Updated: 28th March 2023

0xtra Ltd, registered in Scotland under registration number SC813737, with its principal office at 6 Morningside Court, Scotland, UK, ("us", "our", "we", "0xtra Ltd"), is the data controller of the personal information collected through our website. 0xtra Ltd is dedicated to safeguarding and respecting your privacy.

This privacy policy (the "Policy") outlines the types of personal data we collect and use when you access and visit www.0xtra.com (the "Website") and describes how we may utilise that data.

This Policy outlines our identity, the reasons and methods for processing personal data collected via your use of our Website, and details your rights regarding such data. It also provides information on how to contact us if necessary.

1. Introduction

2. Data We Collect

3. How is your personal data collected?

4. How and why do we use and share your personal data?

5. Retention of personal data

6. Security

7. International Data Transfers

8. Your Rights

9. Contact Details

10. Introduction

    It is essential that you read this Policy in conjunction with any other privacy notices or fair processing notices we may provide on the Website at the time we collect or process your personal data. This includes, for instance, notices displayed when you sign up for email updates or when you first use one of our services. Doing so ensures you are fully informed about how and why we use your data.

    This Policy complements other notices on the Website, including our [Website Terms and Conditions / Platform Terms] and our Cookies Policy, and should be read in conjunction with those terms. It is not intended to override or replace any of these terms.

    By accessing or using the Website, you consent to our terms (as updated periodically) and this Policy. If you do not agree with the terms of this Policy, please discontinue your use of the Website immediately.

    We reserve the right to modify, update, or amend this Policy at any time to reflect changes in our business practices or legal requirements. When significant changes occur, we will make an effort to inform users, typically by displaying a notification upon your next login to the Website. However, it is your responsibility to review this Policy prior to each use of the Website and stay informed of any changes. For your convenience, the date of the latest update is indicated at the top of this Policy.

    Please be aware that the Website is not intended for use by individuals under the age of 18 ("Children"), and we do not knowingly collect personal data from Children. If you believe that we have inadvertently gathered personal data regarding your Child, please contact us at [email protected] to request the cessation of data processing concerning your Child.

11. Data We Collect

    When this Policy mentions 'personal data,' it refers to information about you that could be used to identify you, such as your name, date of birth, contact details, and IP address.

    By law, all organizations that process your personal data in the UK are required to handle your data in specific ways and provide you with adequate information about how they use it. You also have several rights to inquire about the use of your data and to prevent its unlawful processing. For more details on these rights, please refer to the 'Your Rights' section of this Policy.

    The personal data we collect from you depends on the specific details you provide during your interactions with the Website, and may include:

    • Identity Data: Includes your name, date of birth, gender, and any details from identification documents you provide which may or may not contain health or other special categories of personal data.
    • Contact Data: Includes your email address.
    • Location Data: Includes data about where you access the Website from.
    • Technical Data: Includes your IP address, login data, operating system, and browser type and version.
    • Profile Data: Includes your username and password, social media account details, interests, preferences, feedback, and survey responses, including any personal data contained in content you upload to the Website.
    • Usage Data: Includes information about how you use the Website.
    • Transaction Data: Includes details about payments to and from you and other details of services you have purchased from us or while using the Website.
    • Financial Data: Includes your wallet address, where provided.
    • Audio Visual Data: Includes recordings of you and your contributions or uploads to the Website.
    • Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties, including information about the types of advertisements we believe you are most likely to be interested in.

12. How is your personal data collected?

    When you use the Website, you provide personal data through various forms and questions as part of setting up your account. This includes Identity, Contact, and Financial Data, such as your name and location.

    Any data you voluntarily provide or upload to the Website, such as signing up for the 0xtra platform, subscribing to a creator profile, requesting marketing communications, participating in social media functions, completing surveys, filling out forms, posting comments, entering competitions, or contacting us via email, telephone, or post, may be collected, stored, and used by us.

    Use of the Website

    We collect data you upload and data about your interactions with the Website and other users. For example, if you send a message to another user, we collect the message's content and the fact that you sent it. We also collect data on the posts or content you view, like, or approve. This helps us understand user preferences and interactions.

    Please note that we process data about private messages the same way as public messages. If you use the Website to purchase services or content, we collect information about your interests and individual financial transactions.

    Remember, most things you post on the Website are publicly viewable. We collect information about your posts, which other users can also see.

    Automated Technologies or Interactions

    We collect personal data and information about your technology usage through cookies when you visit and interact with the Website. Examples of information we collect include:

    • Your device, browser, or operating system
    • Your IP address
    • Links you click and pages, content, or profiles you view
    • Length of visits to certain pages, content, or profiles
    • Subjects you viewed or searched for
    • Page response times
    • Records of download errors and broken links
    • Page interaction information (such as scrolling, clicks, and mouse-overs)
    • Methods used to browse away from a page
    • The full URL click stream to, through, and from the Website (including date and time)

    We use this data to ensure the Website works properly, is secure, and to monitor online traffic and audience participation. We have a legitimate interest in these activities.

