

The storage location(s) are chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the data in the event of an outage or other problem. We take steps to ensure that the data we collect is processed according to the provisions of this Policy and the requirements of applicable law wherever the data is located. 

This family of standards help us manage the Data and keep it secure. 

1. Processing Systems and Confidentiality

We encrypt critical data such as card and personal data in our vault.   We have implemented processes to help ensure availability, business continuity and prompt disaster recovery.  We are committed to maintaining strong physical and logical access controls and conduct pre-emptive penetration testing. 

1. Transmission of Data Internationally

As the Platform is part of a global network, we may transfer and process information that we collect about you including personal information and may be stored and processed in the United States, Canada or in any other country where Clancy or its affiliates, subsidiaries or service providers maintain facilities, and we may use cloud services whose servers may be anywhere in the world.    

Please note that data protection laws of some countries, such as Canada and the United States, may not offer a level of privacy protection equivalent to that within the European Economic Area (EEA) or your home country.  If your use of the Platform and Services results in the transfer of personal information from the EEA to non-EEA countries that have not been deemed to offer an adequate level of privacy protection, we may rely on (i) standard contractual clauses approved by the European Commission in our contracts with parties that receive information in such countries, and (ii) adequate supplementary safeguards.  By using the Services and the Platform, you expressly consent to such transfers.    

To learn more about the European Commission’s decisions on the adequacy of the protection of personal data in the countries where we process personal data, please visit:   https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en 

1. User Privacy Rights

(a) Generally 

You have the right to access, update and correct factual inaccuracies in personal information that we collect through the Services, subject to certain exceptions. If you have created an online account, you can access, update, and delete your personal information or request to delete your account by logging in to your account through the Services. Any requests you submit will be reviewed and, if approved, processed by our staff.  We may retain certain information as necessary to pursue legitimate business interests or resolve disputes or as required by applicable laws. To protect your privacy and the security of your personal information, we will take reasonable steps to verify your identity before granting access to your personal information or deleting your account. 

(b) European Residents 

If you are a citizen of an EEA member state, the General Data Protection Regulation (EU) 2016/679 (“GDPR”) provides you certain rights with respect to your personal information. You have the following rights, with certain exceptions: 

• Right to access your Personal Information – including the right to obtain a confirmation of whether or not Data is being processed and when it is being processed, access to the Data;
• Right to rectification - the right to have the personal information rectified if it is inaccurate or incomplete;
• Right to erasure - the right to request the erasure of Data; 
• Right to restriction of processing - the right to obtain the restriction of processing of the Data;
• Right to data portability - the right to request a copy, or transfer of Data; and
• Right to object - the right to object to the processing of the Data and to not be subjected to automated decision-making or profiling.

While we will attempt to fulfill your request to exercise these rights, sometimes, we may have legal grounds or obligations to reject your request. You will not have to pay a fee to exercise any of the aforementioned rights.  

If a User is a citizen of an EEA member state, you have the right to lodge a complaint before the competent supervisory authority within the EEA should they believe that their Data is not being processed in accordance with applicable laws or with any concerns you have related to our privacy practices. 

We request that you contact us first, by email, at privacy@clancyworld.com if you have any complaints, so we can attempt to investigate and resolve your concerns. 

(c) California Residents 

• Description of Rights

If you are a resident of California, the California Consumer Protection act provides you with certain rights.  You have the following rights: 

• Right to access– you have the right to request certain information about our collection and use of your personal data over the past 12 months;
• Right to erasure - the right to request the erasure of such personal information; 
• Right to opt-out – the right to opt-out of having their personal information sold to third parties; and
• Right to be informed – on how to exercise your above rights
• Right to not be discriminated against – we will not discriminate against you for exercising your rights under the CCPA

For clarity, Clancy does not sell (as defined in the CCPA) personally identifiable information to any third parties. 

• Requests

To exercise the rights described above, you must, in addition to being a resident of California, send us a request that provides sufficient information,  

• to allow us to verify that (A) you are the person about whom we have collected personal data; and (B) you, as the requester, are the same person as the data subject for whose information you’re requesting (or such person’s parent/guardian);
• that describes your request in sufficient detail to allow us to understand, evaluate and respond to it, 
• that declares, under the penalty of perjury, that you’re exercising your rights under the CCPA as a California resident solely for lawful purposes, and
• in a way that does not and would not unduly burden or otherwise abuse our data request system and/or our App. 

