PRIVACY POLICY
1. INTRODUCTORY PROVISIONS
1.1. The company VRGENS Limited, ID 126948, incorporated: 09.07.2024 with registered office at Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, 969 60 Marshall Islands, ("Controller", "Company" or "We") in relation to the service, a web-based platform providing access to the Terminal and other AI-related functionalities („Service").1.2. To start using the Service, you must first agree to the Terms and conditions of the Service. By accepting it a binding contract is created between us.
2. PROCESSING OF PERSONAL DATA
2.1. If you use the Service, the Company becomes the controller of your personal data within the meaning of Regulation (EU) No 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("Regulation").3. CATEGORIES OF PERSONAL DATA
3.1. If you are using the Service, we might process the following categories of personal data:3.1.1. Wallet address and other blockchain data: When you connect your cryptocurrency wallet (e.g., MetaMask), we receive your public wallet address. We do not have access to your private keys or seed phrases, and we do not store them on our servers.
3.1.2. Inputs and Outputs - text prompts, messages, files or queries (collectively "Inputs") you enter, as well as the Service's responses ("Outputs")
3.1.3. Technical and usage data: data about your device and browser; IP addresses, information about login times to the Service, usage data, session tokens, and similar tracking technologies to maintain your session and understand how you interact with the Service.
3.1.4. Statistical data: demographic information, geographic, geo-location information, performance data and other statistical data.
3.1.5. Cookies: We use both session and persistent cookies to ensure functionality (essential cookies) and to gather analytics data (non-essential cookies), for which we may ask for your consent if required by law.
3.1.6. Other data: other information in your account you provide us with.
3.2. We strongly discourage you from uploading any sensitive personal data (e.g., health information, biometric data, racial or ethnic origin, political opinions, religious or philosophical beliefs, etc.) to the Service, unless absolutely necessary for the intended purpose.3.1.2. Inputs and Outputs - text prompts, messages, files or queries (collectively "Inputs") you enter, as well as the Service's responses ("Outputs")
3.1.3. Technical and usage data: data about your device and browser; IP addresses, information about login times to the Service, usage data, session tokens, and similar tracking technologies to maintain your session and understand how you interact with the Service.
3.1.4. Statistical data: demographic information, geographic, geo-location information, performance data and other statistical data.
3.1.5. Cookies: We use both session and persistent cookies to ensure functionality (essential cookies) and to gather analytics data (non-essential cookies), for which we may ask for your consent if required by law.
3.1.6. Other data: other information in your account you provide us with.
4. LEGAL TITLE AND PURPOSE OF PROCESSING
We process personal data for the following reasons:4.1. Processing of personal data based on applicable laws
4.1.1. We process your personal data based on applicable laws which apply to our business activities.
4.2. Performance of contractual obligations4.2.1. The date of birth is processed to verify you are old enough to use the Service according to the Terms and conditions.
4.2.2. The address of the electronic wallet and other blockchain data is processed in order to identify you and the history of payments.
4.2.3. Technical data and technical cookies are processed to make the Service functional.
4.2.4. We process other data that you voluntarily provided to us to provide you with the respective services you requested (having more information in your account, support request etc.).
4.2.5. Inputs and Outputs may be temporarily stored on our servers for the purpose of providing the Service, improving its functionalities, and ensuring compliance with our Terms and conditions (e.g., to detect prohibited content). We may retain such Inputs and Outputs for a limited time, after which they are either anonymized or deleted unless otherwise required by law.
4.3. Processing of personal data based on legitimate interest4.2.2. The address of the electronic wallet and other blockchain data is processed in order to identify you and the history of payments.
4.2.3. Technical data and technical cookies are processed to make the Service functional.
4.2.4. We process other data that you voluntarily provided to us to provide you with the respective services you requested (having more information in your account, support request etc.).
4.2.5. Inputs and Outputs may be temporarily stored on our servers for the purpose of providing the Service, improving its functionalities, and ensuring compliance with our Terms and conditions (e.g., to detect prohibited content). We may retain such Inputs and Outputs for a limited time, after which they are either anonymized or deleted unless otherwise required by law.
4.3.1. We process statistical data in order to prevent misuse of the Service, to ensure the functioning of the Service and improving the Service. The statistical data are processed in pseudonymised form, so that nobody except for us is able to match the data to the user. This processing is based on our legitimate interest, which is the continuous improvement of the Service.
4.3.2. Some of the statistical data can be used to prove cheating or another breach of Terms and conditions.
4.3.3. We might process your contact details to offer you similar goods or services to the Service. We can also send you information about news from our company, Christmas or birthday wishes and other information related to our brand and our products.
4.3.4. We may also analyze Inputs and Outputs to improve the AI model's accuracy and performance. This processing is based on our legitimate interest in continuously improving the Service. Where possible, we use anonymization or pseudonymization techniques to minimize the impact on your privacy.
4.4. Consent4.3.2. Some of the statistical data can be used to prove cheating or another breach of Terms and conditions.
4.3.3. We might process your contact details to offer you similar goods or services to the Service. We can also send you information about news from our company, Christmas or birthday wishes and other information related to our brand and our products.
4.3.4. We may also analyze Inputs and Outputs to improve the AI model's accuracy and performance. This processing is based on our legitimate interest in continuously improving the Service. Where possible, we use anonymization or pseudonymization techniques to minimize the impact on your privacy.
4.4.1. We might ask you, if you want us to process some of your data to use them for: marketing purposes: such as sending marketing communications, newsletters, or personalized offers (that do not fall within our legitimate interest). Cookies.
