PRIVACY POLICY

1. GENERAL PROVISIONS

Our Privacy Policy was last updated on 06.08.2022

This Privacy Policy (“Privacy Policy”) governs the collection, processing, and use of your Personal Information/data by Verko Technologies AG (“Verko”).

The following information will provide you with an overview of how we collect your data as well as the purposes we use this data for when you use our (i) software, products, platforms, technologies and services that post a link to this Privacy Policy or made available through the Website (the “Products”), and (ii) Website (collectively (i) and (ii) are the “Services”).

Verko is committed to protect and respect your privacy and your right to a fair processing treatment of your Personal data. This Privacy Policy is intended to help you better understand how we collect, use, process and store your Personal data and describes your choices regarding certain types of processing. We are aware of the importance of how Personal data are handled and we assure you that we observe all applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

Unless otherwise indicated, terms used in this Regulation shall have the same meaning as under GDPR.

This Privacy Policy is issued on behalf of Verko Technologies AG so when we mention "Verko", “we”, “us” or “our” in this Privacy Policy, we are referring to the company Verko Technologies AG and its related group of undertakings, responsible for processing your data.

If you have any questions about this Privacy Policy, including any requests, please use the contact details set out below.

Full name of legal entity:        Verko Technologies AG

registration number:        FL-0002.687.030-3

E-Mail Address:        privacy@verko.io 

Postal Address:        Werdenbergerweg 11, 9490 Vaduz, Liechtenstein

When you contact us by e-mail or via a contact form, the data you provide (your e-mail address, name, and telephone number, if applicable) will be stored by us in order to answer your questions. We delete the data accruing in this context, if the inquiry is assigned to a contract, after the time limits for the term of the contract, otherwise after the storage is no longer necessary, or restrict the processing if there are legal obligations to retain data.

You have the right to make a complaint at any time to the Liechtenstein’s Data protection Office (https://www.datenschutzstelle.li/). We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Office, so please contact us in the first instance.

2. DEFINITION

1. “consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. "Cookies" are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
3. “data subject;” an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
4. "Device" means any device that can access the Service such as a computer, a cell phone or a digital tablet.
5. “personal data” means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
6. "pixels” (also called web beacons) are invisible pixels that are placed on webpages or in emails that use this technology for marketing and measurement purposes.
7. “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
8. “pseudonymisation” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
9. “processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
10. “recipient” means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the 4.5.2016 EN Official Journal of the European Union L 119/33 framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be following the applicable data protection rules according to the purposes of the processing.
11. ‘third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
12. “representative” means a natural or legal person established in the Union who, designated by the controller or processor in writing pursuant to Article 27, represents the controller or processor with regard to their respective obligations under this Regulation.
13. "Service" refers to the Products and the Website.
14. ‘supervisory authority concerned’ means a supervisory authority which is concerned by the processing of personal data because:

1. the controller or processor is established on the territory of the Member State of that supervisory authority;
2. data subjects residing in the Member State of that supervisory authority are affected or likely to be affected by the processing; or
3. a complaint has been lodged with that supervisory authority.

1. "Usage Data" refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
2. "Website" refers to Verko Website, accessible from https://verko.io, and its subdomains.
3. "You" means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

3. YOUR LEGAL RIGHTS

1. Right of access and information

You have the right to request from us free confirmation of the processing of the data in question and to be informed of such data and to receive further information and a copy of the data in accordance with the provisions of the law. The subject of the information is the stored personal data themselves, the origin of the data, their recipients, and the purpose of the data processing (cf. Art. 15 GDPR).

2. Right of rectification

You have the right to correct your Data when it is inaccurate or incomplete (for example, change your address).

3. Right to cancellation or blocking

You have the right to demand from us as the responsible party the immediate deletion of the data concerned or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions (cf. Art. 17, 18 GDPR).

4. Right to data transfer

You have the right to demand from us that we hand over to you or pass on to third parties the data concerning you which you have made available to us in accordance with the statutory provisions (cf. Art. 20 GDPR). Direct transfer to another responsible party is subject to technical feasibility.