Each request that meets all of these criteria, and which is confirmed via email verification, will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria.  

We will use commercially reasonable efforts to determine whether a request may be for harmful, fraudulent, deceptive, threatening, harassing, defamatory, obscene, or otherwise objectionable purposes, and we reserve the right not to respond to such request.  

We will only use your personal data provided in a Valid Request to verify your identity and complete your request. You do not need an account on the Platform to submit a Valid Request. 

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request. 

• Where to submit a request

You may submit a request using the following methods: 

Email us at: privacy@clancyworld.com  

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf. 

(d) Conflict 

If there are any conflicts between sections (b) or (c) and any other provision of this Privacy Policy and you are a resident of the geographic location noted in (b) or (cd), the portion that is more protective of your personally-identifiable data will control to the extent of such conflict. 

1. Legal Basis for Processing User Information

The GDPR requires that we inform you of the legal bases we rely on to process your personal information. The legal bases for processing are set forth below: 

• Contractual – for the performance of a contract with a User, including when a User purchases goods or services;
• Our Legitimate interests – including for example the maintenance of security systems; communications with a User generally, and answering a User’s questions, respond to requests, conduct surveys, protection of our rights and rights of others;
• Compliance with laws – to comply with legal and regulatory requirements or to respond to a court order or legal request; and
• Consent – where we rely on consent of a User to process its personal information, which consent can be withdrawn by a User at any time.

1. Data Storage and Retention 

We may retain your Personal Information so long as you continue to use the Platform, or for as long as is necessary to satisfy the purposes described in this Policy, or to otherwise satisfy legal, regulatory, tax accounting or reporting requirements, and for legitimate and lawful business purposes.  In some cases, we may anonymize your personal information for research or statistical purposes, in which case we may use the information indefinitely without further notice to you 

The Data will be hosted on AWS and Google Cloud Platform which servers are located in Frankfurt, Germany.   

We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children. We will never knowingly collect any personal information about individuals under eighteen (18) years of age. If we obtain actual knowledge that it we have collected personal information about an individual under eighteen (18) years of age, we will take steps to delete such information. 

1. Changes to Privacy Policy

Clancy reserves the right to modify this Policy at any time, so please review it frequently. If we decide to amend our Policy, we will post the updated version, together with an updated Effective Date, on this page. Any changes to the Policy will be effective as of the date they are posted.  We encourage you to check this page periodically for any changes.  If there are material changes to the Policy or in how we will use your personal data, we will notify you either by prominently posting a notice of such changes prior to their taking effect or by sending you a notification directly.  Your continued use of the Platform following the posting of an updated Policy will constitute your acceptance of any and all changes. 

1. Third Party Links.

The Platform may contain links to websites managed by third parties ("Third Party Websites"), at our discretion. For example, when you place an order or register on the Platform where transactions are handled by a third party vendor, and not us, those transactions are conducted through the third party vendor’s website and are subject to such vendor’s policies and terms of use.  Please be aware that we are not responsible for the privacy practices of Third Party Websites. We encourage you to be aware when you leave the Platform and ensure you read the privacy policies of each and every website or application that collects personally identifiable information. We are not responsible or liable for the content or activities of these linked sites.  This Policy applies solely to information collected by the Platform.  Notwithstanding the foregoing, we welcome feedback about these Third Party Websites. 

1. Contact us

If you have any questions or suggestions regarding our Privacy Policy or our privacy practices, you may contact us in the following ways: 

Address:           Clancy International Inc. 

125 Don Hilock Drive 

Aurora, ON L4G 0H8 

Canada 

Attention:  Privacy Officer 

Email: privacy@clancyworld.com 

We will endeavour to respond to questions or concerns within 30 days. 

Please be advised that, although we take every reasonable precaution available to protect your data and personaI information, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, we cannot warrant that your information will be absolutely secure. Any transmission of data at or through our Platform is at your own risk.  

PART 2 - COOKIE POLICY 

This Part 2 will tell you about how and why we use cookies and provide you with information on how to manage the cookies stored on your device.  All Cookies used by the Platform are used in accordance with the current applicable legislation to Cookies. 