5. PROCESSORS, RECIPIENTS, AND TRANSFER OF PERSONAL DATA
5.1. For the effective operation of the Service and our company, we have contracts with other service providers to whom we may pass your personal data for processing. In particular, the following may process your personal data:5.1.1. Victoria VR, a.s., ID number 09695346, with its registered seat at Václavské náměstí 796/42, 110 00 Prague 1, Czech Republic, registered at Municipal Court in Prague, file number B 25843 established under the Czech law
5.1.2. payment partners
5.1.3. software and IT service providers (e.g. Google, Microsoft)
5.1.4. marketing service providers
5.1.5. legal service providers
5.2. We process your personal data exclusively in European Union countries. Outside of the European Union, we might process your personal data only if it is necessary for the performance of our contractual or legal obligations.5.1.2. payment partners
5.1.3. software and IT service providers (e.g. Google, Microsoft)
5.1.4. marketing service providers
5.1.5. legal service providers
6. STORAGE TIME
6.1. We process personal data only for the time necessary to fulfil the purpose of processing or for the time required by law. The storage period varies depending on the legal title of the personal data processing:6.1.1. If the legal basis for the processing of personal data is the performance of contractual obligations, we process personal data for the duration of our contract and then 4 years after the contract is terminated or for period prescribed by or in accordance with applicable law.
6.1.2. If the legal basis for the processing of personal data is the fulfilment of our legal obligations, we process personal data for the period of time required by law.
6.1.3. If the legal basis for the processing of personal data is our legitimate interest, we process personal data for the duration of the legitimate interest, or until you notify us that you do not wish us to process the personal data further and then 4 years after the contract is terminated or for period prescribed by or in accordance with applicable law.
6.1.4. If your consent is the legal basis for the processing of your personal data, we will process your personal data for no longer than the duration of your consent.
6.1.2. If the legal basis for the processing of personal data is the fulfilment of our legal obligations, we process personal data for the period of time required by law.
6.1.3. If the legal basis for the processing of personal data is our legitimate interest, we process personal data for the duration of the legitimate interest, or until you notify us that you do not wish us to process the personal data further and then 4 years after the contract is terminated or for period prescribed by or in accordance with applicable law.
6.1.4. If your consent is the legal basis for the processing of your personal data, we will process your personal data for no longer than the duration of your consent.
7. YOUR RIGHTS
7.1. In particular, you have the following rights in relation to your personal data:7.1.1. Right of access to personal data - you can contact us at any time to ask if we are processing your personal data and, if so, to request further information about this processing.
7.1.2. The right to correct or supplement personal data - if your personal data changes during the processing or if you feel that the data we process is incorrect, please contact us.
7.1.3. Right to request restriction of processing - in the cases referred to in Article 18 of the Regulation, you have the right to request restriction of the processing of your personal data.
7.1.4. Right to erasure of personal data - in the cases referred to in Article 17 of the Regulation, you have the right to request that we erase personal data concerning you without undue delay.
7.1.5. Right to request data transfer - under the conditions set out in Article 20 of the Regulation, you have the right to ask us to transfer your personal data to a third party.
7.1.6. Right to withdraw the consent to process your personal data. Where we process your personal data based on your consent You can withdraw such consent at any time by sending us a request at [email protected].
7.1.7. Right to object - where we process your personal data on the basis of our legitimate interest, you have the right to object to such processing at any time.
7.1.8. Right to lodge a complaint - if you have any doubts about our compliance with our obligations related to the processing of personal data, you have the right to lodge a complaint with the data protection regulator in your jurisdiction.
7.1.2. The right to correct or supplement personal data - if your personal data changes during the processing or if you feel that the data we process is incorrect, please contact us.
7.1.3. Right to request restriction of processing - in the cases referred to in Article 18 of the Regulation, you have the right to request restriction of the processing of your personal data.
7.1.4. Right to erasure of personal data - in the cases referred to in Article 17 of the Regulation, you have the right to request that we erase personal data concerning you without undue delay.
7.1.5. Right to request data transfer - under the conditions set out in Article 20 of the Regulation, you have the right to ask us to transfer your personal data to a third party.
7.1.6. Right to withdraw the consent to process your personal data. Where we process your personal data based on your consent You can withdraw such consent at any time by sending us a request at [email protected].
7.1.7. Right to object - where we process your personal data on the basis of our legitimate interest, you have the right to object to such processing at any time.
7.1.8. Right to lodge a complaint - if you have any doubts about our compliance with our obligations related to the processing of personal data, you have the right to lodge a complaint with the data protection regulator in your jurisdiction.
8. THE SOURCES OF YOUR PERSONAL DATA
8.1. We acquire your personal data from the following sources:8.1.1. Directly from you during your registration to Service, using Service or other of our services where necessary, by filling forms during your use of the Service or by direct communication with you.
8.1.2. From monitoring of the use of the Service.
8.1.2. From monitoring of the use of the Service.
9. CONTACT
9.1. If you want to contact us, make a complaint, ask us about anything related to the processing of your personal data or tell us that you do not want us to process your personal data, you can use the following contact details:Victoria VR, a.s.
Václavské náměstí 796/42, 110 00 Prague 1,
Czech Republic
E-mail: [email protected]
10. DATA SECURITY
10.1. In order to secure your data against unauthorized or accidental disclosure, we apply reasonable and appropriate technical and organizational measures, which are continuously updated. The technical measures consist of the deployment of technologies preventing unauthorised access to the data by third parties. Organizational measures are a set of rules of conduct of our coworkers and are part of our internal regulations, which are considered confidential for security reasons. If our servers are located in a data centre operated by a third party, we ensure that the technical and organisational measures are also implemented at this provider.11. OTHER AND FINAL PROVISIONS
11.1. If you refuse to provide personal data necessary for the above purposes, we may not be able to provide you with our service.11.2. We process personal data via software, so the processing is at least partially automated.