5. Right to object and withdraw your consent

You may withdraw consent at any time where we are relying on consent to process your personal data. However, we note that this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will of course advise you if this is the case at the time you withdraw your consent. At any time, you may withdraw your consent or object to the receipt of newsletters and advertising emails, the personalization of advertisements or the sharing of your Data with our partners (except for technical service providers) by email request to privacy@verko.io 

We will not discriminate against and, therefore, not deny requests without legal reason to you that choose to exercise your rights.

We will consider all requests to exercise your rights and provide our response without undue delay (and in any event within one month of your request unless we tell you we are entitled to a longer period allowed by applicable law).

Certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims. If an exception applies, we will tell you this when responding to your request. 

We may request you provide us with information necessary to confirm your identity before responding to any request you make.

If you feel that your rights have not been respected after having contacted us, you have the right to make a complaint to the competent supervisory authority. For Liechtenstein, the competent authority is:

Datenschutzstelle Liechtenstein:

Städtle 38

Postfach 684

FL-9490 Vaduz

T +423 236 60 90

info.dss@llv.li

4. CONTROLLER

Controller for the purpose of the GDPR, other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

Verko Technologies AG

Werdenbergerweg 11, 9490 Vaduz

Principality of Liechtenstein

http://verko.io

Email: privacy@verko.io 

5. PROCESSING OF PERSONAL DATA WHEN VISITING OUR WEBSITE

When using the Website for informational purposes, i.e. merely viewing it without registering and without you providing us with any other information, we process the personal data that your browser transmits to our server. The data described below is technically necessary for us to display our Website to you and to ensure stability and security and must therefore be processed by us. The legal basis is Art. 6 (1) lit. f GDPR:

• IP address
• Date and time of the request
• time zone difference to Greenwich Mean Time (GMT)
• Content of the request (page visited)
• Access status/HTTP status code
• amount of data transferred
• previously visited page
• Browser
• operating system
• language and version of the browser software.

1. COOKIE POLICY

Our Websites and pages use what the industry refers to as “cookies” or “pixels”. We use cookies or similar technologies on our Website for identification and analysis purposes. We also use cookies and similar technologies to analyse how our Website visitors interact with our Website and to serve advertisements to our Website visitors when they are browsing other areas of the internet.

Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (“session cookies”) or they are permanently archived on your device (“permanent cookies”). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser. Tracking pixels work in a similar way to cookies and may allow us to gather information about your behavior on our Website or emails received from us.

In some cases, it is possible that third-party cookies are stored on your device once you enter our Website (“third-party cookies”). These cookies enable you or us to take advantage of certain services offered by the third party.

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g., the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages.

Cookies, which are required for the performance of electronic communication transactions, or for the provision of certain functions you want to use or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR; this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this Website may be limited.

In the event that third-party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.

The first time you visit our Website from an internet browser you will be asked to set your cookie preferences using a ‘cookie manager’. The only cookies that will be delivered by default are those that are strictly necessary for Website performance. All other types of cookies will be set to ‘off’ unless you choose to turn them on. You may need to refresh your page for your settings to take effect. If you click accept all cookies, then all types of cookies will be switched on.

Your preferences will be remembered for one year. This is because the ‘consent cookie’ will expire after one year. You will be then asked to choose your preferences again. If you wish to reset your cookie preferences using the cookie manager, please click here.

2. COLLECTION OF YOUR PERSONAL DATA

Verko may collect, use, store and transfer different kinds of Personal data about you which we have grouped together as follows:

1. Personal information:

This is Personal information you may give us about you by filling in forms within our Services, including when creating account to use our Services, and/or corresponding with us by mail, phone, email or otherwise among other things to provide us with the required Personal information ("Submitted Personal information").

Submitted Personal information in particular includes:

1. Identity data: first name, maiden name, last name, title, date of birth, username, password, and other registration information and/or similar identifiers (if applicable),
2. Contact data: address, e-mail address, phone number, billing address (if necessary),
3. Marketing and Communications Data which includes your communication preferences.