    For more information on this technology and the cookies we use, please see our Cookies Policy.

    Third Parties or Publicly Available Sources

    We partner with third parties who may collect anonymous usage or statistical data through your use of the Website. This includes business partners, sub-contractors, advertising networks, analytics providers, search information providers.

    We may also obtain personal data from other sources, such as when you log into the Website using your Twitter or Google account. In this case, we will receive personal data like your username, social media account details, location, and IP address.

    Updating Your Information

    If you want to update your information, please do so using the app or contact us at [email protected].

13. How and Why We Use and Share Your Personal Data

    Lawful Basis for Processing Your Information

    We use your personal data only when permitted by law. The most common circumstances under which we process your personal data include:

    • Your Consent: When you have given us explicit permission.
    • Performance of a Contract: When necessary to fulfill a contract we have with you.
    • Legitimate Interests: When it is in our legitimate interests or those of a third party, provided these interests do not override your fundamental rights.
    • Legal Obligations: When we need to comply with legal or regulatory requirements.

    Examples of How We Use Your Information and the Lawful Basis for Doing So

    1. Account Creation and Management (Identity and Contact Data):
       • Purpose: To create and manage your account.
       • Lawful Basis: Performance of a contract.
       • Example: Using your name and email address to set up and maintain your user profile.
    2. Processing Transactions (Financial Data):
       • Purpose: To handle payments and prevent fraud.
       • Lawful Basis: Performance of a contract and legitimate interest.
       • Example: Using your wallet address to securely process transactions.
    3. Improving Services (Technical Data):
       • Purpose: To enhance the functionality and security of the Website.
       • Lawful Basis: Legitimate interest.
       • Example: Collecting your IP address and browser type to troubleshoot technical issues.
    4. Marketing Communications (Marketing Data):
       • Purpose: To send you promotional materials and updates.
       • Lawful Basis: Your consent.
       • Example: Using your email address to send newsletters if you have opted in.
    5. User Interaction (Usage Data):
       • Purpose: To analyze how you use the Website and interact with other users.
       • Lawful Basis: Legitimate interest.
       • Example: Tracking your activity to understand which features are most popular and improve user experience.
    6. Compliance and Legal Obligations (All Data Types):
       • Purpose: To comply with legal and regulatory requirements.
       • Lawful Basis: Legal obligation.
       • Example: Retaining transaction records to meet financial reporting obligations.

    By providing clear examples, we ensure transparency and help you understand how and why we process your personal data.

    Marketing and Advertising

    We may use your personal data to identify services and offers that may be of interest to you. This enables us to personalise our marketing efforts to better align with your preferences.

    You will receive marketing communications from us if you have requested information, purchased content, goods, or services from us, and have not opted out of such communications.

    Opting Out of Marketing

    To unsubscribe from marketing messages, click the unsubscribe link included in any marketing email, you can also unsubscribe via the app. Alternatively, you can contact us directly to stop receiving marketing materials.

    We may retain your contact details to ensure we honour your opt-out request, even after you have unsubscribed from marketing messages.

    Sharing Your Personal Data

    Depending on the context, we may share your personal data as follows:

    • With Official Bodies: To prevent and detect fraud or manage credit risks, we may share data with central and local government bodies, HM Revenue & Customs, regulators, law enforcement agencies, and fraud protection agencies.
    • With Third-Party Service Providers: We may subcontract various services, sharing your data with third parties that host or store data, or provide other IT systems.
    • With Analytics and Search Engine Providers: These third parties assist us in improving and optimising our website.
    • With Content Creators: If you purchase content on the website, we may share your data with the creators of that content.
    • With Professional Service Providers: This includes our insurers, accountants, auditors, and lawyers.

    We may also disclose your personal data to third parties in the following situations:

    • Business Transactions: In the event of a sale or purchase of any business or assets, we may disclose your data to prospective sellers or buyers.
    • Company Acquisition: If 0xtra Ltd or its assets are acquired by a third party, customer data will be part of the transferred assets.
    • Legal Obligations: We may disclose your data to comply with legal obligations or assist in criminal investigations.
    • Protecting Rights: To enforce our terms of use or protect our rights, property, or safety, we may exchange information with other companies for fraud protection and credit risk reduction.

    Service Providers

    Our service providers deliver various administrative, statistical, and technical services. We only provide them with the minimum personal data necessary to perform their services, requiring them to protect this data and use it exclusively for the intended purpose. All data processors sign contracts committing to respect individual rights and assist us in upholding these rights.

    For further information about our service providers, please contact us at [email protected].

    Links to Third-Party Sites

    Our website may contain links to third-party websites, plug-ins, and applications not affiliated with us. These sites are beyond our control and not covered by this policy. If you access these links, third parties may collect your data according to their own privacy policies. Please review these policies before submitting any personal data to these sites.