1. What is a cookie?

Cookies are small files that websites or apps place on your computer or mobile device as you browse the web or access an app.  Cookies and similar technologies are used by your computer's browser to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personally identifiable information. Most web browsers automatically accept cookies. You can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. However, some sites may not function properly if you disable cookies. We may request your consent for the use of certain cookies, in accordance with the current applicable legislation to cookies. 

1. Cookies and the Platform
2. Purpose of cookies

Clancy and its third party service providers, including advertising and analytics partners, use cookies to automatically collect information about your use of the Platform and the Services.  We use cookies and similar technologies in order to enhance your experience with the Platform.   Cookies collect information about your online behaviour and allows content to be customized to you and to enhance your experience.  Cookies can provide faster and easier interaction between users and platforms. 

1. What Types of Cookies do we use?

Different types of cookies are used for different functions and have different characteristics.  Persistent cookies remain on your device for a longer period of time and allows a site to recognize you as an existing user, and are activated when you return to the Platform.  Session cookies are temporary and last for a session. 

We generally use the following types of cookies and other technologies, such as GIF files, pixel tags or web beacons for the following purposes: 

• Essential cookies.  These cookies enable you to use our services. These cookies are essential to enable you to browse our Services and use certain features. Disabling them may prevent you from using certain parts of the Services. These cookies also help keep our Services safe and secure.
• Preference cookies.  These cookies store information such as your login data, if applicable, and website preferences. Without these cookies, our Services may not be able to remember certain choices you’ve previously made or personalize your browsing experience by providing you with relevant information. These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.
• Performance cookies.  These cookies collect information about how you use our Services such as which pages you visit regularly. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages.
• Content / advertising cookies.  These cookies gather information about your use of our services so we may improve your experience and provide you with more relevant content and advertising on our services and elsewhere online and across your devices. They are also used to gather feedback on customer satisfaction through surveys. They remember that you’ve visited our services and help us understand usage of our services. Some of these cookies are from third parties that collect information about your use of our services in order to provide advertising (on our services and elsewhere, across your different devices) based on your online activities (so-called “interest-based advertising”). We do not control the privacy practices of these third parties, and their practices are not covered by this Privacy Policy.
• Social – these allow a User to share content across platforms and to sign in with your social network ID

1. Specific Information about this Site and Cookies

Click Here for a list of the types of cookies currently being use on the Platform.   

Some of the cookies used on our Platform, as noted above, are managed for us by third parties.  Where this is the case we don't allow the third party to use the cookies for any purpose other than those listed above. 

Please note that as third party relationships may change, this list may not always be comprehensive.  Not all technologies listed may be used for all of the Services or in all jurisdictions. 

1. Personal Data collected by cookies

Cookies in and of themselves do not require or hold personal information.  They cannot personally identify an internet user.  However, personal data can be collected by using cookies to facilitate certain user features, improving the Internet browsing experience.  Such data is encrypted in a way that does not allow unauthorized people to access them.  If a cookie processes personal data, we will ensure that the processing is done in accordance with applicable law and the GDPR. 

1. Managing Cookies

You can control whether or not these cookies are used, by adjusting your browser settings to reject cookies, but preventing them may mean we cannot offer you some Services, and will reduce the support we can offer you on the Platform.  Such choices are browser and device specific.  It is also possible that preventing these cookies will stops us from remembering that you didn't want a specific service.  If you clear cookies from the browser on your devices, your opt-in choices will need to be reset on the Platform. 

Third party partners, like social media sites, may be able to link your activities in the Platform with respect to the Services to your social media registration information.  Please review the social media networks’ privacy policy and the terms that apply to your use of their platforms. 

1. Other useful resources

All browsers allow the User to accept, reject or delete Cookies by selecting the appropriate settings in the respective browser: 

• Chrome https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=en

• Firefox

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences    

• Internet Explorer

https://support.microsoft.com/pt-pt/help/17442/windows-internet-explorer-delete-manage-cookies   

• Safari

https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac  

To learn more about using cookies by advertisers, use the following links: European alliance for Interactive Digital Advertising (EU) https://edaa.eu; , Advertising Standards Canada https://adstandards.ca