2. Automated Personal data

This is Personal information collected by using automated technologies or interactions ("Automated Personal data").

You may give us this Personal information about you in order to interact with our Services. We may automatically collect:

1. Technical Data: includes the IP address, information on your internet service provider, device type, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, and other technology on the devices you use to access the Services. This also includes information about your use of the Services, including the type of browser time and date of access, pages viewed, and the page you visited before navigating to our Services.
2. Device Data: includes information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
3. Usage Data: includes information about how you use the Services.
4. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data will be derived from your personal data but will be anonymized to the point that it is not considered personal data as this data does not directly or indirectly reveal your identity nor allows any conclusions to be drawn. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the Services. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with the relevant data protection laws and this Privacy Policy.

Verko collects all this Personal data by using cookies, server logs and other similar technologies. This allows us to recognize Users and avoid repetitive requests for the same information. With automation technologies we track, collect, and store the User behavior on the Website.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. Information from other sources

We also collect data from the game publishers who make their games available to you through our Products, such as your usage data in the games and balance of your purchases within Apple (iOS) and Google (Android) stores, solely as required to update balances on your wallet / account you maintain within the Services.  

Our partners are responsible for the data about you processed within their services, and we recommend that you review their privacy policies.

3. USES MADE OF THE DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your data in the following circumstances:

• to provide you with the Services you request, including to allow your installation of the Products;
• create and maintain your account / wallet with us;
• carry out our obligations arising from any agreements entered into between you and us;
• to communicate with you about your use of the Services and to provide support;
• Part of the data is collected to ensure a flawless provision and security of the Website;
• To contact You;
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information;
• To manage Your requests: To attend and manage Your requests to Us;
• Other data can be used to analyse your user behaviour and prepare reports or compile statistics to understand the type of people who use our Services, how they use our Services and to make our Services more intuitive. If not necessarily in direct connection to your account or to your direct benefit within the Services, such details will be anonymized and you will not be identifiable from the information collected;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• Where we need to comply with a legal obligation;
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our service, products, services, marketing and your website experience.

1. LEGAL BASIS FOR PROCESSING PERSONAL DATA under GDPR

We may process Personal Data under the following conditions:

• Performance of a contract: Provision of Personal Data if it is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which Verko is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in Verko.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

2. TRANSFER OF DATA

We may share your Data with:

• With Service Providers: We may share Your personal information with Service Providers of Verko that help us operate our business, our Services or administer activities on our behalf, such as Amazon Web Services providing us with cloud solutions; third parties who provide us with technical support, such as our IT providers.
• With Game Publishers: We may share Your data (such as email, nickname, information about your NFT collections, token balance of your wallet) with the Game Publishers who use our Services to make their games available to you in case you use a relevant game and as required for you to access and use the respective game.
• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.; and/or;
• Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, any third party to which we sell or transfer our assets will have the right to continue to use the personal and other information that you provide us in the manner set out in this Privacy Policy.
• Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

1. TRANSFER OF DATA TO NON-EU COUNTRIES

Among other things, we use tools of companies domiciled in the United States or other from a data protection perspective non-secure non-EU countries. If these tools are active, your personal data may potentially be transferred to these non-EU countries and may be processed there. We must point out that in these countries, a data protection level that is comparable to that in the EU cannot be guaranteed. For instance, U.S. enterprises are under a mandate to release personal data to the security agencies and you as the data subject do not have any litigation options to defend yourself in court. Hence, it cannot be ruled out that U.S. agencies (e.g., the Secret Service) may process, analyse, and permanently archive your personal data for surveillance purposes. We have no control over these processing activities.

Among other things, we use tools and services of companies domiciled outside the EU. If such tools are active and your personal data is being transferred outside the EU, we make sure that the transfer is made only to countries that have been declared as offering an adequate level of protection through a European Commission decision (‘Adequacy Decision’). In absence of an Adequacy Decision, appropriate safeguards are in place and asserted by each contractual party.

2. STORAGE DURATION

Unless a more specific storage period has been specified in this Privacy Policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible obligations for storing your personal data; in the latter case, the deletion will take place after these obligations cease to apply.

3. MARKETING

We may use your Personal data to form a view on what we think you may want or need or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. With regard to our marketing and advertising purposes Verko is striving to provide clear information of Personal data usage. We provide you clear choices on your Personal data uses. You can always access your personal communication preferences management page via our e-mail (privacy@verko.io) and have the possibility to opt-out any time from receiving any marketing communications from us by adjusting your preferences in communication preferences management page, accessible in e-mail or by sending your choice to privacy@verko.io.

4. CONTACT FORM

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions.

The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or on your agreement (Art. 6(1)(a) GDPR) if this has been requested.

The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.

5. ANALYSIS TOOLS AND ADVERTISING

Google Analytics

This Website uses functions of the web analysis service Google Analytics. The provider of this service is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and/or its affiliates.

Google Analytics uses so-called cookies. Cookies are text files, which are stored on your computer and that enable an analysis of the use of the website by users. The information generated by cookies on your use of this Website is usually transferred to a Google server in the United States, where it is stored. Google will possibly also transmit this information to third parties, insofar as this is prescribed by law or insofar as third parties process these data on behalf of Google.

For more information on how to handle user data on Google Analytics, please refer to the Google Privacy Policy: https://support.google.com/analytics/answer/6004245.

The storage of Google Analytics cookies and the utilization of this analysis tool are based on Art. 6 Sect. 1 lit. f GDPR. The operator of this Website has a legitimate interest in the analysis of user patterns to optimize both, the services offered online and the operator’s advertising activities.

Google Tag Manager

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland and/or its affiliates.

The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our Website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.

The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and administration of various tools on his website. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the GDPR. This consent can be revoked at any time.

Meta Pixel

We also use Meta Pixel. This tool is operated by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. It allows us to understand and deliver ads and make them more relevant to you. The collected data remains anonymous, and we cannot see the personal data of any individual user. However, the collected data is saved and processed by Meta. Meta may be able to connect the data with your Facebook or Instagram account and use the data for their own advertising purposes. Meta has ultimate control of the information gathered through Meta Pixel.

Twitter Pixel

On our Website we use the visitor action pixel of Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA ("Twitter") for statistical purposes. The pixel enables us to track the behaviour of users after they have been referred to our Website by clicking on a Twitter ad. This process is used to evaluate the effectiveness of Twitter ads for statistical and market research purposes and may help to optimize future advertising efforts. The data collected in this way does not allow us to draw any conclusions about the identity of users. However, the data is stored and processed by Twitter so that a connection to the profile of the respective user is possible and Twitter can use the data for its own advertising purposes. This data may enable Twitter and its partners to place advertisements on and outside Twitter. A cookie may also be stored and read on users' computers for these purposes.

6. SOCIAL PLUG-INS ( ((Facebook, Twitter; Linked-in etc.)

Our internet pages do not use social plugins from Facebook and Twitter, this means, when visiting our Website , no information is passed on to the Facebook and Twitter providers. However, you can share content on your own Facebook and Twitter profiles through our Website by visiting links from Facebook and Twitter. You then leave our Website and will be redirected directly to the websites and features of the respective providers. The information that they collect about you can be found in the privacy statements of the respective providers.

Facebook Privacy Policy: www.facebook.com/privacy/explanation 

Privacy Policy from Twitter: https://twitter.com/privacy

Linked-in Privacy Policy: https://de.linkedin.com/legal/privacy-policy

Instagram Privacy Policy: https://instagram.com/about/legal/privacy/

7. Data Security

We use a variety of appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

8. LINKS TO OTHER WEBSITES

Our Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices, statements, or policies.

We encourage you to read the privacy policy of every website you visit.

9. CHANGES TO PRIVACY POLICY

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on the Website.

Where appropriate, We will let You know via email and/or a prominent notice on Our service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

10. CONTACT

If you have any questions about this Privacy Policy, You can contact us by sending us an email: privacy@verko.io